What the 2027 Final Rule Changes for RTM
Medicare finalized three changes to Remote Therapeutic Monitoring. Starting January 1, 2027, RTM is limited to established patients and requires a separately reportable initiating visit at which monitoring is discussed. CMS also finalized the rule that monitoring must be furnished by the billing practice's own employed clinical staff rather than contractors, but delayed that one to January 1, 2029.
The four provisions, and where each landed
CMS released the CY 2027 Medicare Physician Fee Schedule final rule on November 4, 2026. It runs 2,468 pages. These are the parts that govern RTM.
RTM is limited to established patients
Finalized as proposed. RTM may only be furnished to an established patient of the billing practitioner. A patient can become established by meeting the initiating visit requirements, so this does not close the door on new patients.
A separately reportable initiating visit is required
Finalized as proposed. Before monitoring begins, the billing practitioner must furnish a visit that stands on its own as a payable service, and RTM has to be discussed during it. The visit may include other care. Where it is delivered by telehealth, Medicare's telehealth requirements apply.
Monitoring must be furnished by employed clinical staff
Finalized, then delayed. Medicare will pay for RTM only where the clinical staff performing the service are employed by the billing practitioner or practice, not contracted from outside. CMS pushed the effective date to January 1, 2029 to give practices time to adapt, and said it intends to issue further guidance on staffing arrangements.
Consolidating the codes into four G-codes
Not finalized. CMS had asked whether the RPM and RTM code families should be replaced with four bundled HCPCS G-codes. It took comment, finalized nothing, and may return to the question in future rulemaking. The existing code set stands for 2027.
What has to be true for every patient you enroll
From January 1, the first two provisions are conditions of payment rather than best practice. A claim for a patient enrolled without them fails on the facts, however well the monitoring itself was delivered. In practice that means four things need to be recorded at enrollment.
- The patient is established with the billing practitioner. Either from prior care, or by way of the initiating visit itself.
- An initiating visit happened, and it was separately payable. For most outpatient PT clinics the initial evaluation already does this job. It is a billable, face-to-face encounter furnished by the treating therapist. What has to be added is the record of which visit it was.
- Monitoring was discussed at that visit. A visit that is otherwise perfectly billable does not qualify if RTM was never raised with the patient during it.
- Consent was obtained and documented. Medicare has required beneficiary consent for remote monitoring for years. Consent may be verbal, and it is documented in the medical record with the date and the person who obtained it.
No extra appointment is needed
The initiating visit does not have to be dedicated to RTM, and nothing in the rule asks you to schedule a separate encounter. The requirement is about the visit being payable in its own right and about the monitoring conversation happening inside it. An initial evaluation satisfies both, as long as the conversation is documented.
What happened to the code values
CMS finalized the valuation changes it proposed for remote monitoring, having concluded that the resource costs behind these codes were higher than warranted. The agency's own estimate puts the combined physical and occupational therapy impact at around 3 percent, driven largely by practice expense. That figure is a category average across all of PT and OT, not a prediction for any one clinic's net change, and the per-code values are what matter.
The musculoskeletal RTM code set is unchanged for 2027. Both 2026 additions survive.
| Code | What it covers |
|---|---|
| 98975 | Initial setup and patient education on the monitoring device |
| 98985 | Device supply with scheduled recordings or alerts, 2 to 15 days of data in 30 days |
| 98977 | Device supply with scheduled recordings or alerts, 16 or more days of data in 30 days |
| 98979 | Treatment management, 10 to 19 minutes in a calendar month |
| 98980 | Treatment management, first 20 minutes in a calendar month |
| 98981 | Treatment management, each additional 20 minutes |
98985 and 98979 arrived in 2026 and removed the old all-or-nothing thresholds, so a patient with twelve days of data or fourteen minutes of management time is billable rather than written off. Both are easy to miss, and leaving them out of a workflow quietly discards revenue the clinic earned.
The dates that matter
Why this is the moment to move to Orva
The 2029 delay is the part worth reading carefully, because it is easy to read as a reprieve and it is not one.
Before November 4, outsourced monitoring was a model under threat. Now it is a model with an expiry date. CMS finalized the requirement that the people doing the monitoring work for the practice that bills for it. That is settled federal policy with a fixed date on it, not a proposal that might be withdrawn. Any clinic that builds its RTM program around clinical staff supplied by a vendor is building toward a migration it will have to complete before January 2029.
A platform decision made this quarter is a decision you keep well past that date. Which makes the structural question, not the feature list, the one that decides it.
Orva was built the way the rule now points. Your own treating therapists deliver the monitoring. Orva does not manage your patients and does not staff your program with outside clinicians, so there is no part of the model that has to be unwound in two years. Between-visit care becomes a defined, reimbursable service delivered by the people already responsible for the plan of care.
What that looks like in practice
- The patient gets a real app. A consumer-grade app on the phone they already carry, built to the standard they expect from shopping, booking travel, paying bills and tracking their own health. It is the 2020s, not the 1970s, and a printout or a web link does not meet that bar.
- Your therapists stay the clinicians. Real-time interactions happen in person as the primary mode, with a phone call an equally viable option, and they are timed.
- Days of data and management minutes are tracked for you. Orva captures them as care happens, so the thresholds behind 98985, 98977, 98979, 98980 and 98981 are accounted for rather than reconstructed at month end.
- Billing support if you want it. An optional billing service, for clinics that would rather not add RTM claims to their own team's plate.
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Where this does not apply, and what is still open
Three honest limits on everything above.
- Cash-pay clinics are not affected. These are Medicare billing requirements. A clinic that does not bill RTM to Medicare has no initiating visit or established patient obligation under this rule.
- Commercial payers set their own terms. RTM is billable to commercial payers as well as Medicare, and coverage varies by plan. Some cover it with their own criteria, some exclude it. Check the plan before enrolling a patient rather than assuming Medicare's rules carry over.
- The per-code values are not in this page. CMS finalized its valuation changes, and the code-level amounts live in the rule's payment addenda. We are working through them and will publish the specifics rather than estimate them here.
This page describes a federal payment rule and is not legal or billing advice. State law can impose its own requirements on remote care, including on how patient consent is captured, and a few states are stricter than Medicare. Check with your own counsel for the states you operate in.
Questions clinics are asking
Does the initiating visit have to be a separate appointment just for RTM?
No. The visit has to be separately reportable, meaning payable under its own code, and RTM has to be discussed with the patient during it. It can include other care. For most outpatient PT clinics the initial evaluation already meets both tests.
Can I still enroll a brand new patient in RTM?
Yes. RTM is limited to established patients, but a patient can become established by meeting the initiating visit requirements. The sequence matters more than the history. The qualifying visit comes first, then monitoring begins.
Does the 2029 staffing rule mean outsourced monitoring is fine until then?
It is payable until then. The requirement is finalized, so the direction is no longer in question, only the date. A program built on contracted clinical staff will have to change before January 1, 2029, and CMS has said it plans to issue further guidance on staffing arrangements in the meantime.
Did the new 2026 codes survive the final rule?
Yes. 98985, for 2 to 15 days of data, and 98979, for 10 to 19 minutes of treatment management, both remain in place for 2027. CMS took comment on replacing the code families with four bundled G-codes and did not finalize that proposal.
Does patient consent have to be in writing?
Medicare permits verbal consent, documented in the medical record. The record should show the date, who obtained it, and what the patient was told, including that cost sharing may apply and that they can stop at any time. Some states impose their own written consent requirements for remote care, so confirm the rules where you practice.
Real RTM™, delivered by your own therapists
The requirements that take effect on January 1 reward programs where the clinic owns the care. That is the only kind Orva builds.
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