2026 RTM CPT Codes: The Complete Guide to 98975, 98979, 98985 & All New Codes

What You Need to Know Upfront

The CMS CY 2026 Physician Fee Schedule Final Rule, released October 31, 2025 and effective January 1, 2026, introduced the most significant expansion to Remote Therapeutic Monitoring (RTM) reimbursement since the original codes were created in 2022. For the first time, CMS recognizes that meaningful patient care happens across a spectrum of engagement—not only above rigid 16-day and 20-minute thresholds.

Two new CPT codes—98985 and 98979—close the revenue gap that previously left shorter monitoring periods and sub-20-minute clinical interactions entirely uncompensated. A third new code, 98984, extends the short-period model to respiratory RTM.

If you still billing RTM the same way you did in 2025, this guide will show you exactly what you are missing—and how much it is costing you.

The Complete 2026 RTM CPT Code Reference Table

All rates below are non-facility national averages published in the CY 2026 Medicare Physician Fee Schedule Final Rule. Actual reimbursement varies by geographic region and payer contract.

What Changed from 2025 to 2026: The Structural Shift

The Pre-2026 Problem: "All-or-Nothing" Billing

Before January 1, 2026, RTM operated under binary thresholds that created a hard revenue cliff:

• Device supply: If a patient transmitted fewer than 16 days of data, you billed $0. No partial credit. No tiered option.

  
  

• Treatment management: If clinical monitoring totaled fewer than 20 minutes, you billed $0. Time below the threshold was permanently lost revenue.

This created an absurd scenario where a patient who engaged for 14 days of excellent adherence generated zero additional RTM billing, while a patient with one extra day of data unlocked $40–$47 in device supply revenue. Clinics were penalizing themselves for accepting short-episode or transitional patients.

The 2026 Fix: Tiered Thresholds Across the Engagement Spectrum

CMS addressed this by creating parallel "short-period" codes for both device supply and treatment management:

Device Supply — Before and After:

• Pre-2026: 16+ days → $40–47 | 1–15 days → $0

• 2026: 16+ days → $40–47 | 2–15 days → $40–47 | 0–1 days → $0

Treatment Management — Before and After:

• Pre-2026: 20+ min → $54 | Under 20 min → $0

• 2026: 20+ min → $54 | 10–19 min → $26 | Under 10 min → $0

The key restriction to know: New short-period codes cannot be billed alongside their existing 16+ day counterparts in the same 30-day period. You bill one or the other—never both for the same patient in the same month.

Deep Dive: CPT 98985 — The MSK Short-Period Game Changer

What It Covers

CPT 98985 reimburses the supply of an FDA-cleared RTM device monitoring the musculoskeletal (MSK) system when a patient transmits between 2 and 15 days of data within a 30-day period. It mirrors the existing CPT 98977 (16+ days, also $40) but removes the 16-day floor.

2026 Reimbursement Rate

• National average (non-facility): $40.00

• APM Qualifying rate: $40.28

• Non-APM Qualifying rate: $40.08

Eligible Conditions for 98985

CPT 98985 applies to musculoskeletal system monitoring, including:

• Post-operative orthopedic patients (ACL reconstruction, total knee replacement, rotator cuff repair, hip replacement)

  
  

• Acute and subacute MSK injuries (sprains, strains, sports injuries)

  
  

• Home exercise program (HEP) adherence tracking

  
  

• Range-of-motion rehabilitation after surgery or injury

  
  

• Chronic MSK conditions with intermittent monitoring needs

Who Can Bill 98985

CMS designates CPT 98985 as a "sometimes therapy" code in the CY 2026 Therapy Code List (MM14250). Eligible provider types include:

• Physical Therapists (PTs)

  
  

• Occupational Therapists (OTs)

  
  

• Speech-Language Pathologists (SLPs)

  
  

• Physicians, Nurse Practitioners, and Physician Assistants (under appropriate scope)

Documentation Checklist for CPT 98985

Before submitting a claim for CPT 98985, confirm every item:

☐ Patient has an eligible MSK diagnosis (ICD-10 code documented)

☐ FDA-cleared RTM device used and device type recorded in chart

☐ Minimum 2 unique calendar days of data transmitted (not 2 sessions on same day)

☐ Maximum 15 days of data transmitted (if 16+ days collected, bill 98977 instead)

☐ Patient consent for RTM obtained and documented with date

☐ Medical necessity documented: specific reason RTM supports the treatment plan

☐ Only one RTM device supply code billed per patient per 30-day period

☐ Device data dates confirmed in EHR audit trail

☐ Code not billed concurrently with CPT 98977 (same calendar month)

Critical Distinction: Two "unique days" means two separate calendar dates with transmitted data. Two monitoring sessions completed on the same calendar day count as one day.

Clinical Use Cases Where 98985 Unlocks Revenue

Post-Op Early Recovery (Days 1–14 post-surgery):

Previously, a patient discharged 10 days into monitoring generated $0 in device supply revenue. With 98985, those 10 days now generate $40.

Episodic MSK Flare Management:

Patients with recurring knee or shoulder conditions who monitor during a flare (average 8–12 days) then stop previously fell through the billing floor entirely. 98985 captures this engagement.

Transitional Care Monitoring:

Patients stepping down from inpatient rehabilitation to home who engage briefly during the transition period are now billable.

Deep Dive: CPT 98979 — The 10-Minute Management Threshold

What It Covers

CPT 98979 reimburses the first 10 to 19 minutes of RTM treatment management services per calendar month. It is the treatment management equivalent of what 98985 is for device supply—a lower-threshold entry point that captures previously uncompensated clinical work.

2026 Reimbursement Rate

• National average (non-facility): $26.00

  
  

• APM Qualifying rate: $39.97

  
  

• Non-APM Qualifying rate: $39.77

(Note: APM vs. non-APM rates differ due to conversion factor adjustments; most outpatient therapy providers fall into the non-APM group)

The Nixon Law Group confirms CPT 98979 was valued at 0.31 work RVUs — half the value of the existing first-20-minute code (98980), reflecting proportionally shorter clinical engagement time.

The Interactive Communication Requirement

To bill CPT 98979, the calendar month must include at least one real-time interactive communication between the treating provider (or qualified clinical staff) and the patient or caregiver. This means:

• Synchronous phone call (minimum brief clinical exchange — not just leaving a voicemail)

  
  

• Video visit focused on RTM data review

  
  

• Secure synchronous messaging within a patient portal if real-time

  
  

Asynchronous communication (email, regular text, app message) does not satisfy this requirement for 98979.

Documentation Checklist for CPT 98979

☐ Total clinical RTM time in calendar month: 10–19 minutes (timed and documented)

☐ At least one real-time interactive communication documented (date, time, type, duration)

☐ Summary of clinical work performed during monitoring time (data reviewed, decisions made, care plan adjustments)

☐ Active RTM device supply code also billed (98985, 98977, 98984, or 98976 — 98979 cannot be billed as a standalone)

☐ Code NOT combined with CPT 98980 or 98981 in the same calendar month

☐ Code NOT combined with CPT 99458 (RPM additional time) in same month

☐ Time documentation method: timestamps preferred (e.g., "10:05–10:18 AM: 13 minutes reviewing HEP data, adjusting protocol, and confirming exercise form via video")

What Counts as Billable Time Under 98979

Qualifying activities:

• Reviewing and interpreting RTM device data

  
  

• Assessing therapy adherence trends against clinical benchmarks

  
  

• Adjusting the treatment plan based on monitoring data

  
  

• Communicating with patient or caregiver about monitoring findings

  
  

• Coordinating with other care team members based on RTM alerts

  
  

• Documenting clinical decisions prompted by RTM data

Not qualifying:

• Time spent on billing or administrative tasks

  
  

• General patient education unrelated to RTM data

  
  

• Scheduling follow-up appointments unrelated to RTM findings

  
  

• Time spent by non-clinical staff on device enrollment

Deep Dive: CPT 98984 — Respiratory Short-Period Monitoring

What It Covers

CPT 98984 is the respiratory system equivalent of CPT 98985. It reimburses the supply of an FDA-cleared RTM device monitoring the respiratory system when 2 to 15 days of data are transmitted within a 30-day period.

2026 Reimbursement Rate

• National average (non-facility): $47.00

This matches the existing CPT 98976 (respiratory, 16+ days), maintaining rate parity between the two respiratory codes at different threshold levels — a deliberate CMS decision to prevent a revenue cliff for shorter respiratory monitoring episodes.

Eligible Conditions for 98984

• COPD exacerbation monitoring during recovery

  
  

• Post-hospitalization respiratory monitoring

  
  

• Pulmonary rehabilitation adherence tracking

  
  

• Asthma management during active symptom periods

  
  

• Short-term respiratory monitoring during transitions of care

Documentation Checklist for CPT 98984

☐ Respiratory condition diagnosis (ICD-10) documented with medical necessity

☐ FDA-cleared respiratory RTM device type and patient usage confirmed

☐ 2–15 unique calendar days of respiratory data transmitted within 30-day period

☐ Patient consent obtained and dated

☐ Code not billed concurrently with CPT 98976 (same 30-day period)

☐ Only one RTM device supply code billed per patient per period

Existing RTM Codes: Updated 2026 Rates and Key Notes

CPT 98975 — Initial Setup ($21.00)

Covers initial setup and patient education on RTM equipment. Billed once per episode, not per calendar month. Requires that 16 or more days of data are eventually collected for the episode to support billing. Cannot be billed for patients who fail to reach 16-day data threshold.

CPT 98976 — Respiratory Device Supply, 16+ Days ($47.00)

Unchanged in structure from prior years. Respiratory conditions, 16 or more days data transmitted per 30-day period. Cannot be billed alongside new CPT 98984 for the same patient in the same 30-day period.

CPT 98977 — MSK Device Supply, 16+ Days ($40.00)

Unchanged in structure. MSK conditions, 16 or more days transmitted per 30-day period. Cannot be billed alongside CPT 98985 for same patient same period.

CPT 98978 — CBT Device Supply (Variable)

Covers cognitive behavioral therapy remote monitoring device supply. Reimbursement is locality-dependent; reference the CMS Medicare Physician Fee Schedule look-up tool for your specific rate.

CPT 98980 — First 20 Minutes Treatment Management ($54.00)

Significant rate increase from 2025 (from $48 to $54 in 2026). Requires minimum one real-time interactive communication per calendar month. Cannot be billed in the same month as new CPT 98979.

CPT 98981 — Additional 20 Minutes Treatment Management ($41.00)

Each additional 20-minute block beyond the initial 98980. Add-on code only—cannot be billed without a corresponding 98980 in the same month.

Billing Rules: Critical Restrictions for 2026

These restrictions apply across all RTM codes effective January 1, 2026:

Exclusivity Rule — Device Supply Codes:

Only one device supply code per patient per 30-day period. You cannot bill both the short-period code (98984 or 98985) and the 16+ day code (98976 or 98977) for the same patient in the same period.

Exclusivity Rule — Treatment Management Codes:

Only one treatment management "first increment" code per patient per calendar month. CPT 98979 (10-19 min) and CPT 98980 (first 20 min) cannot both be billed for the same patient in the same month.

Add-On Restriction:

CPT 98981 (additional 20 min) cannot be stacked onto CPT 98979. Add-on time increments require 98980 as the base code.

RPM/RTM Mutual Exclusivity:

RPM and RTM codes cannot both be billed for the same patient in the same calendar month. Select the appropriate program based on clinical indication (physiologic vs. non-physiologic monitoring).

One Clinician Per Episode:

CPT codes 98976, 98977, 98980, and 98981 can be billed by only one clinician in a 30-day period. The first provider to submit the claim for a given patient in a given month will be reimbursed; subsequent claims for the same patient and period will be denied.

Concurrent Billing Allowed With:

RTM codes can be billed concurrently with Chronic Care Management (CCM), Transition Care Management (TCM), Behavioral Health Integration (BHI), and Principal Care Management (PCM) — but not RPM.

2025 vs. 2026 Quick Comparison

Revenue Impact: Before and After 2026

Scenario: 100-Patient PT Practice, Mixed Engagement

Pre-2026 Model:

• 60 patients reach 16+ days → bill 98977: 60 × $40 = $2,400

  
  

• 40 patients at 2–15 days → bill nothing: 40 × $0 = $0

  
  

• 80 patients with 20+ min management → bill 98980: 80 × $48 = $3,840

  
  

• 20 patients with 10–19 min management → bill nothing: 20 × $0 = $0

  
  

• Monthly Device + Management Revenue: $6,240

2026 Model (with new codes):

• 60 patients at 16+ days → bill 98977: 60 × $40 = $2,400

  
  

• 40 patients at 2–15 days → bill 98985: 40 × $40 = $1,600

  
  

• 80 patients with 20+ min management → bill 98980: 80 × $54 = $4,320

  
  

• 20 patients with 10–19 min → bill 98979: 20 × $26 = $520

  
  

• Monthly Device + Management Revenue: $8,840

Monthly revenue increase: $2,600 (+41.7%)

Annual revenue increase: $31,200

This uplift comes entirely from patients who previously generated $0 in RTM billing — with no new patient enrollment required.

How CliniQ Automates 2026 RTM Billing

Managing nine RTM CPT codes across hundreds of patients, each with different engagement levels, across multiple 30-day billing periods is beyond the practical capacity of manual tracking. CliniQ's integrated RTM platform handles the billing logic automatically:

Automatic Code Selection

CliniQ monitors each patient's real-time data transmission days and clinical time daily. On the final day of each billing period, the system automatically selects the correct CPT code:

• 0–1 days: no device supply billing triggered

  
  

• 2–15 days: 98985 (MSK) or 98984 (respiratory) flagged

  
  

• 16+ days: 98977 (MSK) or 98976 (respiratory) flagged

No manual day-counting. No missed revenue from incorrect threshold tracking.

Clinical Time Tracking

CliniQ's time-stamp documentation tool captures start and end times for every RTM clinical activity:

• 10–19 minutes logged: 98979 queued for billing

  
  

• 20+ minutes logged: 98980 queued for billing

  
  

• Additional 20-min blocks: 98981 flagged automatically

Conflict Prevention

The platform's rules engine prevents common billing errors:

• Blocks simultaneous submission of 98985 + 98977 for same patient same period

  
  

• Blocks simultaneous submission of 98979 + 98980 for same patient same month

  
  

• Flags RPM code submissions for patients already enrolled in RTM

Audit-Ready Documentation

Every billing submission is accompanied by:

• Day-by-day data transmission log (timestamps from connected device)

  
  

• Clinical time documentation with activity summaries

  
  

• Interactive communication records

  
  

• Patient consent date and signature

  
  

• Device type and FDA clearance reference

Payer-Specific Rule Application

Medicare, Medicare Advantage, and commercial payers apply RTM rules differently. CliniQ maintains payer-specific billing rules and applies them automatically based on each patient's insurance, reducing claim denial rates.

Common 2026 RTM Billing Mistakes and How to Avoid Them

Mistake 1: Billing 98985 and 98977 for the same patient in the same month

Prevention: Select one device supply code per patient per 30-day period. If the patient crosses the 16-day threshold, bill 98977. If they end below it, bill 98985. Never both.

Mistake 2: Adding 98981 to a 98979 base code

Prevention: CPT 98981 (additional 20 min) requires 98980 as the base. There is no add-on code for 98979. If management time reaches 20 minutes, use 98980 as base instead.

Mistake 3: Counting same-day sessions as multiple transmission days

Prevention: Only unique calendar dates count toward the day threshold. Patients who transmit data multiple times on the same day still get credit for one day.

Mistake 4: Skipping the real-time communication requirement for 98979

Prevention: Without at least one synchronous interaction in the calendar month, 98979 cannot be billed regardless of time documented. Asynchronous messages do not satisfy this requirement.

Mistake 5: Billing 98975 (setup) without meeting 16-day data threshold

Prevention: CPT 98975 requires the patient to eventually reach 16 days of data for the episode. Short-period patients (2–15 days) using CPT 98985 do not trigger 98975 eligibility.

Compliance and EEAT Notice

The information in this guide is based on:

• CMS CY 2026 Medicare Physician Fee Schedule Final Rule (released October 31, 2025, effective January 1, 2026)

  
  

• CMS MM14250 — Therapy Code List 2026 Annual Update

  
  

• AMA Current Procedural Terminology (CPT) Code Descriptors (2026 edition)

  
  

• Tenovi Health RTM CPT Codes 2026 (February 2026)

  
  

• Limber Health: 2026 CMS Final Rule RTM Codes (February 2026)

  
  

• Nixon Law Group: CMS Finalizes 2026 Remote Monitoring Reimbursement Updates (February 2026)

Reimbursement rates shown are national non-facility averages. Actual rates vary by geographic region, payer contract, and APM qualifying status. This guide is for informational purposes and does not constitute coding, legal, or billing advice. Always verify current rates using the CMS Medicare Physician Fee Schedule Look-Up Tool and consult a qualified billing specialist for practice-specific guidance.

Ready to Capture Every Dollar of 2026 RTM Revenue?

CliniQ's automated billing engine selects the correct code, tracks the correct thresholds, and generates audit-ready documentation — across every patient, every location, every month.

Stop leaving 2-15 day patients unbilled. Start capturing your full RTM revenue today.

Email: info@cliniqhealthcare.com

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