August 13, 2026
Remote therapeutic monitoring has a naming problem. It is keeping physician practices out of a program they are already qualified to run, and it is pushing the ones who do run it into a compliance gap they never see coming.
Ask ten clinic administrators who is allowed to bill remote therapeutic monitoring and most will tell you physical therapists. The word “therapeutic” sits right there in the name. It sounds like a therapy benefit, so people assume it arrives with therapy rules attached: an evaluation by a licensed therapist, a plan of care, a PT or OT signature on every touchpoint.
That assumption is wrong. A physician or nurse practitioner can order, supervise, and bill RTM with no therapist involved at any step.
The assumption is also, in one specific and very common scenario, closer to right than most physician practices realize. Getting that distinction wrong is the difference between a clean claim and a refund demand.
Where the confusion starts
RTM codes carry a Medicare designation called “sometimes therapy.” The label does an enormous amount of work and explains almost none of it.
Here is what it means. The same CPT code changes character depending on who submits the claim and what is being monitored. Bill 98980 as a physical therapist and it is a therapy service, with the machinery that follows: a plan of care, the CQ or CO modifier when an assistant contributes to the time, the 15 percent assistant payment reduction, and the therapy claim edits. Bill the identical code as a physician or nurse practitioner monitoring something outside the therapy benefit, and none of that applies.
Effective January 1, 2026, CMS extended the sometimes-therapy designation to three new RTM codes: 98979, 98984, and 98985. They join the five that already carried it.
The exception nobody reads
This is the part that catches physician practices, and it is worth quoting CMS directly. From the 2026 therapy code list update:
Therapists must always provide RTM services under a therapy plan of care. Physicians, physician assistants, nurse practitioners, and clinical nurse specialists provide RTM services under a therapy plan of care when related to the musculoskeletal device in codes 98977 and 98985, specific to therapy services, such as therapeutic exercises… Otherwise, provide RTM services appropriately outside a therapy plan of care with the sometimes therapy designation.
Read that again if you are building a physician-led home exercise program. Musculoskeletal monitoring tied to therapeutic exercise sits inside the therapy benefit even when a physician NPI is on the claim. The plan of care requirement follows the service, not the biller.
The practical consequences: you need a written plan of treatment, the GP modifier applies, and the claim counts against the KX modifier threshold under 42 CFR 410.60(e) and 410.59(e).
None of that requires hiring a therapist. Under 42 CFR 410.61, a physician, NP, PA, or clinical nurse specialist can establish the plan of treatment themselves, prescribing the type, amount, frequency, and duration of services along with the diagnosis and anticipated goals. But you have to actually do it, document it, and certify it. A physician practice that assumed RTM was a plain medical service and never built a therapy plan of care has a documentation problem sitting on every MSK claim it has filed.
Monitoring that is genuinely outside the therapy benefit, medication adherence or respiratory tracking or symptom reporting, stays a straightforward physician service with no plan of care.
The rule that makes the physician model practical
Being allowed to bill something is not the same as being able to staff it. A physician who personally reviews every adherence report and chases every patient who skipped their exercises has a program that dies in month two.
Effective January 1, 2023, CMS permits RTM to be furnished incident-to under general supervision rather than direct. The billing practitioner does not need to be in the building. Clinical staff can review transmitted data, work the exception reports, send the nudges, and log the minutes, and that time rolls up under the supervising practitioner. CMS said any RTM service may be furnished under the general supervision requirement.
That single change is what turns RTM from a physician side project into something a care team can run at scale. It also has a shelf life, which we will get to.
Where it breaks: assistants
Practices that get this far reach for the obvious labor pool. If the work is exercise adherence and functional check-ins, why not staff it with physical therapist assistants or occupational therapy assistants? They know the content and cost less than a therapist.
It does not work, and the reason depends on which pathway you are on.
If the monitoring is MSK and therapy-specific, you are under a therapy plan of care by CMS own instruction, which means 42 CFR 410.60(a)(3)(iii) governs. Its text:
When a physical therapy service is provided incident to the service of a physician, physician’s assistant, clinical nurse specialist, or nurse practitioner, by anyone other than a physician, physician assistant, clinical nurse specialist, or nurse practitioner, the service and the person who furnishes the service must meet the standards and conditions that apply to physical therapy and physical therapists, except that a license to practice physical therapy in the State is not required.
410.59(a)(3)(iii) says the same for occupational therapy. State licensure is waived. The qualification standard is not, and an assistant does not clear a therapist-level bar.
If the monitoring is outside the therapy benefit, the governing rule is the general incident-to standard at 42 CFR 410.26, which requires auxiliary personnel to meet applicable state requirements for the services they furnish. Now the question is your state practice act. PTAs and OTAs have no standalone scope of practice anywhere in the United States. They are tied to the direction and supervision of a licensed PT or OT for the practice of physical or occupational therapy, and a physician does not substitute for that supervision. Whether a given board would treat non-therapy RTM monitoring as triggering its practice act is fact-specific and varies. Do not assume either answer without state-board counsel.
Assistants are not a shortcut into the physician pathway. They are a feature of the therapist pathway.
What clean staffing looks like
The physician-billed model runs on ordinary clinical staff. A registered nurse, an LPN, a medical assistant, or a trained care coordinator can furnish the monitoring incident-to the physician or NP under general supervision, and their minutes count toward the treatment management codes, including the required live communication.
Many practices choose to have the billing practitioner personally handle that monthly live contact anyway. Medicare does not require it. It is simply a lot easier to defend, and it keeps the practitioner genuinely engaged with the plan rather than certifying work they never saw.
If you want assistant labor in the mix, take the therapist road deliberately. A PT or OT owns the plan of care and bills the RTM codes, assistants contribute time under general supervision (permitted for RTM since January 1, 2024, and for all applicable outpatient PT and OT services in private practice since January 1, 2025), and you accept the CQ and CO modifiers plus the 15 percent reduction on 98975, 98979, 98980, and 98981. The device supply codes are not subject to the assistant differential. Different program, different unit economics. Pick one on purpose instead of drifting into a hybrid that satisfies neither rule set.
The 2026 musculoskeletal codes
CMS added three new sometimes-therapy RTM codes effective January 2026, plus a fourth for cognitive behavioral therapy device supply. The MSK subset most practices will use:
- 98975 Initial setup and patient education on use of the equipment. Now predicated on at least 2 days of monitoring in a 30-day period, down from 16.
- 98985 Device supply, musculoskeletal system, 2 to 15 days of data in a 30-day period. New for 2026.
- 98977 Device supply, musculoskeletal system, 16 to 30 days of data in a 30-day period. Descriptor revised for 2026.
- 98979 Treatment management, first 10 minutes. New for 2026.
- 98980 Treatment management, first 20 minutes.
- 98981 Treatment management, each additional 20 minutes.
Parallel codes exist for respiratory monitoring (98976 and the new 98984) and cognitive behavioral therapy (98978 and the new 98986).
Two constraints trip people up. The codes are non-additive, so you bill one device supply code per 30-day period and one base treatment management code per month. And treatment management requires at least one live, interactive communication with the patient or caregiver during the calendar month. CMS adopted CPT language here and declined to add further exclusions, so audio-only telephone counts and the communication contributes to total time without having to account for all of it. CMS did not affirmatively bless secure messaging, asynchronous chat, or automated prompts. Treat those as unsettled.
Before 2026 the floor was 16 days of data and 20 minutes of management time. A lot of clinically appropriate patients fell through that gap, particularly short postoperative episodes and transitional check-ins. The new codes close it.
What will actually get you audited
Start with the myth that sends people down the wrong road. RTM data may be patient self-reported or manually entered as well as digitally uploaded. That flexibility is the entire reason the RTM family exists separately from remote patient monitoring, which does require automatic device capture of physiologic data. If someone tells you self-report disqualifies you from RTM, they are describing RPM.
What is not negotiable is the device. The tool must meet the FDA definition of a medical device under section 201(h) of the FD&C Act. Software as a medical device can qualify. A generic home exercise app that has never been characterized as an FDA device is not an RTM device, however good the engagement data looks. You also need documented days of data transmission to support whichever supply code you billed.
Then the unglamorous items that show up in every records request:
- Patient consent, obtained and documented before services begin.
- The order from the billing practitioner.
- Timestamped interaction logs, including the monthly live communication.
- A therapy plan of care and GP modifier where the MSK exception applies.
- No minute counted twice across RTM and any other care management or in-person service.
The bigger thing on the horizon
OIG issued two reports on remote patient monitoring, in 2024 and 2025, finding weak oversight and questionable billing. CMS responded in the CY 2027 physician fee schedule proposed rule, released July 2026, and the response reaches RTM as well as RPM.
If finalized, CMS would require an established patient relationship, require a separately reportable face-to-face initiating visit, and pay for monitoring only when it is furnished by clinical staff directly employed by the billing practitioner or the practice. That last one matters more than the others. It would eliminate the third-party and contracted staffing arrangements a large share of full-service RTM programs are built on. CMS also proposed lower valuations for the device supply and setup codes and asked for comment on collapsing all 17 RPM and RTM codes into four bundled G-codes.
Comments are due September 14, 2026. If you run one of these programs, or are about to build one, this is the window.
The bottom line
A physician or nurse practitioner can order, supervise, and bill remote therapeutic monitoring without a PT, OT, or SLP involved at any step, and can staff the daily work with ordinary clinical personnel under general supervision. Two things narrow that. When the monitoring is musculoskeletal and tied to therapeutic exercise, CMS expects a therapy plan of care even with a physician billing, and the practitioner has to actually write one. And the staffing flexibility that makes the model work is on the table in the CY 2027 proposed rule.
Build for the rule as it exists. Watch the one that is coming.
This article is general information about Medicare coding and coverage policy, current as of August 2026. It is not legal or compliance advice. State practice acts vary and several are stricter than the federal floor. Verify your specific staffing model with counsel and your state licensing boards before you build.
Sources: CMS MLN Matters MM14250, Therapy Code List 2026 Annual Update; CY 2026 Medicare Physician Fee Schedule final rule (Nov. 5, 2025); CY 2027 Medicare Physician Fee Schedule proposed rule (July 2026); 42 CFR 410.26, 410.59, 410.60, 410.61; APTA Practice Advisory on Remote Therapeutic Monitoring, July 2025; HHS OIG, Additional Oversight of Remote Patient Monitoring in Medicare Is Needed (2024) and Billing for Remote Patient Monitoring in Medicare (2025).