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Learn How to Quickly and Easily Implement Remote Therapeutic Monitoring Into Your Practice

Learn How to Quickly and Easily Implement Remote Therapeutic Monitoring Into Your Practice

September 19, 2025

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 RTM

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 RTM 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 placeholder CPT codes (98XX4, 98XX5, 98XX6, 98XX7) 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:

  • 98XX4: Device supply/setup for 2–15 days of data, paired with at least 10 minutes of treatment management.
  • 98XX5: Device monitoring and treatment management for 2–15 days, covering the first 20 minutes.
  • 98XX6: Device monitoring and treatment management for ≥16 days, covering the first 20 minutes.
  • 98XX7: Additional 20 minutes of treatment management for ≥16 days.

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.

  1. Clarifications to Existing RTM 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).
  • 98976: Device supply with scheduled recordings for ≥16 days.
  • 98977: Device monitoring and treatment for ≥16 days, first 20 minutes.
  • 98978: Device monitoring for therapy adherence, ≥16 days (musculoskeletal/respiratory-specific).
  • 98980: Treatment management, first 20 minutes of interactive communication (≥16 days).
  • 98981: Additional 20 minutes of interactive communication (≥16 days).

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.

  1. Valuation and Payment Adjustments

CMS proposes changes to how RTM services are valued, focusing on Practice Expense (PE) Relative Value Units (RVUs):

  • OPPS-Based Valuation: For codes like 98XX5 and 98977, CMS proposes using Outpatient Prospective Payment System (OPPS) cost data instead of Relative Value Scale Update Committee (RUC) inputs due to concerns over supply costs (e.g., monthly device fees). This aims to align payments with actual costs.
  • Contractor Pricing: Codes 98XX4, 98976, and 98XX6 will be contractor-priced, allowing regional flexibility in reimbursement.
  • Setup Code (98975): CMS will not separately price enrollment fees, treating them as indirect PE costs.
  • New Technology Status: All RTM codes, including the new ones, are designated as “New Technology” and will be reviewed in April 2030, allowing interim contractor pricing to adapt to evolving costs.

CMS is seeking stakeholder input on supply costs (e.g., invoices) and differences between RTM and Remote Physiologic Monitoring (RPM) valuations to refine these adjustments.

  1. Staffing and Supervision

CMS maintains that RTM services can be performed by clinical staff such as registered nurses, licensed practical nurses, or medical therapy assistants under general supervision. The agency rejected RUC’s recommendation to designate physical therapy assistants as the primary staff, citing that family medicine and other specialties frequently bill RTM codes.

  1. Expanded Access in Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)

Starting in CY 2027, if finalized, RTM services (including 98980 and 98981) will be payable in RHCs and FQHCs as non-face-to-face care coordination services, expanding access to underserved communities.

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, contact us at support@mymovementrx.com