Practice management. 9 minute read.

RTM CPT codes for physical therapy

The RTM CPT codes a physical therapist uses most under Medicare in 2026 are 98975 for setting up the device and teaching the patient, 98985 or 98977 for the musculoskeletal device supply (2 to 15 or 16 to 30 days of data within a 30-day period), and 98979, 98980 and 98981 for management minutes each calendar month. All of them sit under a therapy plan of care and carry the GP modifier. A physical therapist assistant (PTA) can take part, and the CQ modifier can then apply to the set-up and treatment management codes, never to the device supply codes. This is US content, written for physical therapists (PTs) and clinic owners who bill Original Medicare Part B.

What RTM is, how it differs from remote physiologic monitoring, and the wider rules are covered in remote therapeutic monitoring for physical therapists. This page stays with the codes: what each one pays for, when you can report it, which modifiers go with it and what to write down. The official descriptors are in the CPT code book from the American Medical Association and are copyrighted, so the code wording here is a paraphrase. Fee amounts are not given, so look them up in your Medicare Administrative Contractor's (MAC's) fee schedule for the current year. None of this is billing or legal advice, and your MAC decides how your claims are paid.

The RTM CPT codes at a glance

Code What it pays for Counted per Minimum before you report it Can CQ apply?
98975 Setting up the device and teaching the patient to use it Episode of care, once Device activated and at least 2 days of monitoring in a 30-day period Yes
98985 Musculoskeletal device supply 30-day period 2 to 15 days of data No
98977 Musculoskeletal device supply 30-day period 16 to 30 days of data No
98979 Treatment management, first 10 minutes Calendar month A full 10 minutes, with at least 1 real-time interactive communication Yes
98980 Treatment management, first 20 minutes Calendar month A full 20 minutes, with at least 1 real-time interactive communication Yes
98981 Treatment management, each further 20 minutes after 98980 Calendar month Each full additional 20 minutes Yes

The minimums come from the APTA practice advisory on RTM codes, last updated January 29, 2026. The CQ column comes from CMS: its MLN Matters article MM14250 on the 2026 therapy code list names 98975, 98979, 98980 and 98981 as the only RTM codes that fall under the 10 percent de minimis standard for therapy assistants.

The same code family also has device supply codes for the respiratory system (98976 and 98984) and for cognitive behavioral therapy (98978 and 98986), built on the same day bands. In outpatient physical therapy the musculoskeletal pair is the one that normally fits. CMS's CY 2026 final rule says the CPT Editorial Panel created the new codes for fewer than 16 days of data transmission in a 30-day period and fewer than 20 minutes of interactive communication in a month.

98975: set-up and patient education

98975 pays for getting the patient started. That means setting up the device and teaching the patient, or a caregiver, how to use it and how to record data properly. APTA's advisory says to report it only once per episode of care, and only after the patient has activated the device and at least 2 days of cumulative monitoring have taken place in a 30-day period. The advisory adds that the code may be billed on day 3 of monitoring.

A PTA can do the set-up. In the CY 2022 rule, CMS said the set-up and education service "is subject to the de minimis policy," so when the PTA's share of it is large enough under that standard, the line carries CQ as well as GP.

Device supply: 98985 or 98977?

The device supply codes pay for the device and the data it sends. Count the days on which data actually came through in the 30-day period.

Days of data in the 30-day period Device supply code
1 No device supply code
2 to 15 98985
16 to 30 98977

APTA's advisory calls the short and long codes "not additive in nature," so you report one or the other for that period, never both.

The CQ modifier never goes on these two codes. The CY 2026 rule states that CQ and CO are "not applicable to the RTM device codes 98984 and 98985," since the two new codes are based on 98976 and 98977 and those were already exempt. Whether a PTA helped that month makes no difference to the device supply line.

Watch the two different windows. The device supply codes count days within a 30-day period, but the treatment management codes count minutes in a calendar month. The two do not have to start and end on the same dates, so log days and minutes separately.

Treatment management: 98979, 98980, 98981

These codes pay for your time with the data. That covers reviewing what came in, deciding whether the program needs to change, and talking it through with the patient or caregiver. No month qualifies without at least 1 real-time interactive communication. APTA's advisory says that contact has to be synchronous, which it describes as in person, by phone or by video. An in-person talk can count as that contact, but its minutes still follow the clinic time rule below.

Choose the code from the total minutes at the end of the month. The ladder below applies APTA's rule that each code needs its full minutes, and the rule in both APTA's advisory and CMS's CY 2026 rule that the 10-minute and 20-minute codes are not added together.

  • Under 10 minutes: no treatment management code.
  • 10 to 19 minutes: 98979.
  • 20 to 39 minutes: 98980 on its own. A 20-minute month is 98980, not 98979 plus 98980.
  • 40 to 59 minutes: 98980 plus 1 unit of 98981.
  • 60 to 79 minutes: 98980 plus 2 units of 98981. Each further full 20 minutes adds another unit.

Clinic time counts once. The CY 2026 rule puts it this way: "For in-clinic discussions, no time or effort should be counted more than once toward the required time for any services." If you talk about the RTM data during a billed treatment visit, minutes you count toward that visit cannot also go toward the month's RTM total.

CMS confirmed in the same rule that its CQ policy covers the new 98979. MM14250 puts the three treatment management codes on its list of RTM codes subject to the de minimis standard, alongside 98975.

A worked example: three months of RTM for one patient

The patient and numbers below are invented to show code selection. They say nothing about how long a real patient should be monitored or how much time their care needs. To keep the arithmetic simple, her 30-day periods and calendar months are treated as lining up.

Ms. R is 68 and has knee osteoarthritis. Her PT adds RTM to her plan of care, and her home program is tracked through a device that meets the FDA device definition. Her PT does all the RTM work, so there is no CQ.

Month Days with data Management minutes Live contact Codes, each with GP
1 11 14 6-minute phone call 98975, 98985, 98979
2 22 46 10-minute video call 98977, 98980, 98981 x 1
3 9 8 None 98985

In month 1, 98975 is billed once, after her second day of data. In month 2, 46 minutes covers 98980 and one full additional block of 20 minutes, and the remaining 6 minutes do not make a second unit of 98981. In month 3 she is doing well and sends data less often, so the device supply drops back to 98985. There is no treatment management code that month, because the time was under 10 minutes and there was no live contact. 98975 is not billed again, since it is still the same episode of care.

Modifiers: GP and CQ

MM14250 says RTM services furnished by therapists are always provided under a therapy plan of care and need a therapy modifier. For physical therapy that is GP, on every RTM line: the five codes CMS labeled "sometimes therapy" in 2022 and the three it added for 2026. What the plan has to contain, and who certifies it, is in the physical therapy plan of care under Medicare.

CQ is the modifier for a service that a PTA furnished, fully or partly. CMS's Therapy Services page explains the de minimis standard: portions of a service the PTA furnished "independent of the therapist that exceed 10 percent of the total service, or unit of service, must be reported with the CQ/CO modifier, alongside of the corresponding GP/GO therapy modifier." Portions the PTA and PT furnish together count as the PT's. The same page links to CMS's billing examples for working out the percentage. For RTM, that standard covers the set-up code 98975 and the three treatment management codes, and no others.

Supervision of the PTA follows the usual Medicare and state rules for your setting. APTA's advisory notes that since January 1, 2025, Medicare has allowed PTAs in private practice to work under general supervision for all applicable outpatient therapy services, RTM included. If your state practice act is stricter, the state rule is the one you follow.

Do RTM codes count toward the KX modifier threshold?

CMS has not answered this directly in any of the RTM documents cited here. What CMS does say sits in the Claims Processing Manual, Chapter 5. Section 10.4 notes that CMS lists certain codes as "sometimes therapy" services, and says the Common Working File "will capture the amount and apply it to the limitation whenever a service is billed using the GN, GO, or GP modifier." A PT's RTM lines carry GP, and that wording does not set them apart from other GP lines. CMS has not said how it applies to RTM, though, so ask your MAC before you plan around it.

How the threshold works, and what the KX modifier attests to once a patient passes it, is explained in the KX modifier and the Medicare therapy threshold.

Does the 8-minute rule apply to RTM codes?

No. The 8-minute rule comes from Chapter 5, section 20.2 of the Claims Processing Manual, which deals with CPT codes that "specify that the direct (one on one) time spent in patient contact is 15 minutes." In the CY 2022 rule, CMS noted that 98980 and 98981 are 20-minute codes, "a different time interval from the existing 15-minute timed therapy codes." It added that 98981 covers each additional full 20 minutes, "so the midpoint rule is not applicable to these codes." CMS has not said the same in writing for 98979, which arrived in 2026, but APTA says not to report it until a full 10 minutes has occurred.

They overlap at the treatment visit. Minutes of therapeutic exercise or manual therapy in that visit go toward those timed codes under the 8-minute rule. Because of what CMS said about in-clinic time, those same minutes cannot also go into the RTM total. Keep a separate RTM log that shows the date, who did the work and what it was.

What to document for each RTM code

Code What APTA's advisory says to record
98975 Type of device; education and training given to the patient or caregiver; any set-up needed
98985 or 98977 The name and a description of the device used for musculoskeletal monitoring
98979, 98980, 98981 Data from the device; date and time of each interaction with the patient or caregiver; any decisions that changed treatment or the plan of care

APTA also says to document RTM like any other intervention, in terms of progress toward the plan of care goals. The goals do not have to name RTM, but they should say what you hope the monitoring will achieve, and no goal is needed for teaching the patient to use the device.

Two more records make a claim easy to check later. First, how many days had data in every 30-day period, because that settles 98985 against 98977. Second, the minutes in every calendar month, split by who spent them, because that settles the treatment management code and whether CQ applies. Also record that the patient agreed to RTM, and when. The CY 2027 proposed rule speaks of "the required beneficiary consent to receive RPM or RTM services."

RTM codes with commercial payers

These are CPT codes, so commercial plans can recognize them, but each plan sets its own coverage and rules. APTA's advisory recommends reviewing each payer's plans and policies to find out whether the codes are covered when a physical therapist bills them and, if so, what that payer needs for reporting and documentation. Get the answer in writing before the first claim.

What may change in 2027

The CY 2027 proposed rule, published July 16, 2026, could replace the whole code set. CMS is considering bundling the RPM and RTM CPT codes, including 98975, 98977, 98979, 98980, 98981 and 98985, into new codes that describe initial set-up and monthly monitoring and management, and it asked for comment on the idea. For RTM, that would mean two HCPCS G-codes: GRTM1 covering set-up and patient education, and GRTM2 as one monthly code. Comments closed on September 14, 2026. Nothing changes unless a final rule adopts it, and the RTM overview sets out the other 2027 proposals that affect RTM.

Where the home exercise program fits

For most PTs, musculoskeletal RTM means following a patient's home program between visits. The codes are only worth billing if that program is one the patient can actually follow, with the right exercises at the right dose. How to write a home exercise program covers choosing exercises, setting the dose and writing cues.

PocketPhysio is built for writing and sending that program. Every exercise in the library is filmed and paired with a voice guide, and you add the dose (sets, reps, hold) plus a cue in your own words. Your patient opens it through a link, SMS, email or Pocket Physio Care (the patient app), or over WhatsApp. Prices are shown in the app. PocketPhysio is not an RTM device, and this guide does not claim it captures the data or days of data these codes depend on.

Common coding mistakes with RTM codes

  1. Reporting 98979 and 98980 for the same calendar month. The total minutes decide which one.
  2. Reporting 98985 and 98977 for the same 30-day period.
  3. Billing 98979 for 8 or 9 minutes, or a unit of 98981 for part of a 20-minute block.
  4. Billing a treatment management code in a month with no real-time interactive communication.
  5. Billing 98975 a second time in the same episode of care, or before 2 days of monitoring.
  6. Adding CQ to 98977 or 98985, or leaving it off 98975, 98979, 98980 or 98981 when the PTA's share calls for it.
  7. Counting days of data by calendar month, or minutes by 30-day period.
  8. Counting the same minutes toward both a billed treatment visit and the month's RTM time.

The short version

The RTM CPT codes most physical therapists bill are 98975 for set-up and teaching, 98985 or 98977 for the musculoskeletal device depending on the days of data, and 98979, 98980 and 98981 for management minutes each calendar month. All go under a plan of care with GP, and CQ can apply to the set-up and management codes but never the device codes. The codes in each group are not added together, and each needs its full days or minutes. Rules change each year and CMS is weighing a bundled code set for 2027, so before you bill, check the CPT code book, this year's fee schedule rule and your MAC.

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. Sections on remote therapeutic monitoring: new codes, the sometimes therapy designation, CQ and CO modifiers, and in-clinic time. Accessed September 29, 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. MLN Matters MM14250: Therapy Code List: 2026 Annual Update. Article released November 24, 2025; related Change Request 14250 released September 25, 2025; effective January 1, 2026; implementation January 5, 2026. Accessed September 29, 2026. https://www.cms.gov/files/document/mm14250-therapy-code-list-2026-annual-update.pdf
  3. Centers for Medicare and Medicaid Services. Therapy Services, sections CY 2026 Therapy Services Updates and payment for services furnished in whole or in part by PTAs and OTAs (page last modified March 10, 2026). Accessed September 29, 2026. https://www.cms.gov/medicare/coding-billing/therapy-services
  4. 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; Medicare Shared Savings Program Requirements; Provider Enrollment Regulation Updates; and Provider and Supplier Prepayment and Post-Payment Medical Review Requirements (final rule). Federal Register. 86 FR 64996 to 66031, November 19, 2021; effective January 1, 2022. Document 2021-23972. Sections designating the RTM codes as sometimes therapy codes, applying the de minimis standard, noting the 20-minute time interval and stating that the midpoint rule does not apply to 98980 and 98981 (86 FR 65176). Accessed September 29, 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
  5. Centers for Medicare and Medicaid Services. Medicare Claims Processing Manual (Publication 100-04), Chapter 5: Part B Outpatient Rehabilitation and CORF/OPT Services. Section 10.4, Claims Processing Requirements for Financial Limitations (Revision 3995, effective June 11, 2018), and section 20.2, Reporting of Service Units With HCPCS (Revision 3670, effective January 1, 2017). Accessed September 29, 2026. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c05.pdf
  6. 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; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program (proposed rule). Federal Register. 91 FR 43842 to 44557, July 16, 2026; comments closed September 14, 2026. Document 2026-14327. Section on remote monitoring services, including the initiating visit and beneficiary consent. Accessed September 29, 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
  7. American Physical Therapy Association. APTA Practice Advisory: Remote Therapeutic Monitoring Codes Under Medicare. Initially released January 7, 2022; updated January 29, 2026. Accessed September 29, 2026. https://www.apta.org/contentassets/95321a10e951408db650e2f19b96699f/apta-practice-advisory-rtm-codes.pdf

Written and checked by the PocketPhysio editorial team. Last updated 2026-09-29.