Remote Therapeutic Monitoring, Done Right.

A clear, compliant way for specialty practices to monitor therapy progress between visits--and get paid for the work. FairPath helps you operationalize Remote Therapeutic Monitoring (RTM) across musculoskeletal, respiratory, and behavioral health programs.

RTM is built for non-physiologic, therapeutic data--adherence, pain and function scores, inhaler use, CBT homework, post-op recovery--not just vitals. Data can be self-reported inside an FDA-defined medical device, including qualified software as a medical device (SaMD), then used to support RTM billing.

Calculate Your RTM Revenue RTM Essentials ↓

Manually juggling 98975/98976/98977, CBT-specific 98978, and the 98980/98981 time rules risks denials.

Let FairPath automate your RTM workflows and claim checks.

RTM vs. RPM: Different Signals, Different Rules

RTM focuses on therapy--musculoskeletal rehab, respiratory adherence, and CBT/digital therapeutics. It uses non-physiologic data, often self-reported, to manage adherence and response between visits. RPM, by contrast, requires automatically collected physiologic data (e.g., blood pressure, SpO₂, weight) from a connected medical device. You cannot bill RTM and RPM together for the same patient in the same 30-day period.

Built for Specialists

RTM is the remote-care pathway designed for Physical Therapists, Occupational Therapists, Orthopedists, Pulmonologists, pain clinics, and CBT-focused behavioral health teams.

Therapeutic, Non-Physiologic Data

Where RPM tracks vital signs, RTM tracks therapy adherence, symptom and function scores, inhaler use, and digital CBT engagement--captured through an RTM-eligible app or device.

Visibility Between Visits

RTM gives you structured visibility into what patients are actually doing between encounters, and creates a compliant path to be reimbursed for that work instead of absorbing it as uncompensated care.

RTM CBT device supply (CPT 98978) is contractor-priced by Medicare; coverage and rates for CBT-focused RTM vary by MAC and commercial payer.

RTM Data of Record: What Counts and What Does Not

RTM can include subjective patient inputs (pain scores, adherence logs, CBT homework), but the data must be captured inside an RTM eligible device or SaMD with timestamped records you can export.
SMS and voice prompts are fine as nudges, but texts or emails are not the medical device record. The medical device record is the app or device system that stores the data.
Software only RTM: perform SaMD diligence (device identification, FDA definition alignment, BAA coverage, exportable day counts, and audit retention).
CBT device codes are contractor priced and payer dependent; require explicit coverage verification before forecasting.

The 16 Day Rule in RTM, and What 2026 Actually Changes

Device supply codes in the 16 to 30 day tier require 16 days of recorded data in the 30 day period.
2026 adds an explicit 2 to 15 day tier (98984 to 98986). The 16 day threshold does not disappear; it becomes a tier selection problem.
Management codes do not require 16 days, but operators should treat months with very low data as medically fragile and document why management was needed.

RTM Codes and Requirements: 2025 Baseline

Setup & Education · 98975

One time per episode of care. Covers initial configuration and patient education. Operational rule: bill only after the patient has generated at least knowable, auditable device days for the episode. In Medicare baseline guidance, treat 98975 like other RTM device family requirements and do not bill it until you can produce a 16 day usage report for the monitoring period. Practical operations: hold 98975 until day 17 so you are not forced to rebill or retract if the patient stalls at day 15.

Device Supply · 98976–98978

Monthly device supply. For the full reimbursement rate, 98976 (respiratory) and 98977 (MSK) require 16+ days of data. However, new "rescue codes" (98984–98986) now allow you to bill for 2–15 days of monitoring if the full threshold is missed.

Treatment Management · 98980–98981

Monthly RTM treatment-management time. 98980 covers the first 20+ minutes in a calendar month (with at least one real-time interaction), and 98981 covers each additional 20 minutes. The 16-day device rule does not apply to these management codes, but you still need legitimate RTM data and documented interaction.

Category	Code(s)	Threshold	Hard requirement	Notes (what auditors check)
Setup and education	98975	Once per episode	Hold until device day evidence is present (baseline: treat as 16 day aligned)	Episode definition, device day audit trail, and documented patient education.
Device supply respiratory	98976 (16 to 30 days), 98984 (2 to 15 days, 2026)	16–30 days or 2–15 days	Recorded device data days in the 30-day period	Day counts, device identification, and month selection logic.
Device supply MSK	98977 (16 to 30 days), 98985 (2 to 15 days, 2026)	16–30 days or 2–15 days	Recorded device data days in the 30-day period	Day counts, device identification, and coverage alignment.
Device supply CBT	98978 (16 to 30 days, contractor priced), 98986 (2 to 15 days, 2026 contractor priced)	16–30 days or 2–15 days	Recorded device data days in the 30-day period	SaMD qualification, contractor pricing, and payer coverage checks.
Management entry	98979 (10 to 19 minutes, 2026, requires one real time interaction, cannot be billed with 98980)	10–19 minutes	One real-time interaction and documented time	Time logs, interaction mode, and mutual exclusion with 98980.
Management standard	98980 (20 minutes, requires one real time interaction)	20 minutes	One real-time interaction and documented time	Time logs, interaction mode, and data linkage.
Management add on	98981 (each additional 20 minutes, requires documentation of incremental time)	Each additional 20 minutes	Incremental time documentation and additional interactive contact	Incremental time totals and evidence of additional interactive contact.

RTM cannot be billed in the same period as RPM for the same patient. It can be billed alongside CCM/PCM/TCM/BHI/APCM when time and work are not double-counted.

What Changes in 2026: Shorter Episodes, New Time Buckets

Beginning January 1, 2026, RTM becomes more flexible. CPT and CMS introduce new codes for shorter monitoring periods and shorter management time, instead of a single “16 days or nothing” device threshold and a single 20-minute management bucket.

2–15 Day Device Supply · 98984–98986

New codes for shorter episodes of respiratory, musculoskeletal, and CBT RTM. Financial Insight: Pricing is payer and locality dependent; do not assume parity without confirming the current fee schedule.

New 10–19 Minute Management · 98979

98979 covers 10–19 minutes of RTM management (with one live interaction). Note: You cannot bill 98979 and 98980 in the same month. Use 98979 for "maintenance" patients who require brief check-ins, and 98980 for patients requiring standard 20+ minute review.

In 2026, 98976/98977/98978 are updated to represent 16–30 days of monitoring; 98984/98985/98986 represent 2–15 days. The 16-day requirement does not “go away”--it is joined by a short-duration option.

Sometimes Therapy: Modifier, Plan of Care, and Setting Rules

RTM is “sometimes therapy.” If furnished as therapy (PT, OT, SLP), it is treated as therapy for billing purposes and requires the appropriate therapy modifier (GP, GO, GN) and an active therapy plan of care with required certifications.
Physician and NP/PA furnished RTM can still become “therapy coded” when the underlying service is therapy specific (musculoskeletal rehab workflows). Document plan of care linkage rather than trying to route around therapy rules.
Assistant involvement rules (therapy settings): follow the 10% de minimis concept and the CQ/CO modifier and payment reduction when applicable. Device supply codes are practice expense only and are not impacted the same way as professional time codes.
Operational gate: if your practice cannot reliably determine whether an RTM episode is “therapy,” you will miscode modifiers and invite denials. Build a routing rule up front.

Who Can Bill RTM and Who Can Do the Work

Physician, NP, PA can bill RTM and can delegate many tasks to clinical staff under general supervision (post 2023 policy change). The billing provider remains accountable and needs oversight notes.
PT, OT, SLP can bill RTM within scope, but therapist billing does not use incident to the same way physician practices do. Keep the rule simple: therapists should assume the therapist and therapy team are the rendering entity and must follow therapy supervision and assistant rules.
One practitioner per patient per 30 day period: make it a hard operational rule to avoid duplicate billing and denials.

How FairPath Helps You Run In-House RTM

Step 1: Capture RTM-Eligible Data

FairPath and our agents prompt patients to record therapy adherence, symptom scores, and other RTM data inside a medical-device-qualified app. Prompts may be delivered by SMS or voice, but the clinical system of record is an RTM-eligible device or SaMD, maintaining alignment with RTM device rules.

Step 2: Accelerate Cash Flow

We count RTM days and treatment management minutes in the background. For 2026, the big operational unlock is that short duration device supply codes (98984 to 98986) let you bill a defensible device month even when the patient does not reach 16 days. Separately, we track when the episode is mature enough to bill setup and education based on your documented device day evidence and payer rules.

Step 3: Produce Clean, Defensible Claims

Our compliance engine encodes RTM-specific rules: day thresholds for device codes, one-practitioner-per-period limits, incident-to rules for physician practices, therapy plan-of-care and de minimis rules for PT/OT/SLP teams, and coordination with RPM and care-management codes to prevent double-counted time. The result is a clear, exportable audit trail for every RTM claim.

Domain-Specific RTM: How it Looks in Practice

RTM isn't one-size-fits-all. The data captured must be therapeutic and specific to the condition treated.

Musculoskeletal

Target: Post-op joint replacement, chronic back pain.
Data Signals: Range of motion (ROM), exercise repetition counts, and pain scores.
Goal: Identify under-performance due to pain or over-activity that risks injury.

Respiratory

Target: Asthma, COPD.
Data Signals: Inhaler usage frequency (adherence), rescue inhaler spikes, and environmental triggers.
Goal: Detect "rescue" overuse early to prevent exacerbations and ER visits.

Cognitive (CBT)

Target: Depression, Anxiety, Insomnia.
Data Signals: Homework completion, mood scoring, sleep logs.
Compliance Alert: Not all health apps qualify. To bill 98978 (or 98986), the software must meet the FDA definition of a medical device (SaMD). Generic "wellness" apps do not qualify.

The Audit Survival Guide

Avoid the common pitfalls that trigger OIG scrutiny.

The Order: Must explicitly state why RTM is medically necessary (e.g., "High fall risk; RTM needed to monitor gait stability").
Device Verification: Document the specific device name and its FDA status.

Detailed Time Logs: "Spent time reviewing" is insufficient. Use "12 mins data review + 10 mins patient call".
Interaction Content: Document the substance of the call (e.g., "Discussed poor inhaler technique observed in data").

Common Denials and the Fix

Not covered service: Run a coverage check workflow and communicate patient responsibility before enrollment.
No prior auth (MA and commercial): Add a “verify auth” gate before enrollment.
Insufficient days or insufficient minutes: No appeal if thresholds are truly missed; fix with gating before claim creation.

Missing therapy modifiers or missing plan of care: Apply the correct modifier and attach plan of care documentation.
Provider eligibility mismatch: Correct taxonomy, modifier, and payer system edits.
Duplicate billing (RTM plus RPM, or two RTM billers): Assign ownership per patient per period.

The RTM Financials: A New, Predictable Revenue Line

Use the calculator for current, payer-specific estimates. As a reference point, 2025 national, non-facility Medicare payments are approximately in the high-teens to low-$20s for 98975, low-to-mid-$40s for 98976/98977, around $50 for 98980, and around $40 for 98981. Local Medicare Administrative Contractors and commercial plans set their own rates, and 98978 (CBT device supply) is contractor-priced.

Effective January 1, 2026: RTM adds device codes for 2–15 days of monitoring (98984–98986) and a new 10–19 minute management code (98979), alongside the existing 16–30 day and 20+ minute pathways. Practices should confirm MAC and payer adoption; FairPath’s internal rules and calculators are kept aligned with the current CMS fee schedule.

Stop Guessing. See Your RTM Potential in Seconds.

Enter your panel size and program mix to see estimated monthly revenue from RTM, alongside APCM, RPM, and CCM--using up-to-date Medicare assumptions.

Active RTM Patients

100 patients

Typical RTM Codes

98975 · 98977 · 98980

Estimated Monthly Revenue

$9,000 based on current RTM reimbursement assumptions for 2025 Medicare non-facility rates.

Values shown are illustrative and based on national Medicare averages; your locality, payer contracts, and program design will affect actual results.

Calculate Your Revenue

RTM Questions, Answered

1

Can PTs, OTs, and SLPs bill RTM?

Yes. RTM is “sometimes therapy.” Physical Therapists, Occupational Therapists, and Speech-Language Pathologists can bill RTM within their scope when it is delivered under a therapy plan of care. Physicians and other qualified health care professionals can also bill RTM. Use GP/GO/GN modifiers when RTM is provided as therapy under a plan of care, and follow your MAC’s supervision and documentation rules for the setting.

2

Does RTM require a medical device or can I use any app?

RTM requires that data be captured and transmitted by a medical device as defined by the FDA. That can include software as a medical device (SaMD), such as a qualified RTM app, but generic wellness apps or informal text messages are not sufficient. You can use SMS or voice to nudge patients, but the data of record must be entered into, or generated by, an RTM-eligible device or app that your billing team can name and document.

3

Do I always need 16 days of data in a 30-day period?

For 2025 device-supply codes 98976/98977 (and 98978 where covered), you generally need at least 16 days of RTM data in a 30-day period to bill. Management codes 98980/98981 do not have a 16-day requirement, but you still need legitimate RTM data and documented interaction.

Beginning in 2026, new codes 98984/98985/98986 allow you to bill for 2–15 days of monitoring, while 98976/98977/98978 are updated to explicitly cover 16–30 days.

4

What interactive communication is required for RTM management codes?

You must have at least one synchronous, real-time conversation (audio-only telephone or audio-video). Crucial Update: Automated nudges, text messages, AI chat, or portal messages do not count toward the interactive requirement or the clinical labor time.

5

Can two providers bill RTM for the same patient in the same period?

No. Only one practitioner can bill RTM (or RPM) services for a patient in a given 30-day period, even if multiple clinicians are involved and multiple devices are used. Practices should designate a single billing provider for each patient’s RTM episode and coordinate internally.

6

Can I bill RTM together with CCM, PCM, BHI, TCM, or APCM?

In many cases, yes. CMS allows RTM or RPM to be billed in the same month as CCM, PCM, TCM, BHI, chronic pain management, and APCM when the time and services are distinct and not counted twice. The key is that you do not use the same minutes or identical activities to support more than one code family. Your documentation should make the dividing lines clear.

7

Do I need an established patient to start RTM?

No. CMS requires an established relationship for RPM, but not for RTM. RTM services still must be medically reasonable and necessary, and you must be able to show how RTM data is used in the context of the patient’s care, but there is no explicit “established patient” requirement in RTM policy.

8

How does CBT fit into RTM?

CPT 98978 (and, beginning in 2026, 98986 for 2–15 days) support RTM device supply for cognitive-behavioral therapy–oriented digital therapeutics. These codes are contractor-priced and payer adoption is still evolving. If you provide CBT-aligned digital therapy, confirm your MAC and commercial payer policies before relying on RTM CBT codes in your financial planning.

9

Can assistants help with RTM workflows?

Assistant involvement is setting and discipline dependent. Follow your therapy supervision rules and de minimis policies, and confirm MAC guidance for private practice.

10

What documentation do auditors expect for RTM?

Auditors look for: documented patient consent; the specific RTM device or app (and its status as a medical device); the plan of care or episode definition; day-counts for device-supply codes; cumulative treatment-management time logs; dates, times, and modes of interactive communication; and notes showing how RTM data influenced clinical decisions. The more explicitly you connect RTM data to care-plan changes, the stronger your position in an audit.

11

What exactly changes for RTM in 2026?

For dates of service on or after January 1, 2026, RTM gains new device-supply codes for 2–15 days of monitoring (98984–98986) and a new 10–19 minute treatment-management code (98979). Existing device codes 98976/98977/98978 are revised to clearly represent 16–30 days of RTM in a 30-day period, and 98980/98981 continue to cover longer management time buckets. These changes give you more granular options for short episodes and shorter management engagements, while preserving the ability to bill longer, ongoing programs.

12

Can I bill RTM for multiple conditions (e.g., Respiratory and MSK)?

Yes, with caveats. You can bill multiple device codes (e.g., 98976 for respiratory and 98977 for MSK) if the patient has distinct medical needs for both. However, you can still only bill one set of management codes (98980/98981) per month, as management time is per-patient, not per-condition. Coordination is key to avoid "duplicate service" denials.

13

Do I need patient consent for RTM?

Not always emphasized the same way as RPM, but best practice is to obtain and document consent because you are collecting PHI remotely and many payers expect it operationally.

14

Can RTM run during a surgical global period?

Generally the global package limits what the surgeon can separately bill, but RTM may be billable by a provider not paid under the global fee if it is distinct and properly documented; confirm payer rules.