The 2026 RTM Update: New 2–15 Day Supply Codes (98984/98985), a New 10-Minute Management Code (98979), and “Sometimes Therapy” Billing Rules

Overview

Remote Therapeutic Monitoring (RTM) is a Medicare-covered code family intended to support monitoring of therapeutic adherence/response and related interventions using device-enabled data access/transmission plus treatment management.

For CY 2026, CMS finalized three operational changes in the official therapy-code update (CR 14250):

1. New RTM supply codes for short-duration monitoring (2–15 days in a 30-day period): 98984 (respiratory) and 98985 (musculoskeletal).
2. A new RTM treatment-management code for the first 10 minutes in a calendar month: 98979 (requires at least one real-time interactive communication with the patient/caregiver during the calendar month).
3. Revised descriptors for existing RTM supply codes to explicitly represent 16–30 days in a 30-day period: 98976 (respiratory) and 98977 (musculoskeletal).

CMS also designated the new RTM codes as “sometimes therapy” beginning January 1, 2026 and clarified when therapy plans of care and therapy modifiers are required.

1. Key Takeaway in One Sentence

Starting January 1, 2026, Medicare RTM device-supply billing is explicitly tiered into 2–15 day codes (98984/98985) and 16–30 day codes (98976/98977), RTM management adds a first-10-minute monthly code (98979), and all of these remain “sometimes therapy,” so compliance hinges on correct time-window accounting, plan-of-care determination, and modifier/setting logic (GP/GO/GN; CQ/CO where applicable; PFS vs TOB 13X OPPS routing).

3. Core Rule Explanation

3.1 The supply codes are now explicitly duration-bound

CMS created two new RTM device-supply codes for the 2–15 day tier and revised the descriptors of the existing supply codes to make clear they are the 16–30 day tier within a 30-day period. Operationally, this matters because many RTM implementations previously behaved as if supply codes were “monthly” in a loose sense. CMS is removing ambiguity by explicitly tying each supply code to a day-count band within a defined 30-day period.

3.2 The new management entry code is calendar-month based and has an interaction requirement

CMS added 98979 as the first-step management code: physician/other qualified health care professional time in a calendar month, requiring at least one real-time interactive communication with the patient/caregiver during that calendar month, for the first 10 minutes. Supply codes are described in a 30-day period framework; 98979 is explicitly a calendar month framework and includes an explicit interaction requirement. CMS does not provide a unifying instruction that forces supply periods to be calendar months, so operational models must keep these time concepts separate and auditable.

3.3 “Sometimes therapy” is a claims-processing fork, not a label

The original five RTM codes (98975, 98976, 98977, 98980, 98981) were designated sometimes therapy in CY 2022. CMS designates 98979, 98984, and 98985 as sometimes therapy beginning January 1, 2026. Claims from physicians and NPPs for sometimes-therapy codes may be processed without therapy modifiers when they are not therapy services but must still be defensible as physician/NPP services. When submitted under therapist specialty codes, contractors treat them as therapy and return claims lacking therapy modifiers. CMS states RTM services furnished by therapists are always provided under a therapy plan of care and require GP, GO, or GN modifiers.

3.4 Therapy plan-of-care requirements depend on both who furnishes RTM and what the RTM is “about”

Therapists must always provide RTM under a therapy plan of care. Physicians, PAs, NPs, and CNSs provide RTM under a therapy plan of care when the RTM directly relates to the musculoskeletal device codes (98977 and 98985) and is specific to therapy services. Otherwise, RTM may be furnished appropriately outside a therapy plan of care with the sometimes-therapy designation. The operational takeaway: plan-of-care determination must be explicit and tied to modifiers and documentation.

3.5 Assistant modifiers apply only to certain RTM codes

CMS explicitly limits the de minimis / 10% assistant policy (and therefore CQ/CO usage) to 98975, 98979, 98980, and 98981. CMS does not include the RTM device-supply codes in that assistant-modifier subset. Applying CQ/CO to supply codes creates incorrect claims.

3.6 Payment routing depends on setting and claim type

RTM supply codes designated as sometimes therapy (98975, 98976, 98977, 98984, 98985) are paid under the Physician Fee Schedule except in the outpatient hospital setting for type of bill 13X, where they are paid under OPPS. RTM treatment-management codes (98979, 98980, 98981) are paid under the PFS when furnished under therapy plans of care by therapists and their supervised PTAs/OTAs for bill type 13X. Setting-aware routing is required to avoid misaligned payment expectations.

5. Why These Patterns Become Non-Compliant

• Unit-of-service integrity: Billing 2–15 day and 16–30 day supply codes together in one period treats mutually exclusive descriptors as additive units.
• Claims classification integrity: Therapy versus non-therapy status must align with modifiers and documentation; inconsistency invites denials and repayments.
• Assistant modifier integrity: CQ/CO outside 98975/98979/98980/98981 is incorrect coding per CMS instruction.
• Setting and payment-system integrity: PFS versus OPPS routing is explicit for TOB 13X; ignoring it creates systematic errors.

7. Forward-Looking Policy Context

CR 14250 is an implementation-level update inside broader CY 2026 policy direction:

• CMS finalized using “auditable, routinely updated hospital data” (OPPS) to inform relative rate setting for some technical services paid under PFS, including some remote monitoring services.
• CMS finalized a permanent definition of direct supervision allowing real-time audio/video telecommunications (not audio-only) for applicable services required to be performed under direct supervision.
• RTM’s evolution fits a trend: expanding remote-care flexibility while tightening definitional precision on time windows, setting routing, and therapy-versus-medical classification.

9. Planning Checklist

• Update RTM supply logic to support both tiers: 98984/98985 for 2–15 days; 98976/98977 for 16–30 days.
• Implement guardrails that prevent stacking short- and long-duration supply codes for the same monitoring episode within the same measurement period.
• Separate “supply period accounting” from “calendar month management accounting” and store both with reproducible evidence.
• Encode plan-of-care classification as an explicit data element tied to modifier selection (GP/GO/GN for therapy; conditional application for physicians/NPPs aligned to CMS guidance).
• Restrict CQ/CO to RTM codes CMS identifies as subject to the de minimis policy (98975, 98979, 98980, 98981).
• Implement setting-aware billing for TOB 13X versus professional claims for RTM supply and management payment routing.

11. How FairPath Enforces This at Scale

13. References

• CMS MLN Matters MM14250: “Therapy Code List: 2026 Annual Update” (RTM code additions, descriptor revisions, sometimes-therapy designation, plan-of-care and modifier clarifications, payment routing).
• CMS Manual System Transmittal R13431CP / CR 14250: “2026 Annual Update to the Therapy Code List” (official instruction, effective/implementation dates, RTM code text and payment routing statements).
• CMS Medicare Claims Processing Manual, Pub. 100-04, Chapter 5 (therapy modifier requirements; sometimes-therapy processing; documentation expectations when billed without modifiers).
• CMS Fact Sheet: CY 2026 Medicare Physician Fee Schedule Final Rule (CMS-1832-F) (remote monitoring rate-setting context; permanent virtual direct supervision definition).