CPT code guide

CPT 98985 in 2026

Musculoskeletal RTM device supply for 2 to 15 days in a 30-day period

98985 is the lower-threshold musculoskeletal device-supply code in the 2026 RTM framework. It gives clinics a compliant billing path when the patient generates meaningful activity in the period, but does not reach the higher 16-day threshold.

  • Used for musculoskeletal RTM device supply in the 2 to 15 day range
  • Selected instead of 98977 when the patient does not reach 16 to 30 days in the same 30-day period
  • Separate from set-up billing and separate from monthly management-time billing
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2 to 15 days Musculoskeletal system Sometimes therapy No CQ or CO under CMS RTM de minimis rule

What 98985 is really for

98985 exists because the old RTM framework was too blunt. Before 2026, clinics had a much harder threshold problem. Either a patient reached the higher day count or the episode produced no device-supply billing path at all.

Now there is a cleaner lower-threshold code for musculoskeletal RTM. That matters because a patient can still be engaged, clinically worth monitoring, and legitimately billable even when the episode does not reach the higher 16 to 30 day range.

98985 is not a weaker version of 98977. It is the correct code when the patient’s qualifying activity lands in the lower 2 to 15 day band for that 30-day period.

Quick facts

How to think about 98985 in practice

Question
Short answer
What that means operationally
What does it cover
Musculoskeletal device supply for 2 to 15 days in a 30-day period
This is the device-supply side of RTM, not the set-up side and not the monthly management side.
When is it billed
At the end of the 30-day period when the final count is 2 to 15 days
You bill based on the completed period and the final day count, not on a guess about where the patient may end up.
What if the patient reaches 16 or more days
Use 98977 instead
The lower code and higher code are alternatives for the same category. They do not stack in the same 30-day period.
What if the patient only has 0 or 1 day
Do not bill a device-supply code for that period
The period may still matter operationally, but it does not reach a billable device-supply threshold.
Modifier logic for therapists
Use GP, GO, or GN when furnished as therapy
98985 is a sometimes therapy code beginning in 2026, so therapist billing under a therapy plan of care requires the discipline modifier.
Does CQ or CO apply
Not under CMS’s RTM de minimis rule for 98985
CMS explicitly limits that assistant-modifier rule to 98975, 98979, 98980, and 98981 in the RTM family.
What does it cover
AnswerMusculoskeletal device supply for 2 to 15 days in a 30-day period
MeaningThis is the device-supply side of RTM, not the set-up side and not the monthly management side.
When is it billed
AnswerAt the end of the 30-day period when the final count is 2 to 15 days
MeaningYou bill based on the completed period and the final day count, not on a guess about where the patient may end up.
What if the patient reaches 16 or more days
AnswerUse 98977 instead
MeaningThe lower code and higher code are alternatives for the same category. They do not stack in the same 30-day period.
What if the patient only has 0 or 1 day
AnswerDo not bill a device-supply code for that period
MeaningThe period may still matter operationally, but it does not reach a billable device-supply threshold.
Modifier logic for therapists
AnswerUse GP, GO, or GN when furnished as therapy
Meaning98985 is a sometimes therapy code beginning in 2026, so therapist billing under a therapy plan of care requires the discipline modifier.
Does CQ or CO apply
AnswerNot under CMS’s RTM de minimis rule for 98985
MeaningCMS explicitly limits that assistant-modifier rule to 98975, 98979, 98980, and 98981 in the RTM family.

How 98985 fits inside the six-code RTM workflow

The cleanest mental model is simple. 98975 starts the episode. 98985 and 98977 cover the device-supply side based on the final day count in the 30-day period. 98979, 98980, and 98981 cover separate treatment-management work when the clinician is actively managing the case and the monthly rules are met.

That means 98985 should not be treated as a general monthly RTM placeholder. It only answers one question: did the musculoskeletal device-supply activity land in the 2 to 15 day band for that period?

What clinics need to track

The operational discipline for 98985 is mostly about period integrity. The clinic needs a clean 30-day window, a final count that is easy to defend, and a record that makes it obvious why the lower device-supply code was selected instead of the higher one.

That usually means documenting the period start date, period end date, and the final qualifying day count in a way that does not require manual reconstruction later.

Documentation

What matters most for documentation

Record 1

Make the dates obvious

Most 98985 disputes are easier to resolve when the 30-day start date and end date are explicit and tied to the report.

Record 2

Make the day count final

The record should show the completed day count for the period so it is obvious why the lower-threshold code was used.

Record 3

Keep it separate from management time

Device-supply logic and monthly management logic are different. Mixing them together makes the billing picture harder to defend.

Common scenarios

Scenario

Month one with light engagement

The patient completes enough qualifying activity to land at 6 days in the first 30-day period. That is a straightforward 98985 case, assuming the period is documented cleanly.

Scenario

Improving engagement over time

The first 30-day period ends at 10 days, so 98985 fits. The next period ends at 18 days, so the workflow shifts to 98977 for that later 30-day window.

Scenario

Not enough activity

The patient only generates 1 qualifying day in the period. That episode may still matter clinically, but it does not support a device-supply billing code for that window.

The nuance clinics miss

The biggest conceptual mistake is treating 98985 as a downgrade from 98977. It is not a fallback. It is the correct code for the lower band. When clinics frame it as a consolation code, they tend to under-document it or treat those episodes as less legitimate, which is the wrong mindset.

The second mistake is assuming all RTM codes share the same assistant-modifier logic. They do not. CMS carved out the de minimis assistant standard differently for RTM, which is why 98985 needs to be handled more carefully than generic modifier cheat sheets suggest.

The third mistake is choosing too early. A cleaner workflow is to let the 30-day window complete, confirm the final day count, and then select 98985 or 98977 based on what actually happened.

Related pages

98975 starts the RTM episode.

98977 is the higher-threshold musculoskeletal device-supply code for 16 to 30 days in the same 30-day structure.

98979, 98980, and 98981 cover separate monthly treatment-management work.

RTM billing modifiers and place of service covers modifier logic in more detail.

Make RTM simple for your therapists

Orva helps clinics track 30-day periods, keep day counts clear, and generate billing-ready documentation across the full six-code musculoskeletal RTM workflow.

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