Remote therapeutic monitoring (RTM) for physical therapists: codes, rules and 2026 changes

Remote therapeutic monitoring (RTM) is a family of CPT codes that Medicare pays for tracking a patient's response to treatment at home through a medical device, and for the time you spend managing their care from that data. Unlike remote physiologic monitoring (RPM), RTM can use non-physiologic data such as musculoskeletal status and therapy adherence, and physical therapists can bill it under a therapy plan of care. From January 1, 2026, new codes cover months with only 2 to 15 days of data, plus a treatment management code for the first 10 minutes, so the 16-day minimum now applies only to the older device supply codes.

Everything below applies to Original Medicare (Part B) in the US. Where the exact wording matters, the Federal Register is quoted directly. Payment amounts are left out on purpose, since they vary by year and by locality.

This is education only, and none of it is billing or legal advice. RTM rules change every year, and CMS has already proposed further changes for 2027. Before you start or change RTM billing, check the current CPT code book, the latest fee schedule rule and the guidance from your Medicare Administrative Contractor (MAC).

What is remote therapeutic monitoring?

The CY 2026 Physician Fee Schedule final rule describes it in one line: "Remote therapeutic monitoring (RTM) represents the monitoring of adherence to at-home therapeutic interventions." The CY 2024 rule put it another way, as "the use of a device to monitor a patient's health or response to treatment using non-physiological data."

There are separate device supply codes for three kinds of monitoring. CMS lists them as respiratory system, cognitive behavioral therapy and musculoskeletal system monitoring. In outpatient physical therapy it is mostly the musculoskeletal codes, together with the treatment management codes, that come up.

The device matters. When CMS first paid for RTM in the CY 2022 rule, it wrote that for both RPM and RTM "the device used must meet the FDA definition of a device as described in section 201(h) of the Federal Food, Drug and Cosmetic Act (FFDCA)." A paper handout or an ordinary exercise app is not RTM just because the patient uses it at home. If you are weighing up a product, ask the vendor to explain in writing how it meets that definition.

RTM vs RPM: what is the difference?

On paper the two look alike. The difference is in the data they collect and in who may bill them.

	RPM	RTM
Data	Physiologic, digitally uploaded	Non-physiologic; CMS noted reports that it can be patient reported as well as digitally uploaded
Examples in the code descriptors or CMS text	Weight, blood pressure, pulse oximetry, respiratory flow rate	Musculoskeletal system status, respiratory system status, therapy adherence, therapy response
Can a PT bill it under Medicare?	No. CMS treats RPM as evaluation and management (E/M) services	Yes, under a therapy plan of care

The CY 2022 rule explains how that split came about. "RPM services are considered to be E/M services and physical therapists, for example, are not permitted to furnish E/M services." The same rule notes that stakeholders suggested RTM was created so that practitioners who cannot bill RPM could furnish similar services. CMS expected physical therapists to be among the main billers of the new codes, along with physiatrists and nurse practitioners.

You cannot bill both families for the same patient at the same time. In its CY 2024 rule, CMS clarified "that RPM and RTM may not be billed together, so that no time is counted twice by billing for concurrent RPM and RTM services." When commenters on the CY 2026 rule asked to allow concurrent billing, CMS left the policy as it was and pointed back to those 2024 clarifications. A video visit is a different thing again. For the clinical side of treating over video, see telehealth for physical therapists.

RTM CPT codes and what each covers

The CPT code book (published by the American Medical Association) holds the full descriptors, and they are what you bill against. The table below gives the short version, using the CMS wording from the CY 2024 and CY 2026 rules. For the day and time rules behind each one, the GP and CQ modifiers and what to write down, see RTM CPT codes for physical therapy.

Code	What it covers
98975	Initial set-up and patient education on use of equipment
98976	Device supply, respiratory system, each 30 days; from 2026, 16 to 30 days of data
98977	Device supply, musculoskeletal system, each 30 days; from 2026, 16 to 30 days of data
98978	Device supply, cognitive behavioral therapy, each 30 days; from 2026, 16 to 30 days of data
98984	New for 2026: respiratory device supply, 2 to 15 days of data in a 30-day period
98985	New for 2026: musculoskeletal device supply, 2 to 15 days of data in a 30-day period
98986	New for 2026: cognitive behavioral therapy device supply, 2 to 15 days of data in a 30-day period
98979	New for 2026: treatment management, first 10 minutes
98980	Treatment management, first 20 minutes in a calendar month, with at least one interactive communication with the patient or caregiver
98981	Treatment management, each additional 20 minutes (an add-on to 98980)

For a PT, the codes that come up most are 98975, the musculoskeletal pair (98977 and 98985) and the treatment management codes (98979 to 98981). The CY 2022 rule was specific about therapy devices. RTM services that relate to devices specific to therapy services, "such as the ARIA Physical Therapy device (CPT code 98977), should always be furnished under a therapy plan of care."

The 16-day requirement and what changed in 2026

Until the end of 2025, the device supply codes needed at least 16 days of data. The CY 2024 rule restated it after the COVID-19 public health emergency ended: "Monitoring must occur over at least 16 days of a 30-day period." A month with 12 days of readings had no device supply code at all.

For 2026 the CPT Editorial Panel added codes for shorter months. In CMS's words, the Panel "created four new RTM codes to describe RTM services that describe less than 16 days of data transmission per 30-day period and less than 20 minutes of interactive communication per month." It also edited the three older device supply codes, 98976 to 98978, to state the minimum days of data. So the device supply codes now come in two bands: 2 to 15 days and 16 to 30 days in a 30-day period. Neither band describes a month with fewer than 2 days of data.

When CMS proposed how to value the new musculoskeletal code, it proposed "the same valuation for both CPT codes 98985 and 98977 since the device is supplied to the beneficiary for the full 30-day period, regardless of the number of days that data is transmitted." CMS finalized one practice expense value for both codes, and a March 2026 correction to the rule then updated it. For what either code pays in your area this year, check your MAC's current fee schedule.

The set-up code may have changed too. Commenters on the CY 2026 rule described the 2026 CPT change to 98975 as meaning the service "now requires 2 days of monitoring in a 30-day period for reporting, as opposed to 16." CMS replied that it adopts all 2026 CPT descriptor, guideline and parenthetical changes, including for 98975, but it did not restate the day count itself. Before you rely on that, read the current CPT descriptor for 98975 and check how your MAC handles it.

Who can bill RTM under Medicare Part B?

Physical therapists can. The American Physical Therapy Association (APTA) practice advisory on RTM says: "Physical therapists may bill these RTM codes under Medicare, and the codes also may be billable under commercial insurance plans." For commercial plans, read each payer's written policy, because Medicare rules do not carry over automatically.

CMS labels the RTM codes "sometimes therapy" codes, and it confirmed in the CY 2026 rule that the new 98979, 98984 and 98985 carry the same label. It explained what that means: the services "can be billed outside a therapy plan of care (POC) by a physician and certain NPPs, when appropriate; and always require a POC therapy modifier when furnished by a physical therapist (PT) or occupational therapist (OT), or by a therapy assistant under the PT's or OT's supervision, or speech-language pathologist." In practice, a PT puts RTM in the plan of care and adds the GP modifier to the claim lines. What goes into that plan, and who has to certify it, is set out in the Medicare plan of care for PT.

PTAs and supervision

CMS allowed RTM to be furnished under general supervision from 2023, but the private practice regulation still required physical therapists in private practice to supervise their PTAs directly. The CY 2024 rule changed that for RTM from January 1, 2024. The CY 2025 rule then extended general supervision of PTAs in private practice to all physical therapy services from January 1, 2025. The regulation now says "Physical therapy services may be performed by a physical therapist assistant under the general supervision of the physical therapist in private practice" (42 CFR 410.60(c)(2)). A physical therapist who is not enrolled in Medicare still needs direct supervision.

Medicare is not the only rule that applies, though. When CMS made the 2025 change, it said the policy parallels the 44 states that allow general supervision of PTAs, citing the Federation of State Boards of Physical Therapy, and that in states with stricter rules, Medicare therapy services must follow state law. Check your own state practice act, and follow whichever rule is stricter.

The CQ modifier marks services a PTA furnished in whole or in part. CMS says RTM codes generally need CQ, alongside GP, when the PTA's part meets or exceeds the de minimis (10 percent) threshold, and it points to its CQ billing examples on the CMS therapy services web page for how to work that out. The CY 2022 rule already applied the de minimis policy to the set-up code 98975. The CY 2026 rule says the CQ policy applies to the new 98979, but that CQ is "not applicable to the RTM device codes 98984 and 98985," in line with its earlier policy for 98976 and 98977.

One practitioner per 30-day period

In the CY 2024 rule, CMS said that "only one practitioner can bill CPT codes 99453 and 99454, or CPT codes 98976, 98977, 98980, and 98981, during a 30-day period." The same passage says remotely monitored monthly services should be reported only once in a 30-day period, and only when reasonable and necessary. That wording predates the 2026 codes, so check with your MAC before you apply it to 98979 and 98985. At the first visit, also ask the patient whether any other clinician is monitoring them remotely.

The interactive communication requirement

The treatment management codes need a live conversation, not just time spent reading data. In the CY 2026 rule, CMS said it adopts the CPT language, which says codes 98979 to 98981 "require a live, interactive communication with the patient/caregiver. The interactive communication contributes to the total time, but it does not need to represent the entire cumulative reported time of the treatment management service."

Commenters asked CMS whether secure messaging, asynchronous chat, automated two-way messages and AI prompts could count. CMS did not list them as allowed or excluded. It said it is "not specifying further exclusions for the types of communications that can be had with the patient/caregiver, so long as they meet the CPT specifications." If you plan to count anything other than a real-time phone or video conversation, get your MAC's view first.

In-clinic time needs care. CMS added: "For in-clinic discussions, no time or effort should be counted more than once toward the required time for any services." A conversation during a billed treatment visit cannot also count toward the month's RTM minutes.

The 98980 and 98981 descriptors count treatment management time in a calendar month. It runs on its own clock, separate from the 15-minute units that the 8-minute rule applies to timed codes.

Documentation for RTM

None of the rules quoted here sets out an RTM documentation checklist. Still, every requirement above needs something in the record to back it up. In practice that usually means:

1. The plan of care. RTM is included, with the goals it serves, and the plan is certified as usual.
2. The device. Name the device, the date you set it up, and what you taught the patient about using it.
3. Consent. CMS's CY 2027 proposed rule refers to "the required beneficiary consent to receive RPM or RTM services." Record that the patient agreed, and when.
4. Days of data. Count the days with data in each 30-day period, since that decides between the 2 to 15 day code and the 16 to 30 day code.
5. Minutes and people. Log treatment management minutes for each calendar month, who did them (you or a PTA), and the date and method of each live interactive communication.
6. Your clinical decisions. Say what the data showed and what you did about it, such as changing the dose, calling the patient in, or keeping the program as it is. A log of minutes with no reasoning shows no skill. For where reasoning sits in a note, see SOAP note structure; the page on the KX modifier quotes how Medicare looks for skilled care in the record.
7. Modifiers. GP on RTM lines, and CQ on codes such as 98975 and 98979 when a PTA's part meets or exceeds the de minimis threshold, but not on the musculoskeletal device supply codes 98977 and 98985.
8. Other monitoring. Note that you asked whether anyone else was billing remote monitoring for this patient.

Proposed changes for 2027

CMS published the CY 2027 proposed rule on July 16, 2026. Comments closed on September 14, 2026. Nothing in it applies until CMS publishes a final rule. Four parts of it touch RTM directly, and CMS also proposed new values for the set-up and device supply codes because it is concerned they are overvalued.

The first is an established patient rule. For CY 2027, CMS is proposing "to require that RTM services also be furnished only to established patients." Until now, that requirement applied to RPM but not RTM.

The second is an initiating visit. Under the CY 2027 proposal, "practitioners reporting RPM or RTM services must furnish a separately reportable initiating visit in association with the onset of RPM or RTM services." CMS proposes that the visit be face-to-face, in person or by telehealth, that RTM is discussed at it, and that it can be billed separately.

The third is about who does the work. CMS wrote that outsourcing to third parties "can fragment care," and proposed "to only allow payment for RPM or RTM services when furnished by clinical staff employed by the practice." Under the proposal, clinical staff time would count only if the person is a direct employee of the practitioner or the practice.

The fourth is a possible new code set. CMS said it is considering, and asked for comment on, four new HCPCS G-codes for remote monitoring, two of them for RTM: GRTM1 for set-up and patient education, and GRTM2 for a calendar month that bundles device supply, 2 or more days of data transmission, and at least 20 minutes of treatment management with at least one real-time interactive communication. CMS said it could finalize payment for these codes after it has considered the comments.

Some in the profession are worried. Writing on the APTA website, physical therapist Sangwon Lim said that, if finalized, the proposal "could significantly limit many physical therapy practices' ability to provide RTM through contracted clinical support models." Wait for the CY 2027 final rule before you change contracts or staffing.

RTM and the home exercise program

In outpatient physical therapy, the treatment RTM tracks is very often the home exercise program (HEP). Adherence data are only worth having if the program was clear and worth doing in the first place. Exercise choice and dosing have their own page: how to build a HEP patients can follow. If the numbers show a patient has stopped, what gets in the way of home exercise may explain why.

PocketPhysio covers the program side. From the exercise library you choose what the patient needs, give each exercise its dose, and add a cue phrased the way you coach it in clinic. Every exercise in it is filmed and has a voice guide.

Programs go out by link, SMS or email, or into Pocket Physio Care, the patient app. WhatsApp can be used as well. At the follow-up, your last program is there to change or progress. PocketPhysio is not presented here as an RTM device or a billing tool, and this guide makes no claim that it records the data or days of data that RTM billing requires.

Common mistakes with RTM

1. Billing RPM codes as a PT. CMS treats RPM as E/M services, which physical therapists cannot furnish.
2. Assuming any app counts. The device has to meet the FDA definition in section 201(h).
3. Using a 16 to 30 day code for a month with fewer than 16 days of data. From 2026, 2 to 15 days has its own code; below 2 days there is no device supply code.
4. Counting treatment management minutes in a month with no live interactive communication.
5. Counting the same minutes twice, once in a treatment visit and again as RTM time.
6. Leaving off the GP modifier, missing CQ when a PTA's part meets or exceeds the de minimis threshold, or adding CQ to the musculoskeletal device supply codes.
7. Billing when another practitioner already billed remote monitoring for the patient in the same 30-day period.
8. Following last year's rules, or treating the 2027 proposals as if they were final.

The short version

Remote therapeutic monitoring pays for monitoring a patient's response to treatment at home through an FDA-defined device, and for the treatment management time around it. Physical therapists can bill RTM, not RPM, as "sometimes therapy" services under a plan of care, with the GP modifier, and PTAs can take part under the supervision rules for your setting and state.

Since January 1, 2026, device supply comes in two bands, 2 to 15 days (98985 for musculoskeletal) and 16 to 30 days (98977). Treatment management starts at 10 minutes (98979), then 20 minutes (98980) and each additional 20 minutes (98981), and needs a live interactive communication with the patient or caregiver. Your records should show the plan and the patient's consent, the device, the days of data and minutes, and the clinical decisions you made. The rules change every year, and CMS has proposed more for 2027, so check the latest rule and your MAC before you bill.

References

1. Centers for Medicare and Medicaid Services. Medicare and Medicaid Programs; CY 2026 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program (final rule). Federal Register. 90 FR 49266 to 50481, November 5, 2025; effective January 1, 2026. Document 2025-19787. Remote monitoring discussion at 90 FR 49394 to 49404. Accessed September 28, 2026. https://www.federalregister.gov/documents/2025/11/05/2025-19787/medicare-and-medicaid-programs-cy-2026-payment-policies-under-the-physician-fee-schedule-and-other
2. Centers for Medicare and Medicaid Services. CY 2026 Payment Policies Under the Physician Fee Schedule; Correction. Federal Register. 91 FR 12071 to 12082, March 12, 2026. Document 2026-04797. Accessed September 28, 2026. https://www.federalregister.gov/documents/2026/03/12/2026-04797/medicare-and-medicaid-programs-cy-2026-payment-policies-under-the-physician-fee-schedule-and-other
3. Centers for Medicare and Medicaid Services. Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies (proposed rule). Federal Register. 91 FR 43842 to 44557, July 16, 2026; comments closed September 14, 2026. Document 2026-14327. Section on remote monitoring. Accessed September 28, 2026. https://www.federalregister.gov/documents/2026/07/16/2026-14327/medicare-and-medicaid-programs-cy-2027-payment-policies-under-the-physician-fee-schedule-and-other
4. Centers for Medicare and Medicaid Services. Medicare and Medicaid Programs; CY 2024 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies (final rule). Federal Register. 88 FR 78818 to 80047, November 16, 2023; effective January 1, 2024. Document 2023-24184. Sections on clarifications for remote monitoring services and on RTM for physical therapists and occupational therapists in private practice. Accessed September 28, 2026. https://www.federalregister.gov/documents/2023/11/16/2023-24184/medicare-and-medicaid-programs-cy-2024-payment-policies-under-the-physician-fee-schedule-and-other
5. Centers for Medicare and Medicaid Services. Medicare Program; CY 2022 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies (final rule). Federal Register. 86 FR 64996 to 66031, November 19, 2021; effective January 1, 2022. Document 2021-23972. Sections on remote therapeutic monitoring. Accessed September 28, 2026. https://www.federalregister.gov/documents/2021/11/19/2021-23972/medicare-program-cy-2022-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part
6. Centers for Medicare and Medicaid Services. Medicare and Medicaid Programs; CY 2025 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies (final rule). Federal Register. 89 FR 97710 to 99057, December 9, 2024; effective January 1, 2025. Document 2024-25382. Section on supervision of physical therapist assistants in private practice. Accessed September 28, 2026. https://www.federalregister.gov/documents/2024/12/09/2024-25382/medicare-and-medicaid-programs-cy-2025-payment-policies-under-the-physician-fee-schedule-and-other
7. Code of Federal Regulations. 42 CFR 410.60, Outpatient physical therapy services: Conditions, paragraphs (a)(3)(ii) and (c)(2) (as amended at 89 FR 98556, Dec. 9, 2024). Legal Information Institute, Cornell Law School. Accessed September 28, 2026. https://www.law.cornell.edu/cfr/text/42/410.60
8. American Physical Therapy Association. APTA Practice Advisory: Remote Therapeutic Monitoring Codes Under Medicare. January 29, 2026 (full text for APTA account holders; opening paragraph public). Accessed September 28, 2026. https://www.apta.org/your-practice/payment/medicare-payment/rtm-codes-practice-advisory
9. Lim S. Remote Therapeutic Monitoring at a Turning Point: A Perspective From the Field. American Physical Therapy Association, August 28, 2026 (full text for APTA account holders; opening paragraph public). Accessed September 28, 2026. https://www.apta.org/article/2026/08/28/remote-therapeutic-monitoring-at-a-turning-point

Written and checked by the PocketPhysio editorial team. Last updated 2026-09-28.