Remote Therapeutic Monitoring (RTM) CPT Codes 2026: Complete Guide to 98975, 98977, 98985, 98979, 98980, 98981 Billing, Reimbursement, and Implementation

Key Takeaways:

• Remote Therapeutic Monitoring (RTM) tracks non-physiological patient data including musculoskeletal status, respiratory function, therapy adherence, and therapeutic response, complementing RPM's focus on physiological vital signs.
• The 2026 Physician Fee Schedule delivered the most significant RTM expansion since the program launched in 2022, adding three new CPT codes (98985, 98984, 98979) that lower billing thresholds and recognize shorter monitoring durations.
• RTM now has eight CPT codes spanning setup, device supply (MSK, respiratory, cognitive behavioral), and treatment management, with reimbursement ranging from approximately $22 to $54 per code per month.
• New 2-15 day device codes (98985, 98984) and a 10-minute management code (98979) eliminate the previous all-or-nothing billing thresholds, allowing practices to get reimbursed for shorter monitoring periods and lower-intensity clinical engagement.
• RTM and RPM cannot be billed for the same patient in the same month, but RTM can be billed concurrently with CCM, PCM, and BHI when requirements are independently met.

When CMS introduced Remote Patient Monitoring, it gave providers a reimbursable pathway for tracking physiological data like blood pressure, weight, and blood glucose between office visits. But for the millions of Medicare beneficiaries managing musculoskeletal conditions, post-surgical recovery, respiratory disease, or therapy adherence, RPM's physiological focus left a gap. Their monitoring needs were non-physiological: exercise adherence, functional status, therapeutic response, and symptom tracking.

Remote Therapeutic Monitoring was built to fill that gap. First introduced in 2022 with five CPT codes, RTM allows physicians, physical therapists, occupational therapists, and speech-language pathologists to bill for monitoring non-physiological patient data using FDA-defined medical devices, including software applications.

The 2026 Medicare Physician Fee Schedule Final Rule made RTM substantially more practical. CMS added three new codes that lower the minimum billing thresholds from 16 days and 20 minutes to 2 days and 10 minutes, eliminating the all-or-nothing revenue cliff that had prevented many practices from launching RTM programs. Combined with reimbursement increases across existing codes, the 2026 update makes RTM a viable standalone revenue stream for the first time.

This guide covers every RTM CPT code, reimbursement rate, billing rule, documentation requirement, and implementation consideration your practice needs to know for 2026.

What Is Remote Therapeutic Monitoring

Remote Therapeutic Monitoring is a Medicare program that reimburses providers for monitoring non-physiological patient data outside of traditional clinical settings. While RPM tracks vital signs (blood pressure, pulse oximetry, weight, glucose), RTM tracks therapy adherence, therapeutic response, musculoskeletal system status, respiratory system status, and cognitive behavioral therapy data.

RTM data can be collected through FDA-defined medical devices, which CMS has clarified includes software applications. This means practices can use digital therapeutic platforms, home exercise program apps, and patient-reported outcome tools as the monitoring "device" for RTM billing purposes.

Who Can Bill for RTM

RTM codes can be billed by a broader range of providers than RPM. Eligible billing practitioners include physicians, nurse practitioners, physician assistants, clinical nurse specialists, physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs). When therapists furnish RTM services, they must be provided under a therapy plan of care and require a GP, GO, or GN modifier.

Physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) can contribute to monitoring time for codes 98980 and 98981 under general supervision, but the de minimis (10%) standard and CQ/CO modifier rules apply to codes 98975, 98979, 98980, and 98981.

What Changed in 2026: Three New Codes

The CY 2026 Physician Fee Schedule Final Rule introduced the most significant RTM expansion since the program's launch. Previously, RTM billing required at least 16 days of device data collection and a minimum of 20 minutes of treatment management time. These thresholds excluded short-term patients, post-surgical recovery cases, and lower-intensity monitoring scenarios.

The three new codes address that gap directly:

The Complete 2026 RTM Billing Framework

Setup Code

Device Supply Codes (MSK)

Device Supply Codes (Respiratory)

Treatment Management Codes

Important: Reimbursement rates referenced in this article are approximate national averages based on the 2026 Medicare Physician Fee Schedule and are subject to geographic variation by locality (GPCI), payer contracts, and MAC policies. Consult the CMS Physician Fee Schedule Look-Up Tool for location-specific rates.

Critical Billing Rules: What Cannot Be Combined

RTM's expanded code set comes with strict mutual exclusion rules. Understanding these is essential for avoiding denials:

Revenue Scenarios by Patient Profile

At scale: A practice managing 100 MSK patients on full-engagement RTM (98977 + 98980) generates approximately $10,500 per month, or $126,000 per year. Adding the new low-engagement tier (98985 + 98979) for 50 additional patients who previously fell below the billing threshold adds approximately $3,850 per month, recovering revenue that was previously lost.

RTM vs. RPM: Key Differences

When to choose RTM over RPM: Use RTM when the primary clinical need is monitoring therapy adherence, exercise compliance, functional outcomes, or therapeutic response, particularly for MSK conditions (post-surgical recovery, chronic pain, physical therapy) and respiratory conditions. Use RPM when the need is monitoring vital signs and physiological data.

Qualifying Conditions for RTM

Documentation Requirements

• Interactive communication: At least one real-time synchronous, two-way audio interaction per calendar month is required before billing 98979, 98980, or 98981. 
• Device and data documentation: Document the RTM platform name, description, and number of days data was transmitted. Data may include signs, symptoms, compliance, and functions of a therapeutic response.
• Time tracking: Document date, provider/staff name, activities performed, and time spent. Time must meet the minimum threshold before billing (10 min for 98979, 20 min for 98980).
• Setup documentation (98975): Document the education and training provided, type of device, what data to input, frequency of input, and frequency of exercises.
• Therapy plan of care: When therapists (PT, OT, SLP) furnish RTM services, all services must be provided under a therapy plan of care with the appropriate modifier (GP, GO, or GN).

Common RTM Claim Denials and How to Avoid Them

Layering RTM with CCM and BHI

While RTM cannot be billed with RPM, it CAN be billed concurrently with Chronic Care Management, PCM, and BHI. This creates layered revenue opportunities for patients with both therapeutic monitoring needs and chronic disease management requirements.

Consider a Medicare patient with osteoarthritis (RTM for exercise adherence), hypertension (CCM for chronic disease management), and comorbid depression (BHI):

• RTM (98977 + 98980): approximately $105 per month
• CCM (99490): approximately $66 per month
• BHI (99484): approximately $57 per month

Combined monthly revenue: approximately $228 per patient.

Nsight Health delivers all six CMS-reimbursed remote care programs, including RPM, CCM, PCM, BHI, CoCM, and RTM, under one roof with a W2 clinical team. Schedule a demo to learn how we operationalize RTM alongside CCM and BHI for 130,000+ patients across 1,700+ provider teams.

How to Implement RTM in Your Practice

Step 1: Identify Eligible Patients

Query your EHR for Medicare patients with MSK conditions (post-surgical rehab, chronic pain, osteoarthritis), respiratory conditions requiring ongoing monitoring, or patients in active physical/occupational therapy programs.

Step 2: Select RTM-Compliant Devices

RTM devices must meet the FDA definition of a medical device, which includes software applications. Digital home exercise platforms, therapy adherence apps, and patient-reported outcome tools can qualify. Verify that your selected platform captures and transmits data in a format that supports daily tracking.

Step 3: Set Up and Educate Patients

Bill 98975 for the initial setup and patient education. Document the device type, education provided, data input instructions, and exercise frequency. This code is billed once per episode of care.

Step 4: Monitor and Manage Monthly

Track daily data transmission days to determine the appropriate device supply code (2-15 days vs. 16+ days). Conduct at least one real-time interactive communication per month. Document all management time for the appropriate treatment management code.

Step 5: Scale with a Managed Care Partner

Nsight Health's W2 clinical team handles all RTM operations alongside RPM, CCM, PCM, BHI, and CoCM. Schedule a demo to see how we operationalize RTM for your practice.

Compliance Considerations

• "Sometimes therapy" designation: All RTM codes are classified as "sometimes therapy" services. When furnished by therapists under a therapy plan of care, they count toward the annual therapy dollar threshold, but the MPPR does not apply.
• Direct supervision for incident-to: Unlike RPM (general supervision), RTM treatment management codes (98980, 98981) require direct supervision when clinical staff bill incident-to. The billing practitioner must be in the same physical office location.
• CMS New Technology List: All RTM codes remain on the CMS New Technology List through April 2030, meaning CMS will review utilization data at that point to determine whether adjustments are needed.
• Episode of care vs. calendar month: Device supply codes (98985, 98977, 98984, 98976) are billed per 30-day episode of care. Treatment management codes (98979, 98980, 98981) are billed per calendar month. These periods may not align.

Nsight Health's compliance infrastructure ensures all RTM billing meets CMS standards. Schedule a demo to learn how our compliance-first approach protects your practice.

Frequently Asked Questions

Q: Can I bill RTM and RPM for the same patient in the same month?

A: No. RTM and RPM are mutually exclusive for the same patient in the same calendar month. Choose one program based on the primary clinical monitoring need (non-physiological for RTM, physiological for RPM).

Q: Can I bill RTM and CCM for the same patient in the same month?

A: Yes. RTM and CCM address different clinical dimensions and can be billed concurrently when documentation and time requirements are met independently for each program.

Q: What qualifies as an "interactive communication" for RTM?

A: At minimum, a real-time synchronous, two-way audio interaction capable of being enhanced with video or other data transmission. Phone calls and video calls qualify. Text messages and emails do not.

Q: Can physical therapists bill for RTM?

A: Yes. PTs, OTs, and SLPs can bill RTM codes. When therapists furnish RTM services, they must be provided under a therapy plan of care with the appropriate modifier (GP, GO, or GN).

Q: What is the difference between 98985 and 98977?

A: Both are MSK device supply codes. CPT 98985 (new for 2026) covers 2-15 days of data per 30-day period. CPT 98977 covers 16-30 days. They are mutually exclusive. Bill 98985 for lower-engagement months and 98977 for full-engagement months.

Q: Can I bill 98981 as an add-on to 98979?

A: No. CPT 98981 (additional 20 minutes) can only be added to CPT 98980 (first 20 minutes). There is no add-on code for the 10-minute base code 98979. If treatment management time reaches 20 minutes, use 98980 as your base code.

Q: How does Nsight Health support RTM implementation?

A: Nsight Health provides the clinical staff, documentation infrastructure, and billing support to operationalize RTM alongside all other CMS care management programs. Our W2 clinical team handles patient enrollment, device monitoring, interactive communications, and claims-ready documentation. Schedule a demo to see how we manage RTM for 130,000+ patients across 1,700+ provider teams.

Works Cited

Centers for Medicare and Medicaid Services. "Calendar Year (CY) 2026 Medicare Physician Fee Schedule Final Rule (CMS-1832-F)." CMS.gov, 31 Oct. 2025, www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2026-medicare-physician-fee-schedule-final-rule-cms-1832-f.

Centers for Medicare and Medicaid Services. "Physician Fee Schedule Look-Up Tool." CMS.gov, 2026, www.cms.gov/medicare/physician-fee-schedule/search.

Centers for Medicare and Medicaid Services. "Therapy Code List: 2026 Annual Update." CMS.gov, 2025, www.cms.gov/files/document/mm14250-therapy-code-list-2026-annual-update.pdf.

American Medical Association. "CPT Code Set: 2026 Annual Update." AMA-Assn.org, 2026.

This article is for educational and informational purposes only and does not constitute legal, billing, clinical, or medical advice. CPT codes, reimbursement rates, and regulatory requirements referenced herein are based on publicly available CMS guidance current as of early 2026 and are subject to annual updates, geographic adjustments, and payer-specific variation. Nothing in this article should be construed as a guarantee of reimbursement or a recommendation for specific billing practices. CPT is a registered trademark of the American Medical Association. Consult a qualified billing compliance specialist, healthcare attorney, or your Medicare Administrative Contractor for program-specific guidance applicable to your practice.

Nsight Health delivers clinically managed remote care, including RPM, CCM, PCM, BHI, CoCM, and RTM, with 24/7 W2 clinician support for 130,000+ patients across 1,700+ provider teams. Schedule a demo to learn how we can help your practice capture the full value of RTM in 2026.