RTM for physical therapy, built around the thresholds that decide the claim

What remote therapeutic monitoring is

In musculoskeletal care that means three things happening together. The patient transmits non-physiologic data such as home exercise adherence, pain, and function. The clinician reviews that data and acts on it. The clinic documents both well enough that a payer can follow what happened without asking.

RTM is separate from the visit. It does not replace a treatment session, it does not require a telehealth encounter, and it is not a messaging feature bolted onto a portal. It is a distinct service with its own thresholds, its own billing periods, and its own documentation trail.

Physical therapists and occupational therapists furnish RTM under a therapy plan of care, which is why the therapy modifiers matter and why the assistant rules matter. Physicians and other qualified health care professionals can also furnish it. The common thread is that a licensed clinician is reviewing the data and managing the patient, not a piece of software running unattended.

What changed in 2026, and why it matters more than it sounds

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 who transmitted data on 11 days and took 14 minutes of clinical management produced nothing. All that work fell below the old 16-day and 20-minute floors and was written off. That patient is now billable.

The practical consequence is a tracking problem. A clinic now needs to know which tier every patient landed in before the period closes, not after. That is a workflow question long before it is a billing question.

What CMS proposed for 2027, and why RTM belongs in house

The headline proposal would change who is allowed to do the work. Beginning January 1, 2027, RTM and RPM services would be payable only when furnished by clinical staff who are direct employees of the billing practitioner or that practitioner’s practice. Time from contracted third-party monitoring companies would no longer count toward the claim.

CMS was explicit about the reasoning. It does not consider outsourced arrangements to provide adequate oversight, management, or collaboration to support billing these services. Staff would still not need to sit in the building, and patients would still not need to be on site, but the staff furnishing the service would need to be employed by the practice, working under the billing practitioner’s general supervision, and meeting the usual incident-to requirements.

• Direct employee
  The one that reshapes the market. Clinical staff furnishing RTM would have to be direct employees of the billing practice. Vendor-supplied nurses and contracted monitoring teams would stop being billable time.
• Established patient
  The established patient requirement that already applies to RPM would extend to RTM. Monitoring could only be furnished to patients who already have a relationship with the billing practitioner.
• Initiating visit
  A separately reportable, face-to-face initiating visit, in person or by telehealth, would be required before RTM begins. RTM would have to be discussed at that visit for it to count.
• Valuation
  CMS proposed reducing practice expense inputs for device and set-up codes, and eliminating practice expense inputs entirely for treatment management codes. The effect would be lower payment on the management side.
• Code consolidation
  CMS sought comment on collapsing all seventeen RPM and RTM codes into four G-codes, with GRTM1 for set-up and education and GRTM2 for monthly monitoring and management. This was a comment solicitation rather than a formal proposal.

The same caseload, two very different positions

This is the structural argument for running RTM with your own people. Outsourcing looks like the low-effort path right up until the payment rules stop recognizing it. A clinic that owns the clinical work owns the revenue, keeps the patient relationship, and is not exposed to a rule change aimed squarely at vendor-staffed monitoring.

Orva is built for that side of the line. It is software your staff runs, not a service that runs your patients for you. If the direct employee proposal is finalized as written, clinics on this model are already compliant with it.

The six musculoskeletal RTM codes

Rates shown are 2026 Medicare national averages for the non-facility setting. Your actual payment is adjusted by locality, and commercial payers set their own.

The two clocks, and why they do not line up

This is the detail most RTM programs get wrong, and it is the reason month-end feels like an archaeology project.

Two clocks running at different speeds across a caseload of a hundred patients is not something a spreadsheet handles gracefully. Every patient has a personal device window and a shared calendar window, and the qualifying tier on each can change on any given day.

Which codes can and cannot be billed together

• 98985 vs 98977
  Mutually exclusive. One device supply code per 30-day period. Count the days, then choose the tier. Billing both for the same patient in the same period will be denied.
• 98979 vs 98980
  Mutually exclusive. One base treatment management code per calendar month. Once the clinician reaches 20 minutes, the month bills under 98980 and 98979 comes off the claim.
• 98981 on 98979
  Not allowed. The additional 20-minute add-on attaches to the full 98980 base only. There is no add-on path from the 10-minute code.
• 98975 frequency
  Once per episode of care. An episode begins when RTM starts and ends when the established treatment goals are met. It is not a monthly code and it should not reappear each month for a continuing patient.
• Interactive communication
  Required for every management code. At least one real-time communication with the patient or caregiver in the calendar month. Asynchronous messages and portal notes do not satisfy it on their own.

Therapy modifiers and the assistant rule

RTM codes are sometimes therapy services. When the service is furnished under a therapy plan of care, the claim needs the corresponding therapy modifier, and a second modifier may apply depending on who did the work.

• GP / GO / GN
  The discipline modifier for services under a therapy plan of care. GP for physical therapy, GO for occupational therapy, GN for speech-language pathology.
• CQ / CO
  The de minimis 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 exception
  The de minimis standard applies to 98975, 98979, 98980, and 98981. It does not apply to the device supply codes 98985 and 98977. This split is the single most commonly missed rule in RTM claims.

Place of service and the full modifier picture are covered in the RTM modifiers and place of service guide.

What a defensible RTM record contains

Good RTM 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 obtained and recorded, and cost-sharing explained.
• Set-up and education. What was configured, what the patient was taught, and the date it happened, supporting 98975.
• A day count tied to the period. Which days data was actually transmitted, and which 30-day window those days fall inside, supporting the correct device tier.
• Time that reflects clinical work. Minutes attributed to reviewing data, adjusting the program, and communicating about the plan, not to administrative overhead.
• The interactive communication. Date, participants, and substance of the live call or video contact for the month.
• The clinical response. What the data showed and what changed as a result. A record with time but no decisions is the weakest kind of RTM note.
• A monthly summary the biller can use directly. Codes, thresholds met, modifiers, and supporting detail assembled before the claim goes out rather than after a denial.

What the tiers are worth in practice

Two patients on the same caseload, using 2026 national averages. The second one produced nothing at all before this year.

Add 98975 at $21.71 once per episode. The point is not the individual number, it is that the second column used to be a zero. Most clinics have more patients in the second column than they think, and no reliable way to see them.

RTM and RPM are not interchangeable

Clinics sometimes inherit an RPM platform and try to run RTM inside it. The codes look adjacent on a fee schedule and the workflows are not. Day-count logic, therapy modifiers, plan-of-care attachment, and assistant rules all differ, and a tool built for vitals will not track any of them.

Why RTM claims get denied

How Orva runs RTM inside your clinic

Orva was built for outpatient rehab, not retrofitted from vitals monitoring. Patients get a recovery experience they will use, and the clinic gets the threshold visibility that makes the month closeable.

Common RTM questions