RTM CPT Codes in 2026 Explained: Detailed Guide
- ClinIQ Healthcare
- 3 days ago
- 10 min read
Introduction: Why 2026 RTM Codes Matter Now
Remote Therapeutic Monitoring (RTM) is rapidly transforming how healthcare providers deliver continuous care while optimizing reimbursement. The 2026 marks a pivotal year for healthcare organizations seeking to expand remote care services with greater billing flexibility and improved financial sustainability.
The Centers for Medicare & Medicaid Services (CMS) has introduced significant updates to Remote Therapeutic Monitoring CPT codes, specifically focusing on codes 98979, 98984, and 98985. These updates address a critical pain point from earlier RTM models: rigid billing thresholds that prevented providers from capturing revenue for meaningful patient engagement below historical minimums.
This comprehensive guide breaks down the new RTM CPT codes for 2026, explaining how they work, who is eligible to bill them, and what providers must do to remain compliant while maximizing reimbursement opportunities. By understanding these updates, healthcare organizations can confidently integrate RTM into their clinical workflows, strengthen remote care programs, and align RTM services with sustainable revenue strategies.
Understanding Remote Therapeutic Monitoring (RTM)
What Is RTM?
Remote Therapeutic Monitoring (RTM) allows healthcare providers to collect, transmit, and review non-physiologic patient data related to therapy adherence and treatment response using qualifying medical devices. This distinguishes RTM from Remote Patient Monitoring (RPM), which tracks physiologic metrics such as heart rate, blood pressure, or oxygen saturation.
RTM data collection focuses on behavioral and functional indicators that reflect patient engagement with therapeutic interventions.
Current RTM Condition Categories
RTM services currently apply to:
Musculoskeletal (MSK) conditions: Post-operative orthopedic patients, physical therapy cases, chiropractic care
Respiratory conditions: COPD management, pulmonary rehabilitation, asthma monitoring
Cognitive-behavioral domains: Emerging applications in behavioral health monitoring
Common Types of RTM Data
RTM data includes:
Therapy adherence and activity tracking
Range-of-motion and movement measurements
Functional status and pain levels
Inhaler usage patterns and respiratory symptom reporting
Home exercise program compliance
Physical activity engagement metrics
From a clinical perspective, RTM enables continuous care management without the need for frequent in-office visits—particularly valuable for physical therapy, pulmonology, orthopedic surgery, and primary care practices.
Why CMS Redesigned RTM Coding in 2026
The Problem with Legacy RTM Billing
Prior to 2026, RTM reimbursement operated under rigid thresholds that created "all-or-nothing" billing scenarios:
Legacy Requirements:
Minimum 16+ days of patient data collection per calendar month
Minimum 20 minutes of provider management time per calendar month
No reimbursement for partial or short-term patient engagement
Real-World Impact:This inflexible model meant providers lost reimbursement when patients:
Participated in shorter monitoring periods (2-15 days)
Needed brief clinical follow-ups (10-19 minutes)
Engaged less consistently due to life circumstances
Required post-operative monitoring for limited periods
Despite meaningful clinical engagement and clear therapeutic benefit, providers could not capture revenue. This created a significant revenue barrier for expanding RTM programs.
CMS's Response: The 2026 Updates
CMS responded to provider feedback and expanded RTM adoption by redesigning the coding framework. The new structure addresses critical gaps in earlier models by introducing tiered CPT codes that better reflect real-world clinical practice.
Key CMS Objectives:
Better align RTM reimbursement with actual clinical usage patterns
Minimize revenue loss when patients engage below historical thresholds
Support broader RTM adoption across multiple medical specialties
Acknowledge that partial RTM participation remains clinically valuable
Create sustainable, outcomes-driven remote care models
CPT 98979: First 10 Minutes of RTM Clinical Monitoring
Code Definition and Purpose
CPT 98979 reimburses providers for the first 10 minutes per calendar month spent on Remote Therapeutic Monitoring clinical monitoring and management services.
This time-based code captures the clinical work involved in evaluating RTM data and using those insights to guide patient care decisions—even when engagement is brief.
Activities Eligible Under CPT 98979
RTM clinical monitoring activities covered by CPT 98979 include:
Reviewing and interpreting RTM data from patient devices
Assessing therapy adherence and tracking patient progress
Adjusting treatment plans based on data trends
Making clinical decisions related to RTM services
Communicating with patients or caregivers about RTM findings
Coordinating care across clinical team members
Critical Distinction: CPT 98979 is time-based, not data-based. Reimbursement depends on documented clinical time spent on meaningful monitoring activities—not on the volume of data collected from patient devices.
Billing Requirements for CPT 98979
To bill CPT 98979 correctly, providers must meet these specific requirements:
Time Documentation Example:"10 minutes of clinical monitoring: 6 minutes reviewing device data showing 87% exercise adherence, 4 minutes via phone call discussing pain reduction and adjusting HEP [Home Exercise Program]."
When CPT 98979 Stacks With Other Codes
CPT 98979 serves as the foundational clinical management component of an RTM program and pairs with:
CPT 98984 (2-15 days of RTM data collection)
CPT 98985 (16+ days of RTM data collection)
Providers cannot bill CPT 98979 with legacy codes CPT 98980 or 98981 in the same calendar month.
CPT 98984 vs CPT 98985: RTM Data Collection Codes Explained
The Tiered Data Collection Model
One of the most impactful 2026 RTM updates is the introduction of tiered data collection codes, which better reflect varying levels of patient engagement and device usage in real-world clinical practice.
This represents a fundamental shift: CMS now recognizes that patient participation exists on a spectrum, and meaningful clinical work occurs at multiple engagement levels.
CPT 98984: RTM Data Collection for 2–15 Days
Code Purpose:CPT 98984 reimburses RTM data transmission when patients engage for 2 to 15 days per calendar month.
Eligibility Requirements:
Applicable to musculoskeletal (MSK) conditions
Applicable to respiratory conditions
Requires use of a qualifying RTM medical device
Billed once per calendar month
Minimum 2 days of data transmission (vs. previous 16-day minimum)
Clinical Use Cases for CPT 98984:
Post-operative patients in early recovery phase (2-4 weeks)
Episodic or acute musculoskeletal conditions
Respiratory patients with temporary monitoring needs
New patient enrollment periods with variable engagement
Patients transitioning from higher-intensity to maintenance monitoring
Patients with barriers to consistent daily engagement (work schedule, transportation, etc.)
Financial Impact:CPT 98984 enables revenue capture for a patient population previously excluded from RTM billing. A clinic with 50 post-operative patients engaging for 10 days (vs. previous 16+ day minimum) can now capture reimbursement for all 50, rather than 0.
CPT 98985: RTM Data Collection for 16 or More Days
Code Purpose:CPT 98985 covers RTM data transmission for patients who engage for 16 or more days per calendar month—maintaining the original CMS threshold for full-engagement monitoring.
Eligibility Requirements:
Shares all condition and device requirements with CPT 98984
Reflects sustained patient engagement
Supports full participation in structured RTM programs
Billed once per calendar month
Clinical Use Cases for CPT 98985:
Chronic disease management (COPD, long-term rehabilitation)
Post-operative patients extending into mid-recovery phase
Patients with high adherence to prescribed monitoring
Multi-week physical rehabilitation programs
Comprehensive respiratory monitoring programs
Payment Note:CMS confirmed that CPT 98985 receives the same reimbursement rate as CPT 98984, despite higher engagement. This ensures that engaging patients at either threshold generates proportional revenue for providers.
Why Tiered RTM Codes Matter: The Revenue Impact
Historical Problem (Pre-2026):
Patient engaged for 10 days: $0 reimbursement (below 16-day minimum)
Patient engaged for 16 days: $50 reimbursement
Result: Revenue cliff penalizes shorter engagement
New Model (2026+):
Patient engaged for 10 days: $40 reimbursement (CPT 98984)
Patient engaged for 16 days: $50 reimbursement (CPT 98985)
Result: Revenue captured across engagement spectrum
For multi-location clinic networks, this change is transformative. A 10-location PT clinic with 500 patients averaging 12 days of engagement could now capture an additional $200,000-$300,000 annually compared to the pre-2026 model.
RTM Billing and Documentation Requirements in 2026
Critical Documentation Elements
Accurate and thorough documentation is essential for RTM reimbursement compliance and long-term audit protection. Documentation must support medical necessity, demonstrate clinical decision-making, and show compliance with CMS and payer-specific billing requirements.
Required Documentation Elements:
Best Practices for RTM Documentation and Compliance
To reduce audit risk and ensure consistent reimbursement, providers should implement:
1. Monthly RTM Summaries
Clearly outline services performed each calendar month
Document patient engagement metrics (days, adherence %, clinical alerts)
Include clinical monitoring time with specific activities
2. Separate RTM from Clinical Time
Distinguish between RTM data collection (CPT 98984/98985) and clinical monitoring (CPT 98979)
Use timestamps to document clinical time precisely
Avoid combining unrelated clinical activities into RTM time
3. Avoid Templated or Repetitive Notes
Audit programs flag identical notes across billing periods
Document specific patient-level findings and actions
Include unique clinical details for each patient
4. Device and Compliance Verification
Confirm qualifying device used (meets CMS criteria)
Document patient device usage patterns
Note any barriers to engagement and interventions
5. Payer-Specific Requirements
Medicare offers baseline RTM guidance, but commercial payers may apply stricter requirements
Verify coverage policies with each payer before enrollment
Document payer-specific compliance measures
6. Integration With EHR
Embed RTM documentation into patient's electronic health record
Ensure clinical team sees RTM data in existing workflows
Link RTM alerts to care coordination activities
Who Can Bill RTM Codes 98979, 98984, and 98985?
Eligible Provider Types
Remote Therapeutic Monitoring CPT codes are available to a broader range of providers than Remote Patient Monitoring (RPM). However, eligibility depends on scope of practice, state regulations, and payer-specific policies.
Commonly Eligible Provider Types for RTM:
Supervision and Incident-To Billing
When delivering RTM services, providers should be aware of supervision requirements:
Direct Provider Billing:
Qualified health care professionals bill RTM codes directly
Full reimbursement rate applies
Qualified Clinical Staff Supervision:
Qualified clinical staff (e.g., therapy assistants, medical assistants) may assist with RTM services under appropriate provider supervision
Incident-to billing rules may apply, depending on care setting and payer guidelines
Requirements vary by state and payer
Key Consideration:RTM billing rules vary significantly by payer. Providers should verify state regulations and payer-specific requirements before implementing RTM services. Confirming eligibility in advance prevents claim denials and supports compliant RTM program expansion.
RTM vs RPM in 2026: Critical Distinctions for Billing
Why the Distinction Matters
Although often grouped together, Remote Therapeutic Monitoring (RTM) and Remote Patient Monitoring (RPM) serve distinct clinical and billing purposes. Understanding these differences helps providers select the appropriate remote care model and avoid billing errors.
Key Differences
When to Use RTM vs RPM
RTM is Ideal For:
Post-operative orthopedic patients (ACL repair, rotator cuff surgery)
Physical therapy programs (any MSK condition)
Pulmonary rehabilitation (COPD, asthma)
Behavioral therapy monitoring (emerging application)
Practices seeking lower-barrier entry to remote care
RPM is Ideal For:
Chronic disease management (diabetes, hypertension)
Patients requiring vital sign monitoring
High-risk populations with complex medical histories
Cardiology and endocrinology practices
Strategic Insight:For many practices, RTM offers a lower-barrier entry point into reimbursable remote care than RPM. RTM requires less complex infrastructure, enables faster staff training, and generates meaningful clinical data with minimal device overhead. This makes RTM an attractive option for expanding remote services without the complexity of traditional RPM workflows.
Common RTM Billing Mistakes to Avoid in 2026
Frequent Billing Errors (and How to Prevent Them)
Even experienced practices make preventable RTM billing errors that compromise reimbursement and create compliance risk. Understanding these pitfalls helps providers maintain accurate billing and reduce audit exposure.
Error 1: Billing RTM Data Codes Without Meeting Minimum Day Thresholds
Mistake: Submitting CPT 98984 when patient only engaged for 1 day
Prevention: Verify minimum 2 days of data collection before billing CPT 98984; verify 16+ days for CPT 98985
Audit Risk: High—claim automatically denies if threshold not met
Error 2: Confusing Time-Based and Data-Based Codes
Mistake: Billing CPT 98979 (10 min clinical time) as equivalent to data collection codes
Prevention: Remember 98979 is time-based (requires clinical monitoring); 98984/98985 are data-based (requires transmission days)
Documentation: Clearly separate clinical time documentation from RTM device data in patient record
Error 3: Failing to Document Patient Consent
Mistake: Enrolling patient in RTM without documented agreement
Prevention: Obtain signed consent form before RTM enrollment; include in patient chart
Audit Risk: Claim denial + potential compliance violation
Error 4: Billing RTM Without Clear Medical Necessity
Mistake: Enrolling patients in RTM without documented clinical indication
Prevention: Document specific diagnosis, condition severity, and why RTM supports treatment plan
Example: "Patient 4 days post-op ACL repair; RTM monitoring ordered to track HEP adherence and detect post-op complications during acute phase (2-4 weeks)"
Error 5: Assuming Medicare Rules Apply to All Payers
Mistake: Applying Medicare RTM requirements universally across commercial payers
Prevention: Verify payer-specific RTM policies before enrollment
Impact: Commercial payers may have stricter requirements, higher day thresholds, or different eligible conditions
Error 6: Billing Multiple RTM Codes in Same Calendar Month
Mistake: Submitting both CPT 98984 (2-15 days) and CPT 98985 (16+ days) for same patient same month
Prevention: Select one data collection code per calendar month per patient
Result: Duplicate billing triggers automatic denial
Preventing Errors: Pre-Billing Verification Checklist
Before submitting any RTM claim:
✓ Verify patient meets minimum engagement threshold (2+ days)
✓ Confirm medical necessity documented in chart
✓ Check patient consent is signed and dated
✓ Verify device type is CMS-qualified RTM device
✓ Confirm clinical time (if billing 98979) is documented with timestamp
✓ Validate payer coverage and RTM eligibility
✓ Ensure only one RTM data code billed per calendar month per patient
How Providers Should Prepare for RTM in 2026
Strategic Preparation for RTM Success
To fully leverage the new Remote Therapeutic Monitoring CPT codes in 2026, practices should take a proactive and structured approach to implementation. Early planning ensures compliance, streamlines workflows, and maximizes reimbursement opportunities.
Implementation Roadmap
Phase 1: Patient Population Assessment (Weeks 1-2)
Identify RTM-eligible patient populations in current patient base
Prioritize musculoskeletal and respiratory patient cohorts
Calculate projected RTM patient volume and revenue potential
Determine which providers will lead RTM implementation
Phase 2: Technology and Vendor Evaluation (Weeks 2-4)
Research RTM devices and vendor platforms
Verify devices meet CMS RTM requirements
Evaluate EHR integration capabilities (critical for workflow efficiency)
Confirm vendor handles compliance documentation
Request pilot deployment if available
Phase 3: Staff Training and Workflow Development (Weeks 4-6)
Train clinical staff on new RTM CPT codes (98979, 98984, 98985)
Develop documentation templates aligned with CMS requirements
Create RTM enrollment workflow (patient consent, device setup, baseline data)
Establish billing and coding protocols specific to RTM
Train billing staff on claim submission and payer verification
Phase 4: Clinical Workflow Integration (Weeks 6-8)
Map RTM data into existing clinical workflows
Define roles: who reviews RTM data? Who responds to alerts?
Establish communication protocols (patient outreach, escalation procedures)
Create decision trees for clinical actions based on RTM data
Test workflows with pilot patient cohort
Phase 5: Payer Verification and Coverage Setup (Weeks 8-10)
Verify RTM coverage with Medicare, Medicare Advantage, and commercial payers
Document payer-specific requirements and thresholds
Set up billing workflows aligned with payer requirements
Establish appeal procedures if claims are denied
Monitor payer policy updates as 2026 progresses
Phase 6: Pilot Launch and Optimization (Weeks 10-12)
Launch RTM pilot with 20-50 patients
Monitor enrollment rates, engagement, and billing accuracy
Track patient outcomes and adherence metrics
Identify workflow bottlenecks and optimization opportunities
Document lessons learned before full rollout
Phase 7: Full Scale Rollout (Month 4+)
Expand RTM program to full eligible patient population
Automate RTM enrollment where possible
Monitor and report RTM program metrics (volume, revenue, outcomes)
Continuously optimize based on pilot learnings and payer feedback
Conclusion: RTM as Strategic Infrastructure in 2026
The expansion of RTM CPT codes 98979, 98984, and 98985 reflects CMS's long-term commitment to remote, value-based care models. With new billing flexibility and lower thresholds, providers now have greater opportunity to deliver meaningful therapeutic monitoring while ensuring appropriate reimbursement.
For healthcare organizations—from single physical therapy clinics to multi-location orthopedic networks to pulmonary rehabilitation centers—RTM represents a foundational investment in scalable, outcomes-driven care delivery.
The providers that understand RTM billing rules, maintain accurate documentation, and align clinical and billing workflows early will gain clear advantages, both clinically and financially.
The time to implement RTM is now. Early-moving providers will establish market differentiation, build sustainable RTM programs, and position themselves for long-term success as remote care continues to evolve in 2026 and beyond.
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