RTM Billing

RTM Billing in 2026: You No Longer Need 16 Days

The 16-day rule used to decide whether a month of remote therapeutic monitoring paid anything at all. From January 2026, patients with 2 to 15 days of data are billable too. Here's what changed and how to capture it.

November 20268 min read
Nurse and physician reviewing a tablet together in a clinic hallway

The Short Version

Until 2026, a remote therapeutic monitoring (RTM) device-supply code could only be billed when a patient sent data on at least 16 days in a 30-day period. A patient who logged 12 days earned the practice nothing for that month, even though staff had done the work.

From January 1, 2026, that cliff is gone. New device-supply codes cover 2 to 15 days of data, and a new treatment-management code covers 10 to 19 minutes of clinical time. Practices that set their workflows around the old rule are leaving partial months unbilled.

Looking ahead: the 2027 final rule keeps these codes but limits RTM to established patients and adds an initiating visit. See what changes for RTM in 2027.

The 2026 RTM Codes at a Glance

Device supply, 16 to 30 days (the existing codes, now defined as 16–30 days):

  • 98976: respiratory system
  • 98977: musculoskeletal system
  • 98978: cognitive behavioral therapy

Device supply, 2 to 15 days (new for 2026):

  • 98984: respiratory system
  • 98985: musculoskeletal system
  • 98986: cognitive behavioral therapy

Treatment management (clinical time per calendar month):

  • 98979 (new): 10 to 19 minutes, with at least one real-time interaction with the patient or caregiver
  • 98980: the first 20 minutes, with at least one interactive communication
  • 98981: each additional 20 minutes, added to 98980

Setup: 98975 for initial setup and patient education is unchanged.

Sources: ASHA's summary of the 2026 code changes and the CMS 2026 therapy code list update. Check your Medicare Administrative Contractor and commercial payers for their current rates and policies.

The Pairing Rules That Trip Practices Up

The new codes are alternatives to the old ones, not add-ons. In any one 30-day period, you bill either the short-duration code or the full code for that body system, never both:

  • 98984 is not reported with 98976
  • 98985 is not reported with 98977
  • 98986 is not reported with 98978
  • 98979 is not reported with 98980 or 98981

The new device codes also have a floor: they cannot be reported for fewer than 2 days of cumulative monitoring in the 30-day period.

In practice, that means the billing decision now happens at the end of each period, based on the actual day count and the actual minutes. A patient who reaches 16 days gets the full code. A patient who stops at 9 days gets the short-duration code. A patient with 1 day of data still gets nothing.

Still Billing RTM by the 16-Day Rule?

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Why This Matters More Than It Looks

Under the old rule, every patient who fell short of 16 days was a total loss for the month. Engagement in RTM programs is rarely all-or-nothing: patients start strong, miss a week, travel, or finish their home program early. Those were exactly the months the old rule threw away.

The new codes change three things for a practice:

  • Partial months now pay. Every patient with at least 2 days of data is billable, so the revenue from a panel no longer depends on how many patients clear one threshold.
  • Short management time now pays. A month with a 12-minute check-in call used to fall below the 20-minute code. It now fits 98979.
  • Enrollment risk falls. Clinics hesitated to enroll patients who might not stay engaged for 16 days. Those patients are now worth enrolling.

The flip side is more complexity. Each patient, each month, now has a code choice to make, and the pairing rules mean a wrong choice gets denied.

What to Change in Your RTM Workflow

1. Track days and minutes per patient, per period. You need an accurate day count and minute total for every enrolled patient at the end of each 30-day period, not just a yes or no on 16 days.

2. Let the data pick the code. At period close, patients with 16 or more days go to 98976, 98977 or 98978. Patients with 2 to 15 days go to 98984, 98985 or 98986. Management time of 10 to 19 minutes goes to 98979; 20 minutes or more goes to 98980, plus 98981 for each additional 20.

3. Re-check last year's "non-billable" patients. Anyone your team has been dropping for missing 16 days is now a candidate to keep enrolled.

4. Document the interaction. 98979, like 98980, needs a real-time interaction in the month. Make sure the call or video visit is recorded where your biller can see it.

5. Confirm payer coverage. Medicare recognizes the new codes. Commercial payers adopt changes on their own schedules, so confirm before billing them.

How clinIQ Handles the 2026 Codes

clinIQ's RTM billing module counts monitoring days and management minutes for every enrolled patient automatically, then selects the right code at the end of each period: 16-day codes when the patient qualifies, the new 2–15 day codes when they don't, and 98979 or 98980 based on actual minutes. It flags the pairings that would be denied before the claim goes out, and it tells your team which patients are close to the next threshold while there's still time to act.

It sits on top of your existing EHR, so there's no new system for clinicians to learn. If your RTM program was designed around the 16-day rule, a short review of your current panel usually shows how many partial months you've been leaving unbilled.

Related Reading

Still Billing RTM by the 16-Day Rule?

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Frequently Asked Questions

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