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How to bill RTM in physical therapy: a step-by-step guide for 2026

Remote Therapeutic Monitoring is billed from two clocks, under a plan of care, by one practitioner per patient. Here is the whole sequence from checking the payer to sending the claim, with what to document at each step and the mistakes that cost clinics their claims.

Updated October 2026 · Medicare rules, with payer differences noted · A guide, not billing advice

The short version

Check first

Payer and plan of care

Traditional Medicare pays. Commercial payers disagree. RTM has to sit inside an active plan of care.

Count days

Per 30-day period

2 to 15 days of data is 98985, 16 or more is 98977. The setup code needs 2 days.

Log minutes

Per calendar month

10, 20 or each extra 20 minutes, with at least one live phone, video or in-person conversation.

Bill when final

Not before

Send each code once nothing still to come can change it, with a document behind every day and minute.

Before you start: who can bill

  • Physical therapists can bill the RTM codes under Medicare Part B. The codes are for "physicians and other qualified health care professionals." CMS proposed barring PTs in 2021 and reversed in the CY2022 final rule.
  • The service needs an order from a physician or other qualified health care professional, such as a physical therapist.
  • PTAs can furnish RTM. Since January 1, 2025, PTAs in private practice can work under general supervision for RTM. The service is billed under the supervising PT, and 98975 takes the PTA payment adjustment while the device codes do not.
  • One practitioner per patient per 30-day period. CMS allows only one practitioner to bill remote monitoring for a patient in a 30-day period, so decide up front who owns each RTM patient. Most clinics that make RTM work give it to one person or a few; our RTM playbook covers how.

Step 1

Confirm the payer pays for RTM

Coverage is the first question, and it is not one answer:

For anything other than traditional Medicare, call the plan, name the exact codes, and say "remote therapeutic monitoring," because an answer about RPM is not an answer about RTM. Write down the date, the representative and the reference number where the whole clinic can see it. Search any payer to see what its published policy says.

Step 2

Put RTM in the plan of care

RTM and its treatment management "must be included in and provided under an active plan of care during the episode of care." CMS classes the RTM codes as "sometimes therapy," and says RTM for therapy devices should always be furnished under a therapy plan of care.

APTA's advice on goals: document RTM like any other intervention, toward the plan of care's goals. The goals should be "specific to what you hope to achieve using remote therapeutic monitoring," and you do not need a goal about learning the device. One of APTA's examples:

"Remote therapeutic monitoring will facilitate the patient's independence in and their consistent and sustainable performance of a self-management plan."

Step 4

Set up the device and educate the patient (98975)

Show the patient how to log, have them demonstrate it, and document the type of device, the education and training you gave, and any setup. 98975 is billed once per episode of care, and only after the patient has activated the device and logged at least two days of monitoring in a 30-day period. Day 3 is the earliest. It is not billable on the day of setup.

Step 5

Count days of data in each 30-day period

The device supply code depends on how many days the patient's data was transmitted in the 30-day period:

Days of data in the 30-day periodCode2026 Medicare, national
0 or 1No device code-
2 to 1598985$51.44
16 to 3098977$51.44

The two are never billed for the same period. Document the name and description of the device. And watch engagement: APTA's advisory says that a lack of engagement "should be addressed in a timely manner through program modification, patient communication, and/or redetermination of the indication for remote monitoring." A patient who stops logging is a reason to call, not just a lower code. Every code and its 2026 rate: RTM CPT codes for 2026.

Step 6

Log management time in each calendar month

Treatment management is the practitioner's time reviewing the data and acting on it, counted per calendar month:

  • 98979 for 10 to 19 minutes, 98980 for 20 minutes or more (never both), and 98981 for each full additional 20 minutes, which can be billed more than once.
  • Every month needs at least one real-time interactive communication with the patient or caregiver: in person, by phone or by video. APTA says "telehealth and secure messaging would not be considered examples of this code," and minutes in that conversation cannot count toward any other code.
  • Document the data you reviewed, the date and time of the interaction, and any decision that changed the treatment or the plan of care.
  • The day thresholds do not apply here (CMS). A patient spanning two months needs 20 minutes in each month to bill 98980 in each.

Step 7

Bill each code once nothing can change it

Each code becomes safe to bill at a different moment, because data still to come can change some of them:

CodeSafe to billWhy
98975From day 3 of monitoringTwo days of data have occurred. Once per episode.
98977On day 16 of dataNothing later in the period can change it.
98985When the 30-day period endsThe patient could still reach 16 days, which makes it 98977.
98979, 98980, 98981When the calendar month endsMore minutes could still turn 98979 into 98980 or add a 98981 unit.

A physical therapist bills with the GP modifier, under the plan of care. A common setup is a monthly document per patient, uploaded into the clinic's own EMR, with the clinic billing the codes itself so it always knows what went out.

Documentation checklist

What APTA's advisory says to document, code by code. This is what a reviewer will look for.

ForDocument
Every codeAn active plan of care, an order, consent with its date, and how RTM serves the plan of care goals
98975The type of device, the education and training given, any setup required
98985 / 98977The name and description of the device, and the days of data in the 30-day period
98979 / 98980 / 98981The data gathered, the date and time of the live interaction, the decisions that changed treatment, and a time log that supports every minute billed

Mistakes that cost claims

  • Billing 98975 on the setup day. It needs two days of data first.
  • Billing 98985 and 98977 for the same period, or 98979 and 98980 in the same month.
  • Rounding up to 98981. Only a full additional 20 minutes counts. At least 43% of PTs' 98981 claims were denied by Medicare in 2025 (CMS PSPS), the highest of any RTM code.
  • A month with no live conversation. No management code can be billed for it, however many minutes were logged.
  • Counting a portal message as the conversation.
  • Two practitioners billing one patient in the same 30-day period, or billing RTM alongside RPM.
  • Billing after the plan of care has ended.
  • Assuming "Medicare" when the patient is in Medicare Advantage, or assuming every commercial plan pays.

Some denials are not coverage at all: a patient who was inpatient during the monitoring period, or a secondary payer that does not pay. Read the denial reason before you change your process.

The device question

The CPT code set calls for a medical device "as defined by the FDA," and the AMA does not verify any device's status. That is a lower bar than "FDA cleared." Patient-reported data is allowed under Medicare: APTA says data can be "objective device-generated integrated data or subjective inputs reported by a patient."

Two things are not settled. First, some payers ask for more: Highmark requires FDA-authorized technology, and Blue Cross of Idaho excludes manual logs and non-FDA-compliant software. Second, one of APTA's own examples says not to report 98977 when the patient already owns the device, and whether an app on the patient's phone counts as supplied is not addressed in anything we have read. Ask your payer and your MAC in writing before you rely on an answer. For the record: Rehabity is not an FDA-cleared device.

Questions

Can a PTA bill RTM?

A PTA can furnish it, under general supervision in private practice since January 1, 2025, and it is billed under the supervising PT. 98975 takes the PTA payment adjustment and the device codes do not.

Does RTM need an order?

Yes. APTA's advisory says the service must be ordered by a physician or other qualified health care professional, such as a physical therapist.

Can I bill RTM after discharge?

Not for a therapy device. RTM has to be provided under an active plan of care during the episode of care. That makes the tapering weeks at the end of an episode, when visits are far apart, the natural place for it.

How long can a patient stay on RTM?

Medicare sets no fixed number of months in the sources we read, only that it sits inside an active plan of care. Some commercial payers set limits: BCBS of Michigan's orders run up to 90 days, and Highmark authorizes 3 months at a time.

Is patient-reported data enough?

Under Medicare, yes. Some commercial payers attach stricter technology rules, covered in the device question.

Can I bill RTM for a patient getting home health?

Check the payer. Anthem's guideline calls RTM not medically necessary where similar services are provided concurrently, and gives home health as the example.

How Rehabity is set up for this

  • Your clinic admin designates the RTM therapists, so every RTM patient has one owner and nobody else touches billing.
  • Consent, setup and the live calls are recorded in the chart, with dates and what each call covered.
  • Days are counted per 30-day period and minutes per calendar month, and each code shows when it is final.
  • Each period and month produces a signed documentation packet to upload to your EMR. You bill the codes yourself.

See the billing workflow with your own caseload in mind.

We'll walk through how your RTM lead would enroll, review and bill, and how the rest of your team keeps working the way they do today.

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Sources

Read October 22, 2026. Coverage and documentation rules vary by payer, so check with yours and your Medicare Administrative Contractor. Spot an error? Tell us at contact@rehabityhealth.com.

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