Pioneers in Remote Therapeutic Monitoring (RTM) Software for Physical Therapists

At MovementRx, we’re committed to keeping you informed about the latest developments in healthcare, especially those impacting physical therapy and patient care. The Centers for Medicare & Medicaid Services (CMS) recently released the Calendar Year (CY) 2026 Physician Fee Schedule (PFS) Proposed Rule, introducing significant updates to Remote Therapeutic Monitoring (RTM) that could transform how physical therapists deliver care. These changes, proposed on July 14, 2025, aim to enhance access to RTM services, particularly for shorter monitoring periods, and align payment structures with clinical needs. Here’s what you need to know about the proposed changes and how they could benefit your practice and patients.

Background on Remote Therapeutic Monitoring

Remote Therapeutic Monitoring (RTM) allows physical therapists to monitor non-physiological data, such as musculoskeletal or respiratory system status, therapy adherence, and patient progress, using digital tools. Introduced in 2022, RTM CPT codes (98975–98981) have enabled providers to bill for device setup, monitoring, and patient communication, but limitations—particularly the requirement of at least 16 days of data collection in a 30-day period—have restricted their use. The CY 2026 PFS Proposed Rule addresses these challenges with new codes and revised guidelines, making RTM more flexible and accessible.

Key Proposed Changes to Remote Therapeutic Monitoring for 2026

The CMS, informed by the American Medical Association’s (AMA) CPT Editorial Panel updates from September 2024, proposes several changes to make RTM billing more inclusive, especially for shorter monitoring periods. Below are the highlights:

1. New CPT Codes for Shorter Monitoring Periods

To address feedback about the restrictive 16-day minimum data requirement, CMS introduces four new CPT codes for RTM services with 2–15 days of data collection in a 30-day period. These complement the existing codes, which will now explicitly require ≥16 days of data. Here’s a breakdown:

• 98984: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of respiratory system, 2-15 days in a 30-day period.
• 98985: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of musculoskeletal system, 2-15 days in a 30-day period.
• 98986: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of cognitive behavioral therapy, 2-15 days in a 30-day period.
• 98979: Remote therapeutic monitoring treatment management services, physician or other qualified health care professional time in a calendar month requiring at least 1 real-time interactive communication with the patient or caregiver during the calendar month; first 10 minutes.

These new codes allow physical therapists to bill for RTM even when patients transmit data for fewer than 16 days, addressing real-world scenarios where shorter monitoring is clinically appropriate.

2. Clarifications to Existing Remote Therapeutic Monitoring Codes

The existing RTM codes (98975–98981) remain largely unchanged in structure but are clarified to align with the new codes:

• 98975: Device setup and patient education (no change), billed once 30 days after setup and requires >16 days of data transmission to and or from the patietns device/software.
• 98976: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of respiratory system, 16-30 days in a 30-day period.
• 98977: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of musculoskeletal system, 16-30 days in a 30-day period.
• 98978: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of cognitive behavioral therapy, 16-30 days in a 30-day period.

The ≥16-day threshold is now explicitly defined for 98976, 98977, 98978, 98980, and 98981, ensuring clarity when billing alongside the new shorter-period codes.

Implications for Physical Therapists

These proposed changes offer significant opportunities for MovementRx providers:

• Increased Billing Flexibility: The new 2–15-day codes allow billing for shorter monitoring periods, accommodating patients with variable adherence or shorter treatment plans.
• Enhanced Patient Care: RTM’s focus on non-physiological data (e.g., therapy adherence, pain levels) enables physical therapists to monitor progress remotely, improving outcomes through timely interventions.
• Financial Opportunities: Expanded billing options and potential RHC/FQHC payments could increase revenue streams, especially for practices serving rural or underserved populations.
• Streamlined Operations: Clarified code descriptors reduce billing confusion, while contractor pricing offers flexibility in reimbursement.

However, challenges remain, such as navigating contractor-priced codes and ensuring accurate documentation for shorter monitoring periods. MovementRx recommends staying updated on the final rule (expected late 2025) and preparing to adjust billing workflows.

Next Steps for MovementRx Providers

1. Review the Proposed Rule: Dive into the full CMS CY 2026 PFS Proposed Rule for detailed insights. Access it via the Federal Register.
2. Submit Feedback: Although the public comment period closed on September 12, 2025, stay engaged with professional organizations like the APTA to advocate for RTM refinements.
3. Prepare for Implementation: If finalized, these changes take effect January 1, 2026. Update your billing systems and train staff on the new 2–15-day codes.
4. Leverage Technology: Use MovementRx’s digital tools to streamline RTM data collection and ensure compliance with CMS requirements.

Stay Informed with MovementRx

The CY 2026 PFS Proposed Rule marks a pivotal step in expanding RTM’s role in physical therapy. At MovementRx, we’re here to support you with resources, training, and technology to navigate these changes. Stay tuned for updates on the final rule and join our community for expert guidance on integrating RTM into your practice.

For more information, consider reading the Physical Therapists complete guide to Remote Therapeutic Monitoring. 

Also to learn more about the 2026 CMS RTM Code changes read here. 

Below are the most frequently asked questions about the 2026 changes coming….

What are the key changes to Remote Therapeutic Monitoring (RTM) proposed in the CY 2026 Physician Fee Schedule?

The CY 2026 Physician Fee Schedule proposes new CPT codes for shorter monitoring periods of 2–15 days, clarifications to existing RTM codes, adjustments to valuation and payment structures, guidelines on staffing and supervision, and expanded access in Rural Health Clinics and FQHCs.

How will the new CPT codes for 2–15 days of RTM data collection affect billing practices?

The new CPT codes for 2–15 days of data collection (98XX4, 98XX5) will enable providers to bill for shorter monitoring periods, allowing more flexibility in cases where patients transmit data fewer than 16 days, thereby extending the clinical applicability of RTM services.

What are the implications of the proposed RTM changes for physical therapy practices?

These changes offer increased billing flexibility, enhanced remote patient monitoring, new revenue opportunities, and streamlined operations, especially through shorter monitoring period codes, but practices will need to stay updated on the final rule and adjust workflows accordingly.

Who is authorized to perform RTM services under the proposed rules?

CMS states that RTM services can be performed by clinical staff such as registered nurses, licensed practical nurses, or medical therapy assistants under general supervision, with no preference for physical therapy assistants.

What steps should MovementRx providers take to prepare for the potential implementation of these changes?

Providers should review the proposed rule, submit feedback through professional organizations if possible, prepare to update billing systems and educate staff on the new codes, and leverage digital tools to ensure compliance and streamline RTM data collection.