RTM 2026: Codes Explained for Clinics | Orva

Remote Therapeutic Monitoring

RTM 2026: Codes explained for clinics

The 2026 Medicare Physician Fee Schedule adds new flexibility for Remote Therapeutic Monitoring. New CPT options recognize shorter device data periods and shorter management time, while the existing RTM codes remain in use. This guide summarizes what is changing, what stays the same, and how to prepare.

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At a glance

StatusChanges described here reflect the CY 2026 Medicare Physician Fee Schedule proposed rule. Final policy will publish later this year with an effective date of January 1, 2026.
New flexibilityNew RTM codes capture 2–15 days of device data in a 30-day period and 10–19 minutes of monthly management time with real-time, patient-facing communication.
What stays the sameExisting RTM codes 98975, 98977, 98980, and 98981 remain in use. Device supply codes continue to require daily recording or programmed alerts. Management codes require an interactive touchpoint in the month.
Device day rangesExisting device supply codes will be clarified to represent 16–30 days per 30-day period. New device supply codes represent 2–15 days.
Who can billPhysicians and other qualified health care professionals. For therapists, services are therapy and typically require GP, GO, or GN. Append CQ or CO when assistant involvement exceeds the de minimis threshold.

Always confirm your Medicare Administrative Contractor and commercial payer policies.

What is new for 2026

Shorter device periods

New RTM device supply codes allow billing when the patient records 2–15 days of data in a 30-day period. The current 16–30-day pathway remains available.

Shorter management time

A new RTM management code captures 10–19 minutes in a month with at least one real-time, patient-facing interaction. Use with existing 98980 and 98981 when time reaches 20 or more minutes.

Clearer descriptors

Existing device codes will explicitly describe the 16–30-day range. This helps avoid denials tied to day count interpretation.

The RTM code set in 2026

Device supply

  • 98976 Respiratory device supply: represents 16–30 days in a 30-day period.
  • 98977 Musculoskeletal device supply: represents 16–30 days in a 30-day period.
  • 98978 Cognitive therapy or digital therapeutic device supply: represents 16–30 days in a 30-day period.
  • New 2–15-day device codes Placeholders appear as 98XX4, 98XX5, 98XX6 for 2–15 days per 30-day period across RTM device categories. Exact numeric codes will publish before January 2026.

Treatment management

  • 98980 First 20 minutes in a calendar month with at least one interactive communication.
  • 98981 Each additional 20 minutes in the same month with interactive communication.
  • New 10–19-minute code Placeholder appears as 98XX7 for the first 10–19 minutes in a month with interactive communication. Use 98981 only when the incremental 20-minute threshold is met.

Exact code numbers and rates finalize in the CMS 2026 final rule and AMA CPT 2026 release.

Documentation checklist

  • Device days in period: 2–15 or 16–30, with daily recordings or programmed alerts.
  • Monthly time log: dates, activities, totals. Note the real-time, patient-facing interaction.
  • App or device name, purpose, and linkage to the plan of care.
  • Do not double count time with other services in the same period.

Modifiers and POS

Therapy services typically include GP, GO, or GN. Add CQ or CO when assistant involvement exceeds the de minimis threshold. Some payers require 95 to flag the interactive touchpoint. Place of Service is commonly 11 Office for non-face-to-face services. Confirm payer rules for POS 02 or 10 during telemedicine.

See the full guide: RTM modifiers and POS.

Common 2026 scenarios

Patient records 12 days this period

Use the new 2–15-day device code for this 30-day period if other requirements are met. If monthly management time totals 10–19 minutes with an interactive touchpoint, use the new management code. If time reaches 20 minutes, use 98980, and 98981 for each additional 20 minutes.

Patient records 25 days this period

Use the existing device code for 16–30 days in a 30-day period. Layer 98980 and 98981 based on management time and the interactive communication requirement.

Messaging only, no real-time call

Asynchronous messages do not satisfy the interactive requirement. Schedule a brief call to qualify management codes in that month.

Therapy assistant involvement

Append CQ or CO when assistant involvement exceeds the de minimis threshold. Include GP, GO, or GN under the plan of care as applicable.

Related RTM pages

98975

Initial set-up and patient education. Report once per episode of care.

98977

Device supply and therapeutic data collection each 30 days.

98980

First 20 minutes of monthly management time with interactive communication.

98981

Each additional 20 minutes of management time in the same month after 98980.

For the full picture visit the RTM guide.

Compliance note

This educational content summarizes the 2026 proposed rule and CPT updates at the time of writing. Coverage and payment vary by payer and may change in the final rule. Always confirm current policy with your MAC and commercial payers.

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