A useful remote therapeutic monitoring (RTM) program makes the treatment plan visible between visits: whether a patient is following it, how they are responding, and what the treating team needs to do next. Start with that care question before choosing a device or projecting reimbursement. FairPath helps practices organize enrollment, device context, clinical review queues, and time and communication records around the program they operate.
Short answer: Start with one treatment question and the patients it fits. Confirm the device and data pathway, assign a clinical owner and the applicable supervision pathway, then test setup, review and patient contact with a group sized to the team's capacity. Check the service records against the billing requirements before the first claim. Expand when the care process works reliably.
Key Takeaways
- RTM monitors therapeutic adherence and response, not physiologic measurements under a different name.
- A generic portal or exercise library is not automatically a qualifying therapeutic monitoring device.
- Build a care workflow before a billing workflow: data need an owner, a review and an appropriate response.
- Appropriate auxiliary clinical staff and therapy-assistant pathways exist under general supervision; administrative tasks are not automatically management time.
- CY 2026 includes shorter-duration device alternatives and a first-10-minute management alternative; those thresholds are not care targets.
- Medicare does not permit concurrent remote physiologic monitoring (RPM) and RTM billing for the same patient.
- FairPath organizes records and review work; the practice owns the clinical workforce, supervision, treatment decisions and claims.
Pick a treatment question first
RTM captures nonphysiologic information related to treatment. CMS describes data that may be patient-reported through a connected medical device, including treatment adherence and response. The device-supply categories cover respiratory, musculoskeletal and cognitive behavioral therapy (CBT) monitoring. Select patients whose care can use this information between visits, then establish how the team will act on it.
A good starting question is specific enough to guide action. “How is this patient following and responding to the prescribed home exercise plan?” is more useful than “Can we add remote monitoring?” The team should know what information it needs, how often review is clinically appropriate, what will prompt contact and who can decide whether the plan changes.
| Candidate question | What needs to be established |
|---|---|
| Musculoskeletal adherence and response | A treatment plan, qualifying system and clinically useful information between visits |
| Respiratory treatment adherence and response | The therapeutic question and appropriate category—not a substitution for physiologic pulse-ox monitoring |
| Cognitive behavioral therapy response | A suitable therapeutic pathway and category-specific device and service evidence |
| General engagement or reminders | Whether this is ordinary support rather than a qualifying monitoring service |
In the illustrative example used throughout this article, a physical therapy (PT) private practice wants to understand whether patients are completing a prescribed rehabilitation exercise plan and how symptoms and function are responding between visits. The therapist determines suitability and individualizes the plan.
Patient selection includes ability to use the system, willingness to participate and a feasible way to contact the team. RTM does not have Medicare RPM's established-patient requirement, but it still needs an appropriate treatment relationship and a reasonable and necessary service. Explain the purpose, review arrangements, participation expectations and applicable consent and cost-sharing requirements for the patient's payer.
Remote monitoring should not be described as continuous surveillance. Patients need clear instructions about routine questions, urgent changes and emergencies. A notification that arrives outside review hours is not a substitute for the patient's established emergency pathway.
Decide who will do the clinical work
The practice should name the treating professional, define review and coverage arrangements, and separate clinical work from logistics. A physician or nonphysician practitioner (NPP) may use an applicable incident-to arrangement for auxiliary clinical staff working under general supervision. CMS finalized general supervision for RTM services beginning in 2023. The record should show whose clinical service the work belongs to and who handles escalations; personnel must still meet scope, licensure and service requirements.
Eligible physical therapists (PTs) and occupational therapists (OTs) furnish RTM within the therapy plan-of-care framework. Since 2024, private-practice PTs and OTs may use general supervision for physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) furnishing RTM. This pathway does not extend to unlicensed aides.
Name the clinical owner
Choose the applicable service and supervision pathway before launch.
Physician / NPP service
Appropriate auxiliary clinical staff under general supervision.
PT / OT service
Eligible therapist with appropriately supervised PTA / OTA and therapy requirements.
| Activity | Who owns it | What the record should show |
|---|---|---|
| Treatment goal and monitoring decision | Appropriate treating professional | Clinical rationale and individualized plan |
| Setup and education | Appropriate personnel within the service framework | What was taught and whether the patient can use the system |
| Clinical review and patient interaction | Eligible professional or appropriately supervised clinical personnel | Information reviewed, clinical work, communication and time |
| Therapy-assistant work | Appropriately supervised PTA or OTA | Relevant plan of care, supervision and modifier evidence |
| Delivery, scheduling and eligibility checks | Administrative support | Logistics kept distinct from clinical management |
| Claim decision | Billing practice | Code, period, personnel and payer requirements supported by the record |
For these RTM services furnished under a therapy plan of care, GP identifies physical therapy and GO identifies occupational therapy. When assistant involvement meets CMS's applicable threshold, CQ identifies PTA work and CO identifies OTA work. The CY 2026 final rule applies the assistant-modifier policy to new management code 98979 but excludes device-supply codes 98984 and 98985. Plan-of-care and assistant modifiers describe different parts of the service; one does not replace the other.
In the illustrative PT workflow, the therapist owns the plan and clinical decisions. An appropriately supervised PTA may perform permitted work. A coordinator may arrange equipment or appointments, but those minutes do not become treatment management simply because they occurred during the patient's monitoring month. Every recorded activity needs an honest description and a single allocation of time.
Get device and data evidence before enrollment
Ask the vendor to demonstrate the exact system the practice intends to use. A platform that delivers exercises or accepts a check-in may be useful without satisfying the requirements of a particular RTM service. Device qualification, therapeutic category and the actual information pathway need evidence, not a marketing label.
| Evidence | What to inspect |
|---|---|
| Intended use and qualification | Exact product information and support for the applicable medical-device framework |
| Therapeutic category | Why the respiratory, musculoskeletal or CBT category fits the intended service |
| Patient attribution and dates | How information is linked to the correct patient and period |
| Clinical usability | What the team can review and how uncertainty or missing information is resolved |
| Records and continuity | How data, review, communication and transitions are retained and available to the practice |
Run the patient experience before launching. Can the patient access the system? Can they understand what they are being asked to report? Can the clinician distinguish missing information from an actual lack of adherence? Can support staff solve a connection problem without making treatment decisions? Those tests often reveal more than a polished demonstration dashboard.
In the rehabilitation example, exercise reports stop arriving and the assigned team member contacts the patient. If the cause is a login or connection problem, support helps restore the data pathway and the patient demonstrates it again. The gap is recorded as missing information, not assumed nonadherence, and technical troubleshooting stays separate from clinical management.
If the patient instead reports difficulty completing the plan, the information goes to the therapist for clinical review. The therapist decides whether to maintain or adjust the plan or arrange an assessment. The record captures what was reviewed, the patient contact and the clinical work performed. Urgent changes follow the patient's established escalation pathway rather than waiting in a routine queue.
Training should include the patient demonstrating the system and knowing how to reach the practice. Document the monitoring instructions and review arrangements. Have a transition process for discontinuation, hospitalization or a change of treating team so information does not remain in an unattended queue.
How the 2026 codes fit the work
The RTM code structure separates setup, device supply and treatment management. For CY 2026, the short and full device alternatives are based on data days within 30 days. The management codes use a calendar month. The shorter options do not mean a practice should design treatment to reach a minimum threshold and stop.
| RTM service | CY 2026 structure |
|---|---|
| Initial setup and patient education | 98975; CMS adopted a two-day monitoring requirement in a 30-day period |
| Respiratory device supply | 98984 for 2–15 days or 98976 for 16–30 days |
| Musculoskeletal device supply | 98985 for 2–15 days or 98977 for 16–30 days |
| CBT device supply | 98986 for 2–15 days or 98978 for 16–30 days |
| First 10 management minutes | 98979 per calendar month |
| First 20 management minutes | 98980 per calendar month; an alternative to 98979 |
| Each additional 20 minutes | 98981 after the 20-minute base 98980 |
Two clocks in the rehabilitation example
CY 2026 musculoskeletal RTM; other categories have their own device codes.
Device data · 30 days
2–15 days: 98985. Or 16–30 days: 98977.
Management · calendar month
First 10 minutes: 98979. Or first 20: 98980. Additional 20 after 98980: 98981.
98979 is a management code, not a fourth device category. CMS says the first-10- and first-20-minute bases are not additive, and the short/full device codes are not additive either. Additional management units follow the 20-minute base and require their full additional time.
Management includes the required live interactive communication with the patient or caregiver. CMS explains that the conversation contributes to the cumulative total rather than needing to account for every minute. A work record should identify who performed the clinical activity, what was reviewed or communicated, when it occurred and the qualifying time. An automated prompt does not demonstrate that the required live interaction happened.
Device-day minimums are not a 16-day prerequisite for treatment management. In the illustrative musculoskeletal case, 12 qualifying data days would be evaluated under the short device alternative 98985. If the month also contains 22 qualifying management minutes with required live communication and appropriate personnel, evaluate 98980 on its own requirements. That total does not support an additional 20-minute unit and does not permit adding 98979 to 98980.
Medicare does not permit concurrent RPM and RTM billing for the same patient. CMS permits either family, but not both, with chronic care management, transitional care management, behavioral health integration, principal care management and chronic pain management when requirements are independently satisfied and time and effort are not counted twice. Coordinate service ownership and verify applicable CPT, therapy, payer and claim requirements before submission. Medicare Advantage and other payers may differ in coverage, authorization and payment.
Size the first cohort to real capacity
Size the first group around the work the team can actually cover: planned reviews and patient contact, exceptions and useful documentation, without displacing other necessary care.
Estimate protected clinical time, anticipated routine work, variability and coverage. Reserve capacity for escalations and failed contacts. Budget setup, device support and scheduling separately, including any clinical-team time they consume; those resource costs are not automatically treatment-management minutes.
Illustrative capacity calculation: six protected clinical hours minus two hours reserved for exceptions and coverage leaves four hours, or 240 minutes. At an assumed 30 minutes of routine work per patient, that is capacity for eight patients. These are planning assumptions—not CMS targets, a recommended cohort or a calculation of billable minutes. Use the practice's observed workload to revise the estimate.
Scale the proof, not the enrollment count
A practical startup sequence—not a mandated launch calendar.
Question + device evidence
Define the therapeutic purpose and demonstrate the qualifying data pathway.
Review + capacity
Complete a real care loop within protected team capacity.
Records + claims
Audit the service evidence and assess actual adjudicated claims before expansion.
Follow the illustrative rehabilitation patient through the whole cycle: selection, demonstrated setup, data arriving, clinical review, live contact, a decision to maintain or adjust the plan, and a documented next step. Then review the service evidence before billing. A patient enrolled successfully but never reached for required communication is not the same as a completed management service.
Before expanding, review whether patients completed setup, missing reports were traced to a cause and every review item had a named owner. The clinical notes should show how the information informed a decision to maintain or change care. Check that management records contain the required live communication, time is allocated once, modifiers match the personnel involved and actual claims match the documented service.
Expand when that process is repeatable and the team retains capacity for exceptions. If support demand routinely consumes the reserve, adjust the workload before adding patients. Resolve documentation gaps before billing and record only work actually performed; a missing service cannot be created by completing a note. Use those findings to improve how future work is captured as it happens.
Where FairPath fits
| Function | What your team owns | What FairPath records or surfaces |
|---|---|---|
| Selection and enrollment | Medical necessity, treatment plan and patient discussion | Enrollment and consent records |
| Device and data context | Device qualification, training and interpretation | Device information and patient context |
| Review and escalation | Clinical workforce, supervision and authorized decisions | Review queues and clinician-workspace context |
| Time and communication | Appropriate activities, live interaction and single time allocation | Time and communication documentation |
| Claim decision | Code, modifier, period and payer requirements | Billing-review items for human assessment |
The platform does not employ the clinical team, determine the treatment plan or certify a claim. Its role is to keep relevant records and work visible to the people responsible for them.
Common questions
Does RTM require an established patient? Medicare distinguishes it from RPM: RTM does not have RPM's established-patient requirement. The treatment relationship and all other applicable requirements still need to be appropriate.
Can a PT or OT operate RTM? Yes, through the relevant therapy framework, with the plan of care, permitted personnel and applicable modifiers.
Can a generic exercise app qualify? Do not assume so. Evaluate the exact medical-device framework, therapeutic category, data pathway and service evidence.
What should the practice measure before expanding? Review completed care loops, unresolved work, support demand, accurate service records and actual claims. Enrollment and projected revenue alone do not show whether the program is working.
Must every patient have 16 data days? No. CY 2026 provides 2–15-day device alternatives, and management has separate requirements. The clinical plan still determines appropriate monitoring and care.
Related FairPath Guides
Sources
- CMS CY 2026 Physician Fee Schedule final rule, remote-monitoring section: device and management alternatives, communication, setup and therapy policy.
- CMS CY 2023 Physician Fee Schedule final rule, 87 FR 69649: general supervision for RTM.
- CMS CY 2024 Physician Fee Schedule final-rule fact sheet: therapy-assistant supervision in private-practice RTM.
- CMS MLN901705: Telehealth & Remote Monitoring, December 2025, pages 12–13.