What the 2026 Medicare Proposed Rule Means for Remote Therapeutic Monitoring
The Centers for Medicare and Medicaid Services (CMS) recently released its proposed Medicare Physician Fee Schedule for calendar year 2026. Among many changes, one of the most relevant for orthopedic and physical therapy practices is a set of proposed updates to Remote Therapeutic Monitoring (RTM). These changes would make RTM more flexible and accessible, allowing providers to bill for a broader range of patient engagement scenarios while keeping reimbursement for the existing structure intact.
New RTM Codes for Shorter Engagement Periods
CMS is proposing a new set of RTM codes that would allow practices to bill for patients who engage in their home exercise program for fewer than 16 days in a 30-day period. Under current rules, RTM reimbursement is only available when patients meet or exceed that 16-day threshold. The new codes would also allow billing for management time below the existing 20-minute minimum. Specifically, clinics would be able to bill for as few as 2 to 15 days of device use and 2 to 19 minutes of clinical review.
These proposed codes are designed to reflect the reality that not all patients follow the same recovery path. Some may be discharged early, others may pause care mid-month due to travel or illness, and some may simply need less ongoing monitoring to reach their goals. The new structure would allow practices to receive partial reimbursement for the work they are doing with those patients, rather than being limited to all-or-nothing thresholds.
CMS intends to classify these new codes as "New Technology" services. That means they will be priced initially using placeholder values and will remain in this provisional category through at least 2030 while CMS collects data on utilization and outcomes.
No Changes to Existing RTM Codes
The proposed rule does not change any of the current RTM billing codes. CPT codes 98975, 98977, 98980, and 98981 will retain their current structure and reimbursement values. This provides continuity for practices that already have RTM workflows in place and are meeting the existing thresholds.
For many clinics, the best path forward will involve using the new codes in combination with the existing ones. Patients who meet full engagement and time requirements will continue to qualify under 98977 and 98980. Those who fall short will still be eligible for partial reimbursement under the new codes, helping practices capture more of the value they are already delivering.
Policy Support for Remote Care Infrastructure
In addition to changes specific to RTM, CMS is also proposing to make virtual direct supervision permanent. Under this rule, a supervising provider could be available by real-time video rather than needing to be physically present. This policy is especially helpful in RTM models where clinical review and intervention may be performed by different members of the care team.
CMS has also asked for public input on broader digital health questions, including how to support software-as-a-service tools and condition-specific digital interventions. This signals a growing openness to reimbursing technology-driven care models more broadly, which will likely shape future reimbursement beyond RTM.
What This Means for Orva Clinics
Clinics using Orva do not need to make any immediate changes. The current code set remains valid and continues to be supported. If these new codes are finalized, Orva will incorporate them into its reporting and billing workflows to ensure providers can take advantage of the expanded structure. All the data tracking and time monitoring required for these codes is already built into the platform.
The 2026 proposal makes it easier for clinics to bill accurately and get paid for the care they are providing. It reflects a more realistic view of patient behavior and recovery timelines, and it reinforces CMS’s long-term commitment to digital care delivery.
The public comment period runs through September 12, 2025. Final details of the rule will be published later this year, with changes scheduled to take effect on January 1, 2026. Orva will provide updated guidance and platform support well ahead of that date.
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