The RTM billing cheat sheet for physical therapy
All six musculoskeletal RTM codes, the thresholds that decide each claim, 2026 Medicare rates, modifiers and documentation on one page you can print and keep at the front desk.
The six musculoskeletal RTM codes
Rates are 2026 Medicare national averages for the non-facility setting. Actual payment is adjusted by locality, and commercial payers set their own.
| Code | What it covers | Threshold | Billing period | 2026 avg |
|---|---|---|---|---|
| 98975 | Set-up and patient education on the monitoring application | At least 2 days of monitoring | Once per episode of care | $21.71 |
| 98985New 2026 | Device supply for musculoskeletal data access or transmission | 2 to 15 days of data | Rolling 30 days | $51.44 |
| 98977 | Device supply for musculoskeletal data access or transmission | 16 to 30 days of data | Rolling 30 days | $51.44 |
| 98979New 2026 | Treatment management, reviewing data and managing the patient | 10 to 19 minutes plus one real-time interaction | Calendar month | $26.39 |
| 98980 | Treatment management, first 20 minutes | 20 minutes or more plus one real-time interaction | Calendar month | $54.11 |
| 98981 | Treatment management, each additional 20 minutes | Each additional full 20 minutes beyond 98980 | Calendar month, add-on to 98980 | $41.42 |
Which code applies this period
Device supply and treatment management run on two different clocks. Count each one separately, then pick the tier.
Days of data in the 30-day period
Rolling 30 days from the start of monitoring for that patient
Management minutes in the calendar month
Resets on the 1st and needs one real-time interaction
Minutes that count include reviewing the patient's data, adjusting the home program, and talking with the patient or caregiver about the plan. Scheduling, billing and other administrative work don't count, and minutes don't carry over to the next month.
What can be billed together
- 98985 and 98977Mutually exclusive. One device supply code per 30-day period.
- 98979 and 98980Mutually exclusive. Once the month reaches 20 minutes, it bills under 98980.
- 98981Add-on to 98980 only. There is no add-on path from 98979.
- 98975Once per episode of care, not monthly for a continuing patient.
- Real-time interactionRequired for every management code. Asynchronous messages alone don't meet it.
- RTM and RPMSeparate code families. A tool built for vitals monitoring won't track RTM day counts or therapy rules.
Modifiers
Separate three questions. Which discipline, whether an assistant crossed the de minimis threshold, and whether the payer wants telehealth reporting.
| Question | Use | Applies to |
|---|---|---|
| Discipline | GP for PT, GO for OT, GN for SLP | All RTM codes furnished under a therapy plan of care |
| Assistant | CQ for a PTA, CO for an OTA, when the assistant furnishes more than 10% of the service | 98975, 98979, 98980 and 98981 only |
| Not on supply | No CQ or CO under the RTM de minimis rule | 98985 and 98977 |
| 95 | Payer-specific, not automatic | Only when a payer tells you to report the live interaction as telehealth |
Place of service
| POS | When it fits |
|---|---|
| 11 | Office. The usual starting point for clinic-based RTM. |
| 10 | Telehealth with the patient at home, only when the payer wants telehealth POS for the live interaction. |
| 02 | Telehealth with the patient somewhere other than home, under the same payer condition. |
| 12 | Home. An edge case, not the default just because the patient uses the app at home. |
| 19 or 22 | Outpatient hospital. Hospital-based clinics have separate payment details for supply and management codes. |
More detail in the RTM modifiers and place of service guide.
Documentation checklist
A reviewer should be able to reconstruct the month without calling the clinic.
- Order and consent. RTM ordered by the treating clinician, with patient consent recorded and cost-sharing explained.
- Set-up and education. What was configured, what the patient was taught, and when, supporting 98975.
- Day count tied to the period. Which days data was sent and which 30-day window they fall in.
- Clinical time. Minutes spent reviewing data, adjusting the program and discussing the plan, not administrative work.
- The live interaction. Date, participants and substance of the month's real-time contact.
- The clinical response. What the data showed and what changed as a result.
- A monthly summary for the biller. Codes, thresholds met, modifiers and supporting detail before the claim goes out.
Why RTM claims get denied
- Wrong device tierDays assumed rather than counted, or counted against the calendar month instead of the rolling 30 days.
- No live interactionManagement time came entirely from asynchronous review and messaging.
- Assistant modifiers misappliedCQ or CO added to a supply code, or left off a management code a PTA materially contributed to.
- Exclusive codes on one claim98985 with 98977, 98979 with 98980, or 98981 attached to 98979.
- Set-up billed more than once98975 repeating monthly within one continuing episode of care.
- Time without decisionsMinutes documented with no record of what the data showed or what changed.
What a month is worth
Two patients on the same caseload at 2026 national averages. Before 2026, the second patient qualified for neither code.
Engaged patient
20 days of data, 25 minutes, one live interaction
Partially engaged patient
10 days of data, 14 minutes, one live interaction
Add 98975 at $21.71 once per episode. To run the numbers on your own caseload, use the RTM revenue calculator.
Proposed for 2027
Proposed, not final. The CY 2027 Physician Fee Schedule proposed rule would pay for RTM and RPM only when the practice's own employed clinical staff furnish the service, so time from contracted third-party monitoring companies would no longer count. It would also extend the established patient requirement to RTM and require an initiating visit before monitoring begins.
CMS could finalize, change or drop any of this. Plan for it, but keep billing under the 2026 rules above until a final rule takes effect. The details are in our 2027 proposal breakdown.
Orva tracks both clocks for every patient
Your own therapists run RTM in Orva. Day counts, minutes and the right code for each patient are tracked automatically, with a patient app people keep using.