Key Takeaways:
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.
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.
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.
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:
| New Code | What It Covers | Previous Requirement | Approx. 2026 Rate |
|---|---|---|---|
| 98985 | MSK device supply, 2-15 days of data | 98977 required 16+ days | $51 |
| 98984 | Respiratory device supply, 2-15 days of data | 98976 required 16+ days | $40 |
| 98979 | Treatment management, first 10 minutes | 98980 required 20+ minutes | $26 |
| CPT Code | Description | Frequency | Approx. 2026 Rate |
|---|---|---|---|
| 98975 | Initial setup and patient education on RTM equipment | Once per episode of care | $22 |
| CPT Code | Description | Data Threshold | Approx. 2026 Rate |
|---|---|---|---|
| 98985 [NEW] | MSK device supply and data transmission | 2-15 days per 30-day period | $51 |
| 98977 | MSK device supply and data transmission | 16-30 days per 30-day period | $51 |
| CPT Code | Description | Data Threshold | Approx. 2026 Rate |
|---|---|---|---|
| 98984 [NEW] | Respiratory device supply and data transmission | 2-15 days per 30-day period | $40 |
| 98976 | Respiratory device supply and data transmission | 16-30 days per 30-day period | $40 |
| CPT Code | Description | Time Threshold | Approx. 2026 Rate |
|---|---|---|---|
| 98979 [NEW] | Treatment management, first 10 minutes | 10-19 min per calendar month | $26 |
| 98980 | Treatment management, first 20 minutes | 20+ min per calendar month | $54 |
| 98981 | Treatment management, each additional 20 minutes | Add-on to 98980 only | $41 |
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.
RTM's expanded code set comes with strict mutual exclusion rules. Understanding these is essential for avoiding denials:
| Rule | What It Means |
|---|---|
| 98985 and 98977 are mutually exclusive | Bill one MSK device code per patient per 30-day period. If data exceeds 15 days, bill 98977. If 2-15 days, bill 98985. Never both. |
| 98984 and 98976 are mutually exclusive | Same rule for respiratory codes. One device code per patient per 30-day period. |
| 98979 and 98980 are mutually exclusive | Bill one base treatment management code per patient per calendar month. If 10-19 minutes, bill 98979. If 20+ minutes, bill 98980. Never both. |
| 98981 can only add on to 98980 | There is no add-on code for 98979. If management time reaches 20 minutes, use 98980 as your base code instead. |
| RTM and RPM cannot be billed together | A patient cannot receive both RTM and RPM in the same calendar month. Choose one based on clinical indication. |
| One clinician per patient per 30-day period | Only one billing clinician can submit RTM claims per patient per period. The first claim submitted is reimbursed; subsequent claims are denied. |
| Patient Scenario | Codes Billed | Approx. Monthly Revenue |
|---|---|---|
| MSK patient, low engagement (2-15 days, 10 min mgmt) | 98985 + 98979 | $77 |
| MSK patient, full engagement (16+ days, 20 min mgmt) | 98977 + 98980 | $105 |
| MSK patient, high engagement (16+ days, 40 min mgmt) | 98977 + 98980 + 98981 | $146 |
| Respiratory patient, low engagement | 98984 + 98979 | $66 |
| Respiratory patient, full engagement | 98976 + 98980 | $94 |
| New MSK patient, setup + first month full | 98975 + 98977 + 98980 | $127 |
| MSK patient + CCM (layered) | 98977 + 98980 + 99490 | $171 |
| MSK patient + CCM + BHI (layered) | 98977 + 98980 + 99490 + 99484 | $228 |
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.
| Dimension | RTM | RPM |
|---|---|---|
| Data type | Non-physiological (therapy adherence, functional status, therapeutic response) | Physiological (blood pressure, weight, glucose, SpO2) |
| Eligible providers | Physicians, NPs, PAs, PTs, OTs, SLPs | Physicians, NPs, PAs, CNSs |
| Device requirement | FDA-defined medical device (including software) | FDA-cleared medical device |
| Supervision for staff | Direct supervision for incident-to billing | General supervision |
| Billing period | 30-day episode of care (device codes) / calendar month (management codes) | Calendar month |
| Can bill together | No. RTM and RPM are mutually exclusive for the same patient in the same month. | |
| Can bill with CCM | Yes | Yes |
| Can bill with BHI | Yes | Yes |
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.
| System | Common RTM-Qualifying Conditions | Device Codes |
|---|---|---|
| Musculoskeletal | Post-surgical rehabilitation (knee/hip replacement, rotator cuff), chronic low back pain, osteoarthritis, sports injuries, physical therapy programs | 98985, 98977 |
| Respiratory | COPD with pulmonary rehab, chronic asthma, post-COVID respiratory recovery | 98984, 98976 |
| Cognitive Behavioral | Substance use treatment adherence, cognitive behavioral therapy response | 98978 |
| Denial Reason | What Triggers It | How to Prevent It |
|---|---|---|
| Billing both device tiers | 98985 and 98977 (or 98984 and 98976) billed for the same patient in the same period | Wait until end of billing period to determine the correct tier, then bill one code |
| Billing both management bases | 98979 and 98980 billed for the same patient in the same month | If time reaches 20 min, bill 98980 only. Use 98979 only for 10-19 min months. |
| Stacking 98981 on 98979 | 98981 add-on billed without 98980 as the base code | 98981 can only be added to 98980. There is no add-on for the 10-minute code. |
| Missing interactive communication | Management codes billed without a qualifying real-time interaction | Ensure at least one phone or video call per calendar month before billing 98979/98980/98981 |
| Concurrent RPM and RTM | Both RPM and RTM billed for the same patient in the same month | Choose one program per patient per month based on clinical need |
| Missing therapy modifier | Therapist billing RTM without GP, GO, or GN modifier | Append the appropriate modifier when RTM is furnished under a therapy plan of care |
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):
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.
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.
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.
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.
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.
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.
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.
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.
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.