RTM Frequently Asked Questions (FAQ) - 2026 Edition

The RTM CPT codes have opened up new possibilities for many providers, and with the 2026 updates, those opportunities have expanded significantly. Alongside those possibilities, there are many questions. We've collected some of the questions we've most frequently received related to RTM to help you navigate these billing codes and workflows.

General Questions

What is Remote Therapeutic Monitoring (RTM)?

Remote Therapeutic Monitoring (RTM) is a set of CPT codes that allow healthcare providers to bill for monitoring and managing patients remotely if using medical devices or software solutions that meet the FDA definition of a device (SaMD) that collects non-physiological data. At this time, these codes are covered by Medicare, Medicaid, and many private insurance plans.

RTM is designed for conditions affecting the musculoskeletal and respiratory systems, as well as behavioral health, and enables clinicians to track therapy adherence, therapy response, and other patient-reported health data. It is particularly useful in settings where continued monitoring of a patient's adherence and progress can help guide interventions.

Note: RTM is different from Remote Patient Monitoring (RPM), which collects physiological data such as blood pressure or heart rate. RTM focuses on monitoring non-physiological data including patient-reported outcomes and adherence to treatment plans and can enhance patient engagement, improve clinical decision-making, and support remote interactions between patients and providers.

Why is RTM important?

RTM is important because it provides providers with a preventative healthcare tool to help patients improve their healthcare outcomes. Through digital check-ins and patient-reported data, care teams can adjust plans sooner. When payer requirements are met, RTM CPT codes allow eligible providers to bill for remote monitoring and management.

As medical devices and the possibilities for patient-reported data continue to evolve, many organizations are expanding their use of remote monitoring to complement in-person care. The creation and expansion of the RTM codes reflect CMS recognition of the value of remote support between visits.

How can Actuvi help with RTM?

Actuvi provides a full solution to be able to have an RTM program within your organization. Providers can enroll patients and assign them care pathways that include assessments, videos, etc. Once assigned, providers can track patient participation in assigned assessments, review patients' responses, update and modify assessments for remote treatment, and facilitate communication between the patient and their care team, all from within the Actuvi RTM platform.

Actuvi's platform automates time tracking for billing compliance and generates billing reports for logged activity. The platform integrates with EHR and EMR systems to streamline workflows and includes AI agents to increase patient engagement with remote programs. If you're interested in using the Actuvi RTM platform at your organization, learn more at https://dub.sh/digitalcare

Does Actuvi meet the FDA requirements for a medical device as described in the RTM CPT codes?

Yes! RTM codes require that any device used for monitoring must meet the FDA's definition of a medical device. Actuvi is a registered platform on the FDA and meets the requirements as a Software as a Medical Device (SaMD).

Is Actuvi HIPAA compliant?

Yes. Actuvi is both HIPAA and GDPR compliant.

Does RTM replace in-person visits?

No, RTM is not intended to replace in-person visits. RTM serves as an adjunct to in-person care, helping you get more information about your patients between visits. It is for preventative care and providing better care and better outcomes, but that should not replace the in-person experience.

Will patients have to pay a copay for RTM services? How can I communicate that to patients?

It depends.

If a patient's insurance has a patient responsibility (i.e., copay or coinsurance), then patients receiving RTM services may need to pay for those services just as they would for any other therapy services they receive, such as manual therapy or therapeutic exercise services. For example, for Medicare, there is a 20% coinsurance for all services rendered by the provider, and RTM would fall under this. The patient or a Medicare Advantage plan would be responsible for 20% of the reimbursed amount for the RTM codes.

We recommend communicating that to your patients in the same way you would any other copayment by explaining the patient's plan of care, stating that it includes RTM services, and that depending on what their insurance provider reimburses, they may need to pay a copayment.

Billing Questions

Who can bill for RTM?

RTM is available to all qualified healthcare practitioners who are not eligible to independently bill for evaluation and management. This includes PTs, PTAs, OTs, COTAs, and more.

What are the RTM codes?

As of January 1, 2026, there are 10 CPT codes for RTM:

• Device Set Up (CPT Code 98975)

• Patient Data Transmission (2-15 days) (CPT Codes 98984, 98985, and 98986) - NEW FOR 2026

• Patient Data Transmission (16-30 days) (CPT Codes 98976, 98977, and 98978)

• Treatment Management (CPT Codes 98979, 98980, and 98981)

What changed for RTM codes in 2026?

The 2026 CMS Physician Fee Schedule Final Rule introduced significant updates to make RTM more accessible and practical for providers:

New CPT Codes Added:

• 98979: Treatment management services for the first 10-19 minutes per calendar month

• 98984, 98985, and 98986: For patients who transmit data on 2-15 days within a 30-day period

These new codes lower the threshold for billing RTM services, allowing providers to get reimbursed for monitoring patients who may not meet the previous 16-day requirement. This is particularly helpful for patients with lower engagement levels, short-term monitoring needs, or those starting RTM late in a billing period.

Are the RTM codes subject to multiple procedure payment reduction ("MPPR")?

No. CMS designated the RTM codes as "sometimes therapy" codes, which means that while they will count towards the annual therapy threshold, MPPR will not apply.

Can you bill for RPM and RTM for the same patient in the same month?

No. According to CPT guidelines, RTM and RPM codes should not be reported for the same patient in the same month. They are distinct services, and billing them concurrently is viewed as duplicative. You must choose the appropriate set of codes based on the primary nature of the monitoring (physiological vs. non-physiological) for that billing period.

Can you bill for Advanced Primary Care Management (APCM) and RTM for the same patient in the same month?

Yes! Unlike RPM, the 2026 Physician Fee Schedule allows RTM to be billed concurrently with Advanced Primary Care Management (APCM) services, provided that the specific requirements for each service are met independently. RTM is not considered duplicative of APCM, so you may enroll patients in both programs if clinically appropriate.

If my patient starts towards the end of the month and I am not able to record 16 days of activity to bill for 98976/98977/98978 (Patient Data Transmission), can I still bill for 98979/98980/98981 (Treatment Management)?

Yes, you should be able to bill for 98979, 98980, or 98981 if you meet the time requirement. The treatment management codes are independent of the 16-day data collection requirement.

Additionally, with the new 2026 codes, if your patient transmits data on 2-15 days, you can bill for the Patient Data Transmission codes for 2-15 days (98984, 98985, or 98986) instead.

Does 98975 (Device Set Up) require 98976/98977/98978 (Patient Data Transmission) to be fulfilled to be billed?

98975 refers to the provider setting up the device, educating, and setting expectations for use of the device with the patient and caregivers. Once the patient logs in and sets up their device, they have the ability to use the device, so the code starts to become eligible. Once the billing period has concluded, you can bill for 98975.

Patient Data Transmission codes (98976, 98977, 98978, 98984, 98985, and 98986) require data to be transmitted on the specified number of days (either 2-15 days or 16-30 days) within a 30-day period. Therefore, the patient needs to log in to Actuvi and complete some activity in order for a day to be counted towards the threshold. You can bill for the appropriate data transmission code once the patient has provided data on the required number of days within the 30-day period.

Does 98979/98980 (Treatment Management) require 98975 (Device Set Up) or patient data transmission codes to be fulfilled to be billed?

The treatment management codes (98979, 98980, 98981) are independent of 98975 and the patient data transmission codes. In the 2024 Physician Fee Schedule Final Rule, CMS stated: "We would like to offer clarification that the 16-day data collection requirement does not apply to CPT codes...98980, and 98981. These CPT codes are treatment management codes that account for time spent in a calendar month and do not require 16 days of data collection in a 30-day period."

This same principle applies to 98979, the new treatment management code added for 2026.

Note that this clarification impacts Medicare, but if you're billing other payers, you will need to check with that payer's coverage policies.

Can I bill both the 2-15 day patient data transmission codes and the 16-30 day patient data transmission codes in the same period?

No. The Patient Data Transmission codes for 2-15 days (98984, 98985, 98986) cannot be billed with the Patient Data Transmission codes for 16-30 days (98976, 98977, 98978) in the same 30-day period. You must choose one code per patient per 30-day period based on the patient's actual engagement level.

Can I bill both 98979 and 98980 in the same month?

No. You cannot bill both the 10-minute treatment management code (98979) and the 20-minute treatment management code (98980) in the same calendar month. You must choose the code that reflects your total time spent:

• If you spend 10-19 minutes, bill 98979

• If you spend 20-39 minutes, bill 98980

• If you spend 40 minutes or more, bill 98980 plus 98981

For any questions on RTM or to launch your RTM program with Actuvi's award-winning platform, book a call with our digital care expert - https://dub.sh/digitalcare