Last Chance for Therapy Practices to Prepare for the 2026 Medicare RTM Changes

Remote Patient Monitoring (RPM) helped establish the infrastructure for virtual care reimbursement, but Remote Therapeutic Monitoring (RTM) has always been the more meaningful framework for therapists because it actually measures what therapy achieves. RPM tracks blood pressure and glucose. RTM tracks range of motion, gait patterns, cognitive exercises, and respiratory function during rehabilitation. For physical therapists, occupational therapists, and speech-language pathologists, RTM captures the measurable progress that defines successful treatment. The 2026 Medicare Physician Fee Schedule from the Centers for Medicare & Medicaid Services (CMS) represents the most significant update to RTM since the codes were introduced in 2022.

The new rule creates shorter-duration monitoring pathways and introduces a new 10-minute treatment management code. These updates change who you can monitor, how you structure your workflows, how you document care, and what compliance standards you must meet.

The opportunity is substantial, but so is the need for precision in operational control. Practices that understand the rule and have reliable systems will benefit most.

What Actually Changed and Why It Matters

CMS introduced a new set of device supply codes that allow billing for only 2 to 15 days of data in a 30-day period. Previously, 16 days were required. The new codes are 98984 for respiratory monitoring, 98985 for musculoskeletal monitoring, and 98986 for cognitive behavioral therapy monitoring, each covering 2 to 15 days.

These shorter-duration codes pay the same amount as the 16 to 30 day codes (98976, 98977, 98978). CMS made a conscious decision not to pay less for fewer days of data, as long as the minimum requirement is met. This pricing structure reflects an important policy signal. The agency is valuing clinical relevance over volume, acknowledging that concentrated monitoring during critical windows can be as valuable as extended observation.

This opens the door to care models that were not viable before. Two-week post-operative monitoring becomes economically feasible. Focused gait training cycles can be tracked without artificial extension. Range of motion during the acute phase of frozen shoulder treatment can be monitored precisely when it matters most. Short, targeted episodes for patients who do not need month-long monitoring now have a clear pathway to reimbursement.

CMS also finalized a new 10-minute treatment management code. Code 98979 covers 10 to 19 minutes and is valued at exactly half the 20-minute code 98980. This provides therapists with a realistic option for patients who do not need a full 20-minute management cycle every month.

The intent is straightforward. Not every patient requires the same level of monthly engagement to justify reimbursement. A patient in maintenance mode after achieving functional goals may need brief check-ins. A patient navigating complex post-surgical protocols may need extended discussions. The code set now reflects that reality.

The Critical Constraint and How Code Selection Works

The new flexibility comes with a strict limitation. You cannot mix shorter and longer codes in the same 30-day or calendar month period.

You cannot combine 98985 with 98977 for the same patient in the same period. You cannot combine 98979 with 98980. If you choose the 10-minute code (98979), you cannot add the 20-minute add-on code (98981). These codes are designed as mutually exclusive pathways, and CMS has made clear that selecting one forecloses the other.

This means your decisions need to be made before monitoring begins, not retrospectively when you review billing at month's end. You need a clear sense of whether a patient is likely to fall into a 2 to 15 day or 16 to 30 day pattern based on their diagnosis, functional status, and engagement history. You also need a system that tracks data transmission throughout the month with precision.

A common scenario illustrates the problem. A therapist bills 98985 on day 12 after seeing consistent engagement during the first two weeks. The patient then becomes even more engaged and continues transmitting data past day 16. The additional days technically qualify for the 16 to 30 day code, but that code can no longer be billed because the 2 to 15 day code is already on the claim. The practice has left reimbursement on the table not because of clinical failure but because of structural miscalculation.

This is why reliable tracking and prospective decision-making are not optional features. They are fundamental requirements.

How CMS Is Valuing RTM Device Codes

CMS is now using Outpatient Prospective Payment System (OPPS) Geometric Mean Cost data to value RTM device supply codes. Instead of relying on individual practice invoices, which vary widely and are difficult to verify, the agency applies a standardized national cost model based on thousands of hospital claims. The geometric mean cost is divided by the Physician Fee Schedule conversion factor to establish the payment amount in the non-facility setting.

There was debate about whether hospital cost structures accurately reflect therapy practice operations. CMS concluded that for medical devices, cost patterns are similar enough across settings to justify the model. The agency noted that devices used in outpatient therapy settings and hospital outpatient departments face similar supply chain costs, regulatory burdens, and technological requirements.

This method also brings attention to software-driven components of modern care. Cloud storage, cybersecurity infrastructure, and subscription-based platforms are becoming fundamental parts of device-supported care, and this valuation model begins to reflect that reality. The shift acknowledges that RTM is not simply about hardware. It is about the entire ecosystem that makes continuous data capture, transmission, and interpretation possible.

The Sometimes Therapy Designation

CMS assigned a sometimes therapy designation to 98979, 98984, and 98985. This means these codes can be furnished by therapists and therapy assistants under the appropriate supervision rules. When assistants deliver the management work, CQ or CO modifiers apply depending on the supervision structure. The device supply codes do not require therapy modifiers because supplying a device is not considered a therapy service under Medicare policy.

CMS declined to add pharmacists or dietitians as eligible RTM providers due to statutory limits in how therapy services are defined under the Social Security Act. RTM remains squarely in the therapy and physician domains.

The Interactive Communication Question

CMS adopted Current Procedural Terminology (CPT) language that requires live, interactive communication with the patient or caregiver for treatment management time. CMS also stated that it is not adding restrictions on the types of communication that may qualify, provided they meet CPT requirements.

This wording contrasts with earlier CMS guidance that required real-time audio for Remote Patient Monitoring (RPM) and explicitly excluded messaging. The 2026 language suggests a possible shift toward aligning more closely with CPT definitions, although CMS has not provided explicit examples of what qualifies. Another part of the rule reminds providers not to count time twice for any service, including in-clinic interactions. The overall takeaway is that communication requirements should follow CPT rules, and further clarification may come through future guidance, Medicare Administrative Contractor (MAC) policy, or audit trends.

What These Changes Mean for Your RTM Program

Your strategy depends on where your program stands today.

If you are getting started, the 2 to 15 day codes lower the minimum threshold for meaningful reimbursement. You can design shorter episodes of care without worrying about whether patients will produce 16 days of data. This makes pilot programs less risky and allows you to test RTM with specific diagnoses or patient populations before committing to broader implementation.

If you are scaling, the new 10-minute treatment management code allows you to match the level of work to the needs of the patient. This can expand your capacity without increasing staff time. A therapist who previously managed 20 patients per month at 20 minutes each could now manage 30 patients by routing stable patients to the 10-minute pathway while reserving longer sessions for complex cases.

If you are optimizing a mature program, the mutual exclusivity rules require clear routing, consistent documentation, and reliable tracking. A manual approach is not practical at scale. The difference between compliant billing and denials often comes down to how well a practice manages thresholds and timing, not clinical quality.

Setup Requirements and Minimum Activity

Device setup and education under code 98975 now requires at least two days of patient monitoring activity. The requirement ensures that setup is tied to genuine use rather than to devices that were never activated. Practices must verify data transmission before billing setup. This prevents scenarios where a device is shipped, billed, but never used because the patient did not engage or the technology failed at onboarding.

Geographic Adjustments and Reimbursement Variation

CMS assigns a Geographic Practice Cost Index (GPCI) of 1.0 to the equipment and supplies part of the practice expense calculation, meaning that portion does not vary by region. Other components, such as clinical wages and office rent, remain geographically adjusted based on local cost data.

The result is that total reimbursement still varies by location but less dramatically than in codes that are purely service-based. This creates a more stable reimbursement floor for therapy practices across different markets. A practice in rural Montana and a practice in Manhattan will see different total payments, but the gap is smaller than it would be for evaluation codes or manual therapy, where labor costs dominate.

Open Questions and What CMS Will Revisit

CMS noted that RTM codes remain on the New Technology list for three years. The agency expects to make refinements as more evidence becomes available. Several areas remain open for clarification.

Can multiple devices be billed simultaneously for the same patient if they monitor different body systems? Can RTM and RPM be billed together for different conditions in the same month? Can remote monitoring time count toward Chronic Care Management or Principal Care Management services if the same patient qualifies for multiple programs?

Further clarity may come through rulemaking, MAC guidance, or patterns that emerge from audits and coverage determinations.

Implementation Priorities for 2026

To operate confidently under the 2026 rule set, practices need five core capabilities.

Accurate patient routing based on expected monitoring intensity. This requires clinical judgment combined with historical data on patient engagement patterns.

Real-time tracking of data transmission so billing thresholds are never crossed accidentally. If a patient approaches 16 days of transmission but is routed to the 2 to 15 day pathway, the system must flag this before the claim is generated.

Clinician-friendly documentation workflows that support reimbursement without adding burden. Therapists should not be forced to navigate billing logic manually while managing clinical care.

Governance systems that validate code selection before claims go out the door. A second layer of review ensures that mutual exclusivity rules are followed and that documentation supports the code billed.

Outcome measurement frameworks that demonstrate value for both Medicare and commercial payers. As RTM matures, payers will increasingly ask for evidence that the service improves outcomes, reduces hospitalizations, or accelerates functional recovery.

These capabilities turn RTM from a billing opportunity into a sustainable clinical service that withstands scrutiny and scales across patient populations.

How Orva Handles These Requirements

The complexity of the 2026 rule is exactly the type of problem modern software is designed to handle, and Orva's platform was built specifically for this. The system analyzes patient engagement in real time and places patients into the appropriate code pathway automatically based on transmission patterns, clinical characteristics, and Medicare policy logic. If a patient's behavior begins to shift toward a different billing category, the system flags it before it becomes a compliance issue.

Data transmission, treatment management time, and documentation are captured and sorted within the workflow itself. Code selection logic is embedded in the system, so therapists do not have to manually track which codes can and cannot be combined. All 2026 code changes are already mapped into Orva's routing engine and will be processed automatically when the new year begins.

This allows the clinical team to focus on care, not on counting days, minutes, or billing thresholds. The platform handles the operational execution so the practice can scale confidently without expanding administrative overhead. Orva does not simply automate billing. It structures the entire care delivery model so that compliance, documentation, and clinical outcomes are integrated from the start.

What This Means for Your Practice

The 2026 updates represent a turning point for RTM. Medicare is no longer asking whether therapeutic monitoring works. It is establishing a more mature structure for how the work should be paid for, and that structure demands precision. With more flexibility comes the need for stronger systems and clearer workflows.

The practices that embrace thoughtful routing, transparent documentation, and automated operational guardrails will thrive under the new rules. Those that approach RTM casually or manually will face preventable compliance problems and reduced profitability. The margin for error has narrowed, and the stakes have increased.

RTM is becoming a core part of modern therapy practice. The question is not whether to offer it but whether your practice is equipped to offer it in a way that is scalable, compliant, and clinically meaningful. Orva provides the structure needed to make that possible at any size and in any setting.

Ready to Build RTM Into Your Practice?

We know these changes raise questions about implementation, billing workflows, and how RTM fits into your current operations. That's exactly what we're here for. Our team has worked with therapy practices of every size to design RTM programs that work clinically, scale operationally, and hold up under audit.

If you're thinking about getting started with RTM in 2026 or want to refine what you already have in place, we'd love to talk through your specific situation. No pressure, no sales pitch. Just a straightforward conversation about what makes sense for your practice.

Schedule a call with us and we'll walk through the 2026 updates, answer your questions, and show you exactly how Orva handles the complexity so you don't have to.