Who Can Bill RTM in 2026? A Guide for PT, OT, PTA, OTA, and Orthopedic Clinics
Remote Therapeutic Monitoring (RTM) is one of the most important reimbursement opportunities in outpatient rehab right now. It is also one of the most misunderstood, particularly around who can actually bill, how assistant involvement works, and what the supervision rules require.
In 2026 that clarity matters more than ever. CMS added new RTM codes and formally expanded the therapy code list. Clinics that understand the rules will bill with confidence. Clinics operating on assumptions will find gaps they may not discover until an audit.
Here is the practical breakdown for physical therapy, occupational therapy, and orthopedic practices.
The short answer
Most of the confusion in RTM billing comes down to three things. Here is where things stand in 2026.
The 2026 RTM codes for musculoskeletal practices
CMS confirmed the addition of two new codes effective January 1, 2026, alongside the existing RTM family.
The 2026 update also revised the device supply thresholds. Where previously one supply code covered a broader range, there are now two distinct buckets: 2 to 15 days and 16 to 30 days. Billing the right one requires knowing exactly how many days of data were transmitted each month.
Can physical therapists bill RTM?
Yes. Under Medicare, PTs can bill RTM codes. APTA's 2026 practice advisory confirms this directly, and CMS includes RTM codes on the therapy code list, including the 2026 additions. For most outpatient orthopedic and PT practices, this is the core billing pathway.
It is one reason RTM has become so valuable for PT clinics specifically. It creates billable clinical touchpoints outside the clinic, extends skilled care between visits, and produces a documented record of clinical impact that in-clinic notes alone cannot capture.
Can occupational therapists bill RTM?
Yes. OTs fit within the therapy framework CMS uses for RTM. The 2025 Medicare Physician Fee Schedule final rule and CMS's therapy code list updates apply to occupational therapists as affected providers.
One important caveat: Medicare rules and commercial payer behavior are not identical. RTM codes may be billable under commercial plans, but payer-by-payer verification still matters before assuming coverage parity.
Can PTAs and OTAs bill RTM?
This is where language matters most.
PTs and OTs bill Medicare RTM. PTAs and OTAs may participate in furnishing portions of the service where allowed. APTA's RTM advisory notes that effective January 1, 2025, Medicare allows PTAs in private practice to operate under general supervision for applicable outpatient therapy services. CMS confirmed the same for OTAs.
In practical terms:
- A PTA or OTA can be part of the RTM workflow.
- The supervising PT or OT remains the billing professional under Medicare.
- Assistant involvement can trigger modifier and payment adjustment rules for certain services.
One frequently missed detail: 98975 is subject to the PTA payment adjustment, while 98976 and 98977 are not. Assistant participation is not just a compliance question. It is also a reimbursement and claims-accuracy question.
What changed with supervision?
CMS finalized a regulatory change allowing general supervision of PTAs and OTAs by PTs and OTs in private practice for applicable outpatient therapy services. This took effect in 2025 and remains in place for 2026.
General supervision is more flexible than direct supervision. The supervising therapist does not have to be physically present while an assistant furnishes applicable services. APTA described this as bringing private practice into alignment with the broader Medicare supervision policy for assistants.
For RTM programs, this matters because monitoring workflows often include data review, patient outreach, escalation, and documentation that do not happen while the billing therapist is in the same room. General supervision gives clinics more operational flexibility in structuring those workflows.
It is not a free pass, though. General supervision does not override scope-of-practice rules, documentation requirements, assistant modifiers, or payer-specific restrictions. Clinics still need clear internal policies on who performs setup and education, who reviews transmitted data, who conducts required interactive communication, who documents treatment management time, and who ultimately bills the service.
Can physicians and orthopedic groups bill RTM?
Yes. RTM is not limited to therapy-only practices. CMS identifies affected providers as therapists, physicians, certain non-physician practitioners, and other providers billing Medicare Administrative Contractors for therapy services.
For orthopedic groups, the practical question is usually not whether the organization can participate, but which practitioner owns the 30-day monitoring episode. Because only one practitioner can bill remote monitoring per patient in a 30-day period, multi-provider organizations need to coordinate that ownership clearly.
The most common misconception
That is not just a semantic distinction. It affects claims, modifiers, payment adjustments, compliance exposure, and audit defensibility.
Orva is built to handle exactly this kind of complexity, so your team is not figuring it out claim by claim. See how it works.
A practical checklist before you bill RTM in 2026
If your team cannot answer each of these quickly, the workflow probably needs tightening.
- Which practitioner owns the 30-day monitoring episode?
- Which code applies: setup, device supply, or treatment management?
- Did the device actually transmit qualifying data?
- Did the patient hit the right day threshold for the code billed?
- Did the required real-time interactive communication occur and was it documented?
- If a PTA or OTA participated, was supervision appropriate and the claim coded correctly?
- Does your payer actually follow the Medicare pathway you are assuming?
The bottom line
In 2026 the practical Medicare answer is straightforward. PTs and OTs can bill RTM. PTAs and OTAs can participate in furnishing applicable services under general supervision in private practice, but that is not the same as independently billing in their own names. Orthopedic and physician-led groups can also participate, but only one practitioner can bill remote monitoring per patient in a 30-day period.
The clinics that do RTM well will not just know the codes. They will know exactly who is billing, who is furnishing the work, how supervision is being handled, and how the documentation supports every claim.
Orva is built for clinics that take RTM seriously
From code thresholds to supervision workflows to audit-ready documentation, Orva gives orthopedic and rehab practices the structure to run RTM with confidence. Book a demo to see it in action.
Book a demo