2026 CMS Final Rule for Remote Therapeutic Monitoring: What Changed and How to Prepare

The Centers for Medicare & Medicaid Services (CMS) has finalized significant updates to Remote Therapeutic Monitoring (RTM) for 2026. These changes make RTM easier to use, more flexible for different patient needs, and more financially sustainable for practices. Here's what has changed and what providers need to do. 

2026 RTM CPT Codes & Reimbursement 

Note: These are national average payment rates. Actual payments vary by region and billing code. APM (Alternative Payment Model) participants receive slightly higher rates. 

Code Breakdown: 

• 98984 = Respiratory system monitoring 

• 98985 = Musculoskeletal (MSK) system monitoring  

• 98986 = Cognitive behavioral therapy (CBT) monitoring 

• 98976 = Respiratory (existing) 

• 98977 = MSK (existing) 

• 98978 = CBT (existing) 

What Changed 

CMS Adds 2-15 Day Monitoring Codes 

Previously, practices had to collect patient data for at least 16 days in a month to bill for RTM device supply codes. This rigid threshold excluded many patients who could benefit from RTM but couldn't meet the 16-day requirement. 

Starting January 1, 2026, CMS introduced new codes (98984/5/6) for 2–15 days of monitoring, while the existing codes (98976/7/8) now specifically cover 16–30 days. 

What this means for providers 

Practices can now serve patient populations who were previously excluded from RTM benefits: 

• Post-surgical patients who need focused monitoring during their critical 7-14 day recovery window 

• Patients with episodic conditions (flare-ups, acute pain episodes) who benefit from targeted monitoring during symptom changes 

• Medication titration patients who need short-term monitoring while adjusting therapy 

• Transitional care patients being discharged from the hospital who need close monitoring for 10-14 days 

• Trial program participants who want to test RTM before committing to long-term monitoring 

This flexibility is particularly valuable for pain clinics managing chronic pain patients who experience episodic flare-ups. These changes also address the gap between RTM awareness and RTM adoption that many practices have experienced. 

Important: Practices Cannot Bill Both 

Providers cannot bill both the 2-15 day codes (98984/5/6) and the 16-30 day codes (98976/7/8) for the same patient in the same 30-day period. Practices must choose the code that matches the actual monitoring duration. 

Example: 

• Monitor for 12 days → Bill 98985 (MSK, 2-15 days) 

• Monitor for 22 days → Bill 98977 (MSK, 16-30 days) 

• Practices cannot bill both to capture all 22 days 

10-Minute Management Time is Now Billable 

Previously, providers needed to spend at least 20 minutes on RTM management per month to bill for their time. If a provider spent 19 minutes reviewing data and calling a patient, that time went uncompensated. 

Now, practices can bill for interactions as short as 10 minutes using the new code 98979. 

What this means for providers 

Meaningful but brief interactions are now billable: 

• A 15-minute call to discuss therapy adherence 

• A 12-minute review of an alert and care plan adjustment 

• A 17-minute video check-in to assess pain levels and modify exercises 

This reduces uncompensated work and encourages regular patient contact without the pressure to artificially extend conversations to reach 20 minutes. For practices looking to understand how RTM improves patient outcomes compared to traditional methods, this flexibility enables more frequent, targeted interventions. 

How Time-Based Billing Works 

The 10-minute code (98979) can only be used when the total monthly time with a patient is between 10 and 19 minutes. 

Once the total reaches 20 minutes or more in a month, providers must use the 20-minute codes (98980 and 98981) instead. The 10-minute and 20-minute codes are mutually exclusive. 

*Based on 2026 national average rates for non-APM participants. 

Real Example: 90 Minutes of Management Time 

If a provider spends 90 minutes total on RTM management in a month, the practice bills: 

• 98980 (first 20 minutes) 

• 98981 (additional 20 minutes) 

• 98981 (additional 20 minutes) 

• 98981 (additional 20 minutes) 

Total billable: 80 minutes (~$178) 

The last 10 minutes cannot be billed because CPT 98981 requires full 20-minute increments. Practices cannot use the 10-minute code (98979) as a "top-off" when total time exceeds 20 minutes. 

"Sometimes Therapy" Designation 

CMS has finalized a "sometimes therapy" designation for specific RTM codes: 98979, 98984, and 98985. 

When these services are furnished by a therapy assistant (not a therapist or other qualified healthcare professional), practices must apply the appropriate CQ/CO modifiers to the claim. 

• CQ Modifier: Outpatient physical therapy assistant service 

• CO Modifier: Outpatient occupational therapy assistant service 

This is relevant for physical therapy practices using PTAs, occupational therapy practices using COTAs, and rehabilitation clinics with therapy assistant staff. If a licensed therapist, physician, or other qualified healthcare professional provides the service, no modifier is needed. 

Shift to Value-Based Care 

The 2026 RTM changes represent more than just new billing codes. They signal CMS's commitment to value-based care and recognition that remote monitoring is a core component of modern healthcare delivery. 

CMS explicitly stated that the new codes are designed to reduce administrative burden, expand access to remote monitoring, encourage adoption by making RTM financially viable for more practice types, and support value-based care by enabling proactive, data-driven interventions. 

Practices that establish RTM programs now will capture first-mover advantage in their markets, build patient engagement and loyalty, generate new revenue streams, position themselves for success in value-based payment models, and differentiate from competitors still relying solely on in-person care. 

How Actuvi Launches RTM Programs 

Actuvi's digital care delivery platform is specifically designed to help health orgs maximize the 2026 RTM opportunities: 

Step 1: Actuvi Designs the Program 

The health org decides the target patient population, clinical goals to track, and alert thresholds. Actuvi provides ready-to-use assessments along with the option to create custom assessments, monitoring track creation, team role management, and automated workflow configuration. 

Step 2: Actuvi Launches the Program 

The health org introduces the program and has patients download the Actuvi app, then assigns them to a monitoring track. Actuvi handles sending download instructions, importing patients in bulk or one at a time, delivering assessment reminders, sending automated push notifications, tracking all responses, texting non-compliant patients via AI, and documenting all patient communication with timestamps. Actuvi trains the health org team on using the platform, managing alerts, using communication tools, and exporting billing reports. All the health orgs need to do is submit those billing reports for reimbursement. 

Step 3: Ongoing Optimization 

Actuvi provides continued support as the program evolves. Practices can change assessments built on the platform, modify monitoring tracks for any patient at any given point in time, and adjust workflows based on clinical needs. Actuvi provides weekly program reports to help practices track performance and identify opportunities for improvement. 

Actuvi launches your custom RTM program within three weeks with zero IT burden. Schedule a 15-minute demo to see how we would do it for your practice and patient population.