Preparing for 2026 Changes to Remote Therapeutic Monitoring in Physical Therapy and Orthopedics
Remote Therapeutic Monitoring (RTM) is on the verge of its most significant expansion since the Centers for Medicare & Medicaid Services (CMS) first introduced the codes in 2022. The proposed 2026 Medicare Physician Fee Schedule (PFS) includes sweeping updates that will make RTM more accessible to patients and more financially rewarding for physical therapy and orthopedic practices.
The final CMS rule is expected in early November 2025, and if adopted as proposed, the new codes will take effect on January 1, 2026. Below is what clinics need to know about the proposed changes, the lower thresholds for qualification, and how to prepare for implementation.
What Is Remote Therapeutic Monitoring
Remote Therapeutic Monitoring allows healthcare providers to track and manage patient-reported, non-physiological data between visits. Unlike Remote Physiologic Monitoring (RPM), which records vital signs like heart rate or blood pressure, RTM focuses on functional and musculoskeletal outcomes such as exercise adherence, pain levels, range of motion, respiratory participation, and cognitive behavioral therapy (CBT) engagement.
For physical therapists and orthopedic providers, RTM helps maintain continuity of care, strengthen patient accountability, and improve outcomes while qualifying for additional Medicare reimbursement.
The 2026 RTM Proposal Explained
In July 2025, CMS released the proposed rule for the 2026 Physician Fee Schedule. Among the most notable updates are new RTM codes designed to expand eligibility and simplify billing requirements.
Proposed New Codes for 2–15 Days of Monitoring
Under current policy, most RTM codes require at least 16 days of data transmission within a 30-day period. CMS has acknowledged that this threshold excludes many patients, especially those in short-term rehabilitation or post-surgical recovery programs.
In the proposed 2026 rule, CMS introduces a new set of RTM codes that would allow billing for 2–15 days of patient-reported data collection. These new codes are temporarily listed as 98XX4 through 98XX7 and are designed to expand access to reimbursement for patients who engage for fewer days or require shorter monitoring windows. The “XX” designations are placeholders that will be replaced once the American Medical Association finalizes the CPT numbers in the official 2026 release.
The proposed codes include new options for musculoskeletal monitoring, cognitive behavioral therapy, and a shorter 10–19 minute treatment management tier. While still pending final approval, these codes reflect CMS’s goal to make RTM more flexible and better aligned with real-world clinical practice.
Lower Time Threshold for Provider Management
CMS also proposes adding a new lower-tier treatment management code for 10–19 minutes of care management time per month. If finalized, it would complement the existing 20-minute and 40-minute codes that clinics currently use (98980 and 98981).
The proposed 10-minute tier would recognize meaningful clinical engagement that falls below 20 minutes, broadening reimbursement opportunities for patient interactions that are still clinically significant but shorter in duration.
Existing Codes Will Stay in Place
The current RTM codes, including 98975, 98977, 98980, and 98981, will remain active in 2026. Clinics will be able to use either the existing 16–30 day codes or the new 2–15 day codes, depending on the level of patient engagement during that billing period.
All proposed payment rates remain estimates until CMS publishes the final rule in November.
Which Patients Qualify for RTM
RTM is available to Medicare beneficiaries receiving treatment for musculoskeletal, respiratory, or cognitive behavioral conditions when ongoing monitoring can support recovery.
Patients qualify if they have an active plan of care established by a qualified provider, can use a digital tool such as a smartphone or tablet to submit data, and participate between regular visits. They do not need to be homebound or exclusively telehealth patients. RTM is designed to complement in-person care.
If finalized, the lower thresholds for 2026 would significantly expand eligibility. Short-term rehabilitation patients, post-surgical patients, those in episodic care models, rural patients with intermittent connectivity, and individuals with fluctuating symptoms would all qualify under the 2–15 day codes.
What Counts as Billable RTM Activity
The setup and education code (98975) requires onboarding, patient instruction, and confirmation of device or app setup. It can only be billed once per episode of care.
The monitoring codes (98977 or the new proposed 2–15 day codes) require the patient to transmit data for the qualifying number of days within a 30-day period. The data can include exercise completion, pain scores, range-of-motion self-reports, or functional updates.
Treatment management codes (98980, 98981, or the new 10–19 minute code) include reviewing patient data, communicating with the patient, adjusting exercises, documenting plan updates, and making clinical decisions based on that data. At least one real-time, interactive communication per month is required. This can be a phone call, video visit, or substantive back-and-forth messaging about clinical care.
Non-clinical tasks such as scheduling, marketing, or technical troubleshooting do not qualify as billable time.
How RTM Differs from Other Remote Care Models
RTM differs from other remote care models in both scope and purpose. Remote Physiologic Monitoring (RPM) collects vital signs automatically through medical devices, while RTM focuses on patient-reported, non-physiologic data such as pain, function, and exercise adherence.
Telehealth visits involve real-time video or phone consultations and are billed as traditional evaluation or treatment codes. RTM is the continuous monitoring that occurs between visits, whether those visits happen in person or virtually.
Home exercise programs alone are not billable under RTM unless they involve data reporting, review, and interactive communication about the patient’s progress.
How to Set Up an RTM Program
Implementing RTM successfully requires a reliable technology platform and clear internal workflows.
From a technology standpoint, a compliant RTM platform should automatically capture exercise completion data, collect pain and function metrics, facilitate secure two-way messaging between providers and patients, log time spent on qualifying activities, and generate compliant documentation for billing and audits.
Orva is built specifically for RTM. It automates exercise tracking, patient feedback, messaging, and documentation, allowing providers to capture every billable interaction without additional administrative work.
From a workflow standpoint, clinics should define clear processes for patient enrollment, data review, communication expectations, and billing documentation. Many clinics have therapists manage their own RTM patients, while larger programs may designate a coordinator to oversee enrollment and adherence tracking.
Documentation and Compliance
Proper documentation is critical for compliance and audit protection. Each RTM episode should include:
Patient consent for RTM services
A care plan describing what will be monitored and why
Documentation of platform setup and education
A log of data transmissions with dates
A time log of provider activities with date, duration, and purpose
Clinical notes summarizing review and plan adjustments
A record of at least one interactive communication during the month
Common documentation errors include vague time entries, missing communication notes, and billing for management time without evidence of interaction or clinical decision-making.
Medicare and Commercial Coverage
RTM codes are covered under Medicare Part B for physical, occupational, and respiratory therapists and other qualified healthcare professionals. Clinics do not need to be physician-owned to participate.
Medicare Advantage plans must also cover RTM, although prior authorization or plan-specific documentation requirements may apply.
Commercial coverage varies widely. Some payers have adopted Medicare’s structure and reimburse RTM codes, while others have not. Always verify coverage with each patient’s insurance provider before enrolling them in RTM.
Reimbursement Outlook
CMS proposes modest payment increases for 2026, with separate conversion factors for clinicians who participate in Alternative Payment Models and those who do not. These increases will affect all services under the Physician Fee Schedule, including RTM.
Some RTM codes, such as those for respiratory or cognitive behavioral therapy monitoring, will continue to be priced regionally by Medicare Administrative Contractors (MACs). CMS will maintain national reimbursement rates for musculoskeletal RTM codes once the 2026 rule is finalized.
Preparing for January 2026
The period between the final rule’s publication in November and the effective date of January 1 will be short. Clinics should begin preparing now by identifying eligible patients, selecting or optimizing their RTM platform, training staff, and updating internal workflows.
Educate patients on what RTM is, how it supports their recovery, and what is expected of them. Review billing software or vendor systems to ensure they can accommodate the new codes once they are finalized.
By preparing in advance, clinics can start billing immediately when the new rules take effect.
Why CMS Is Expanding RTM
CMS’s 2026 proposal signals continued support for technology-enabled care. The goal is to promote value-based care, encourage patient engagement between visits, reduce costs through early intervention, and give providers more flexibility in delivering hybrid care.
CMS has also requested public input on potential reimbursement models for software and artificial intelligence tools. This could lead to further innovation and additional billing opportunities in the future.
If finalized as proposed, the 2026 RTM expansion will make remote care more flexible, inclusive, and financially viable. It rewards clinics that maintain continuous engagement with their patients between visits.
Clinics that act now will be positioned to begin billing the new codes on January 1, 2026, strengthen outcomes, and create reliable new revenue streams. CMS’s direction is clear. RTM is becoming an integral part of modern rehabilitation care.
About Orva
Orva is a digital patient engagement platform designed for physical therapy and orthopedic practices. It automates exercise tracking, pain and function reporting, secure two-way messaging, and time-based documentation required for RTM billing.
With Orva, providers gain real-time visibility into patient progress, while patients stay motivated, consistent, and supported throughout their recovery.
Orva will continue monitoring the CMS rulemaking process and provide updated guidance as soon as the final rule is released in November 2025.
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Disclaimer: This article is for informational purposes only and does not constitute billing, legal, or clinical advice. The information reflects CMS’s proposed 2026 Physician Fee Schedule as of October 29, 2025. Final requirements may differ when CMS publishes the final rule.