CPT 98977 is the recurring device code in a musculoskeletal Remote Therapeutic Monitoring (RTM) program, the code a clinic bills for every 30-day period a patient stays enrolled and keeps engaging with their monitoring. The clinic is reimbursed for the data that patient transmits through the software (Actuvi).

For a musculoskeletal patient, that data is their level pain, their range of motion, how consistently they do the home exercises they were given, and how their function changes as they heal from an injury, a surgery, or a flare of an orthopedic condition. All of it is patient-reported and non-physiological.

Getting that patient enrolled and set up in the first place is billed on its own, once, under 98975. From there, 98977 is the code that comes back, once for every 30-day period the patient stays on the program.

What CPT 98977 covers

98977 pays for providing the patient the software that records their RTM data, and data transmission across the 30-day period. The software has to meet the FDA's definition of a medical device, so an app qualifies, with no hardware to ship to the patient. What the code will not pay for is the clinician's time reviewing and monitoring what comes in, which is billed on its own through the treatment-management codes.

The 16-day requirement, and how 98977 works with 98985

98977 is the code for a full month of monitoring, and CMS sets that bar at 16 days of transmitted data inside the 30-day period. If a patient submits their data on fifteen days within a 30-day period, the clinic can't 98977.

That changed in 2026. The 2026 CMS final rule introduced 98985, a companion code for musculoskeletal monitoring that runs 2 to 15 days, and it pays the same $51.44 as 98977. The two are mutually exclusive, so a patient in any single 30-day period is billed under one or the other and never both, with the day count making the call: 16 days or more is 98977, 2 to 15 is 98985, and anything under 2 days leaves no device code for the period. Actuvi keeps that count as the data comes in and moves each patient onto the code their data transmission days qualifies them, for easy billing.

Where 98977 fits within the remote therapeutic monitoring (RTM) code set

98977 is one code in a set that runs an episode from start to finish. It opens with a one-time setup under 98975, and from there the device code covers the software for each 30-day period while the treatment-management codes cover the clinical time. The full family looks like this:

Those figures are national averages, and the amount paid depends on Medicare locality and payer.

A billing month for CPT 98977

Take a patient two months into recovery from a knee surgery and still on the program. Over the 30-day period, the app records data on 21 of the days, and the care team puts in 20 minutes reviewing it plus one call to the patient. That month goes out as 98977 for the software and its data, with 98980 added for the first 20 minutes of treatment management. Setup code does not appear again, since it was billed once at the very start of the episode, and from here it is the device and management codes that recur.

Situations where CPT 98977 should not be billed

A few things take 98977 off the table for a given month:

• The patient transmitted on fewer than 16 days, which moves the month to 98985 if it reached at least 2 days, and to no device code below that

• 98985 went out for the same patient in the same 30-day period

• The software does not meet the FDA's definition of a medical device

• The setup and patient consent were never documented

Who can bill CPT 98977

98977 is billed by the providers who deliver musculoskeletal RTM, which in practice is mostly physical therapists and occupational therapists, along with physicians and other qualified providers working within their scope. Chiropractors are not currently covered for RTM under Medicare. Because the code is for device supply, it sits under the supervising provider rather than an assistant, so a PTA or COTA does not bill 98977 directly; their time counts on the treatment-management codes instead, under general supervision and with the CQ or CO modifier.

Required documentation for CPT 98977

A 98977 claim that holds up under review comes down to a handful of records: the FDA-defined software supplied to the patient, proof that data was transmitted on at least 16 days inside the 30-day period, the recorded data itself, and a clear link to an active plan of care. The day count is what a reviewer checks first, since it is what separates 98977 from 98985, so the 30-day windows have to be clean and the transmitted days have to line up with the right period.

How CPT 98977 works on the Actuvi platform

By the time 98977 is in the picture, the patient is enrolled and through onboarding. Across the month, they log their pain, their range of motion, their exercise completion, and more in the Actuvi app and the platform records every day a submission lands. As those days build up, Actuvi puts each patient on the billing page under the code their count supports, ready for 98977 once they pass 16 days and for 98985 in the range below.

Actuvi's app increases patient compliance with in-app streaks and badges, push reminders, and an AI Agent that reaches out by text the moment a patient stops engaging. If someone cannot manage the app on their own, Guardian and Caregiver Access lets a family member/staff submit the data for them. Actuvi is FDA-listed and HIPAA compliant, and a musculoskeletal RTM program can be live within two weeks.

Frequently asked questions

What does 98977 pay in 2026? On the national average, 98977 pays $51.44 for each 30-day period, though the allowed amount varies with Medicare locality and payer.

Does 98977 require a physical device? No. The device in RTM can be software that meets the FDA's definition of a medical device, like an app the patient records data in, so there is nothing to ship or wear.

How is 98977 different from 98985? They differ only on the number of days of data. 98977 covers a full month of 16 to 30 days, while 98985, new for 2026, covers the shorter 2 to 15 day window, and a patient is billed under one or the other in a given 30-day period, never both.

Does 98977 pay for reviewing the data? No. 98977 covers the software and the data transmission. The time a clinician spends reviewing data and reaching the patient is billed through the treatment-management codes: 98979, 98980, and 98981.