RTM for physical therapy, with every code and rule in one place
Six musculoskeletal codes, two billing clocks, and the thresholds that decide each claim in 2026, plus how your own therapists can run it inside the clinic with Orva.
7-day free trialWhat does this patient qualify for?
Choose where the patient landed this period and the codes update.
Below 2 days of data and 10 minutes of management, no RTM code applies this period.
Management time can't be billed without at least one real-time interaction with the patient or caregiver in the month.
Includes 98975 set-up, billed once per episode of care. Figures are 2026 Medicare national averages for the non-facility setting and vary by locality, payer, and contract.
- Codes covered98975, 98985, 98977, 98979, 98980, 98981
- New for 202698985 and 98979 add a lower tier for short episodes and partial months
- Who furnishes itPTs and OTs under a therapy plan of care, plus physicians and other qualified professionals
- Proposed for 2027Payment only when the practice's own employed staff furnishes the service
What remote therapeutic monitoring is
Remote therapeutic monitoring is a defined, reimbursable service for the care a clinician provides between visits, using data the patient sends from a monitoring application.
In musculoskeletal care, three things happen together. The patient sends non-physiologic data such as home exercise adherence, pain, and function. The clinician reviews that data and acts on it. The clinic documents both clearly enough that a payer can follow what happened.
RTM is separate from the visit. It doesn't replace a treatment session, it doesn't require a telehealth encounter, and it isn't a messaging feature added to a portal. It has its own thresholds, its own billing periods, and its own documentation trail.
Physical and occupational therapists furnish RTM under a therapy plan of care, which is why the therapy modifiers and assistant rules apply. Physicians and other qualified health care professionals can furnish it too. In every case, a licensed clinician reviews the data and manages the patient.
What changed in 2026
The CY 2026 Medicare Physician Fee Schedule final rule added two musculoskeletal RTM codes, 98985 for device supply across 2 to 15 days and 98979 for 10 to 19 minutes of treatment management. CMS also designated 98979, 98984, and 98985 as sometimes therapy services beginning January 1, 2026.
Before this, a patient with 11 days of data and 14 minutes of management met neither threshold, so no code applied. The new lower tiers bring short episodes, late starters, and partially adherent patients into the service.
Before 2026
One threshold on each side. 16 days of data for device supply and 20 minutes for management, with no code below either line.
From January 2026
Two tiers on each side. Device supply splits into 2 to 15 and 16 to 30 days. Management splits into 10 to 19 and 20 or more minutes.
The practical result is a tracking problem. A clinic now needs to know which tier each patient will land in before the period closes, which makes it a workflow question long before it becomes a billing question.
What CMS proposed for 2027, and why RTM belongs in house
Proposed rule, not final. These provisions come from the CY 2027 Medicare Physician Fee Schedule proposed rule, issued after two OIG reports on oversight and billing in remote monitoring. CMS could finalize, modify, or drop any of them. Plan for them, but don't bill against them.
The headline proposal changes who can do the work. Beginning January 1, 2027, RTM and RPM would be payable only when furnished by clinical staff who are direct employees of the billing practitioner or practice. Time from contracted third-party monitoring companies would no longer count toward the claim.
CMS said outsourced arrangements don't provide adequate oversight, management, or collaboration to support billing these services. Staff still wouldn't need to be in the building and patients still wouldn't need to be on site, but the people furnishing the service would need to be employed by the practice, work under the billing practitioner's general supervision, and meet the usual incident-to requirements.
- Direct employeeThe provision that reshapes the market. Vendor-supplied nurses and contracted monitoring teams would stop being billable time.
- Established patientThe established patient requirement that applies to RPM would extend to RTM, limiting monitoring to patients who already have a relationship with the billing practitioner.
- Initiating visitA separately reportable face-to-face visit, in person or by telehealth, would need to happen before RTM begins, and RTM would need to be discussed at it.
- ValuationCMS proposed lower practice expense inputs for device and set-up codes and none for treatment management codes, which would lower payment on the management side.
- Code consolidationCMS asked for comment on collapsing all seventeen RPM and RTM codes into four G-codes, including GRTM1 for set-up and education and GRTM2 for monthly monitoring and management. This was a comment request rather than a formal proposal.
Rebuild the program on a deadline
A clinic that handed RTM to a monitoring company's staff would need to bring the clinical work back in house, hire or reassign for it, and rewrite the vendor relationship before the effective date.
Already on the right side of the rule
A clinic whose own therapists deliver RTM with software, rather than through an outside monitoring service, already meets the employment condition. What remains is ordinary documentation for a practice already treating the patient.
Outsourcing looks like the low-effort path until the payment rules stop recognizing it. A clinic that owns the clinical work keeps the patient relationship and isn't exposed to a rule aimed at vendor-staffed monitoring.
Orva is built for that model. It's software your therapists use, not a service that manages your patients for you. If the direct employee proposal is finalized as written, clinics using Orva this way already meet it.
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. Need it on one page? Use the printable RTM billing cheat sheet.
| 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 in 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 in 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 | Additional treatment management, each further 20 minutes | Each additional full 20 minutes beyond 98980 | Calendar month, add-on to 98980 | $41.42 |
Set-up and patient education on the monitoring application
At least 2 days of monitoring, once per episode of care
Treatment management, 10 to 19 minutes plus one real-time interaction
Calendar month, new in 2026
Additional treatment management, each further full 20 minutes
Calendar month, add-on to 98980
Two clocks that don't line up
This is the detail most RTM programs get wrong, and the reason month-end can turn into a reconstruction project.
Device supply runs on a rolling 30 days
98985 and 98977 count days across a 30-day window that starts when monitoring begins for that patient. A patient who enrolls on the 12th has a window that closes on the 11th of the next month.
Management runs on the calendar month
98979, 98980, and 98981 add up clinician time within the calendar month and reset on the first. Minutes don't carry over.
Across a caseload of a hundred patients, every one has a personal device window and a shared calendar window, and the qualifying tier on each can change on any given day. A spreadsheet doesn't keep up with that.
How treatment management minutes add up
The three management codes pay for the clinical work a therapist does with a patient's data over the calendar month. The total minutes decide which code applies, and the real-time interaction decides whether any of them can be billed at all.
- Under 10 minutesNo management code this month. Device supply and set-up can still be billed if their own thresholds are met.
- 10 to 19 minutes98979. The lower tier added in 2026 for patients who needed less of the therapist's time this month.
- 20 to 39 minutes98980. Once the month reaches 20 minutes, it bills under 98980 instead of 98979, never both.
- 40 minutes or more98980 plus 98981 for each additional full 20 minutes. A partial block beyond 20 doesn't qualify for the add-on.
Time that counts
Reviewing the patient's data, adjusting the home program, and communicating with the patient or caregiver about the plan. The real-time interaction counts too, whether it happens in person or by phone, so time it like the rest of the month's work.
Time that doesn't
Scheduling, billing, and other administrative work, along with any minutes already counted toward another billed service. Minutes from last month don't carry forward either.
A useful habit is making at least one program change for each patient every month. It gives the minutes a clear clinical purpose, and it gives a reviewer something concrete to follow when they read the note.
Which codes can be billed together
- 98985 and 98977Mutually exclusive. One device supply code per 30-day period. Count the days, then choose the tier.
- 98979 and 98980Mutually exclusive. One base management code per calendar month. Once the clinician reaches 20 minutes, the month bills under 98980.
- 98981 on 98979Not allowed. The add-on attaches to 98980 only. There is no add-on path from the 10-minute code.
- 98975 frequencyOnce per episode of care. An episode begins when RTM starts and ends when the treatment goals are met. It shouldn't repeat monthly for a continuing patient.
- Live interactionRequired for every management code. At least one real-time communication with the patient or caregiver in the calendar month. Asynchronous messages on their own don't satisfy it.
Therapy modifiers and the assistant rule
RTM codes are sometimes therapy services. Under a therapy plan of care, the claim needs the discipline modifier, and a second modifier may apply depending on who did the work.
- GP, GO, GNThe discipline modifier for services under a therapy plan of care. GP for physical therapy, GO for occupational therapy, GN for speech-language pathology.
- CQ, COThe assistant modifiers, applied when a PTA or OTA furnishes more than ten percent of the service. CQ for a physical therapist assistant, CO for an occupational therapy assistant.
- The exceptionThe de minimis standard applies to 98975, 98979, 98980, and 98981. It does not apply to the device supply codes 98985 and 98977, and it's the most commonly missed rule in RTM claims.
Place of service and the full modifier picture are in the RTM modifiers and place of service guide.
What a defensible RTM record contains
Good documentation is about traceability, not volume. A reviewer should be able to reconstruct the month without calling the clinic.
- The 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.
- A day count tied to the period. Which days data was sent and which 30-day window they fall in, supporting the correct device tier.
- Time that reflects clinical work. Minutes spent reviewing data, adjusting the program, and discussing the plan, not administrative overhead.
- 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. Time with no decisions is the weakest kind of RTM note.
- A monthly summary the biller can use. Codes, thresholds met, modifiers, and supporting detail assembled before the claim goes out.
With that summary in hand, charge entry becomes the simple part. The codes, modifiers, and units carry straight into the claim in your EMR, and the record behind each one stays in the patient's chart for anyone who needs to follow it later.
What the tiers are worth in practice
Two patients on the same caseload at 2026 national averages. Before this year, the second patient didn't qualify for either code.
Engaged patient
20 days of data, 25 minutes, one live interactionPartially engaged patient
10 days of data, 14 minutes, one live interactionAdd 98975 at $21.71 once per episode. Most clinics have more patients in the second group than they expect, and no easy way to see them before the period closes.
To run these numbers on your own caseload, use the RTM revenue calculator. For a plain-language look at whether the time and cost pay off at a smaller practice, read Is RTM worth it for a small physical therapy clinic?
RTM and RPM are not interchangeable
RTM tracks therapeutic data
Exercise adherence, therapy response, pain, and function. Furnished by PTs and OTs under a plan of care as well as by physicians. The fit for post-operative recovery, chronic musculoskeletal pain, and outpatient rehab.
RPM tracks physiologic data
Weight, blood pressure, pulse oximetry, and similar vital signs. Generally furnished by physicians and qualified health professionals. The fit for chronic medical management.
Clinics sometimes inherit an RPM platform and try to run RTM inside it. The codes sit near each other on the fee schedule, but day-count logic, therapy modifiers, plan-of-care attachment, and assistant rules all differ, and a tool built for vitals won't track them.
Why RTM claims get denied
The wrong tier was billed
The day count was assumed rather than counted, or measured against the calendar month instead of the rolling 30 days.
No live interaction in the month
Management time came entirely from asynchronous review and messaging, with no real-time contact to support the code.
Assistant rules applied incorrectly
CQ or CO added to a device supply code, or left off a management code a PTA materially contributed to.
Exclusive codes on one claim
98985 with 98977, 98979 with 98980, or 98981 attached to the 10-minute code.
Set-up billed more than once
98975 repeating monthly for a patient in a single continuing episode of care.
Time without clinical decisions
Minutes documented with no record of what the data showed or what the clinician changed.
How Orva runs RTM inside your clinic
Orva was built for outpatient rehab rather than adapted from vitals monitoring. Patients get an app they'll keep using, and the clinic sees where every patient stands while there's still time to act.
A consumer-grade app for patients
Home programs, check-ins, and messaging on the patient's own phone, built to the standard they expect from their bank and the stores they shop at. Adherence drives every threshold on this page.
Both clocks visible before they close
Where each patient sits against the day and minute tiers, who needs a live interaction before month-end, and what's still missing.
A closeout that's already assembled
Qualifying codes, thresholds met, and supporting documentation per patient, so the biller reviews a summary instead of rebuilding the month.
Your own therapists, your own workflow
RTM delivered by the people already treating the patient, inside the routine the clinic already runs, with Orva Sidecar working alongside WebPT.
Common RTM questions
Can physical therapists bill RTM?
Yes. Physical and occupational therapists can furnish and bill RTM under a therapy plan of care, with the appropriate therapy modifier on the claim. RTM codes are sometimes therapy services, which is why the modifier and assistant rules apply.
How many days of data does RTM require?
At least 2 days of data in a 30-day period to bill 98985, and 16 or more to bill 98977. Below 2 days no device supply code applies, and 98975 set-up also requires at least 2 days of monitoring.
Can 98985 and 98977 be billed in the same period?
No. They are mutually exclusive, so only one device supply code can be billed per patient per 30-day period. Count the days in the window and bill the matching tier.
What counts as management time for 98979, 98980, and 98981?
Clinician time spent reviewing data, adjusting the therapeutic program, and communicating with the patient about the plan during the calendar month. Every management code also requires at least one real-time interaction with the patient or caregiver that month. Administrative time doesn't count.
Does the real-time interaction count toward management minutes?
Yes. Time spent in the live interaction with the patient or caregiver counts toward the month's management minutes, as long as it isn't also counted toward another billed service. It can happen in person or by phone, and it should be timed and documented like the rest of the month's work.
Do device supply and management codes use the same billing period?
No. Device supply codes count days across a rolling 30-day period that starts when monitoring begins for the patient. Management codes add up time within the calendar month and reset on the first.
Does the assistant modifier apply to every RTM code?
No. The de minimis standard, and with it the CQ or CO modifier, applies to 98975, 98979, 98980, and 98981 when a PTA or OTA furnishes more than ten percent of the service. It doesn't apply to the device supply codes 98985 and 98977.
How often can 98975 be billed?
Once per episode of care. The episode begins when RTM starts and ends when the treatment goals are met. It isn't a recurring monthly charge.
What did CMS propose for RTM in 2027?
The CY 2027 Medicare Physician Fee Schedule proposed rule would pay for RTM and RPM only when furnished by clinical staff directly employed by the billing practice, limit RTM to established patients, and require a separately reportable face-to-face initiating visit. CMS also proposed lower practice expense valuations and asked for comment on consolidating the code families into four G-codes. These were proposals, not final policy, at the time of publication.
Would the 2027 proposal stop clinics from outsourcing RTM?
If finalized as written, yes. Time from clinical staff supplied under contract by a third-party monitoring company would no longer count toward the claim starting January 1, 2027. Clinics running RTM with their own employed staff wouldn't be affected by that provision.
What is the difference between RTM and RPM?
RTM monitors therapeutic data such as exercise adherence, therapy response, pain, and function, and can be furnished by therapists under a plan of care. RPM monitors physiologic data such as blood pressure and weight and is generally furnished by physicians and other qualified health professionals. For musculoskeletal rehab, RTM is the applicable family.
Does RTM require separate hardware?
Musculoskeletal RTM programs like Orva run on an application on the patient's own phone, with no separate hardware to ship or collect. CMS requires the monitoring device to meet the FDA definition of a medical device, so confirm that with any vendor you evaluate.
How much does RTM pay per patient?
At 2026 Medicare national averages, an engaged month with 98977 and 98980 is about $106, and a partially engaged month with 98985 and 98979 is about $78, with 98975 adding about $22 once per episode. Actual payment varies by locality, payer, and contract, so treat these as a planning range.
Real RTM™, delivered by your own therapists
See where your patients land against every threshold on this page, inside the workflow your clinic already runs.
- All six musculoskeletal codes tracked in one workflow
- Rolling 30-day and calendar-month clocks handled separately
- Delivered by your own staff, under your own plans of care
- Built for outpatient PT and orthopedic clinics
Go deeper on a specific code, or run your numbers
This page is a general reference for clinic operations and is not billing, legal, or coding advice. Reimbursement figures are 2026 Medicare national averages for the non-facility setting and are adjusted by locality. Commercial payer coverage and rates vary. CY 2027 provisions described here come from the CY 2027 Medicare Physician Fee Schedule proposed rule and are not final policy. CPT is a registered trademark of the American Medical Association. Confirm coding and coverage decisions against current CMS guidance, your MAC, and your payer contracts.