The New 2026 RTM Rules: Billing 2–15 Days (98985) & 10–19 Minutes

What changed for RTM billing in 2026?

CMS ended all-or-nothing RTM billing. Through 2025, the thresholds were cliffs: a patient who logged 15 of the required 16 days paid $0 on the device-supply code, and a clinician who reviewed for 19 of the required 20 minutes paid $0 on treatment management. The 2026 Physician Fee Schedule added two codes that turn those cliffs into steps:

98985 covers the musculoskeletal system — the code pediatric therapy clinics use. Its siblings 98984 (respiratory, $52.11, at parity with 98976) and 98986 (cognitive behavioral therapy, contractor-priced) follow the same 2–15-day logic.

The parity isn’t a coincidence or a rounding artifact. Each device-supply pair shares a single practice-expense RVU — 1.54 for the musculoskeletal pair, 1.56 for the respiratory pair — because the resource cost of supplying the platform doesn’t change with how often the patient uses it. That’s why partial-period billing doesn’t cost you anything on the device side.

For clinics, this is a revenue-capture change, not a paperwork change. The patients who fall just short of the thresholds — the moderately compliant middle of every caseload — were previously worth $0 in monitoring reimbursement. Now most of those months are billable. If you need the full code-by-code map first, start with RTM CPT codes explained.

One caveat before you rebuild your projections: payer adoption of new codes varies. Medicare pays them under the 2026 fee schedule; confirm with your MAC and commercial payers before treating them as guaranteed, and verify your locality’s rates on the CMS fee schedule search.

And one that will cost you claims if you miss it: the new codes are “sometimes therapy” services. CMS gave 98979, 98984, and 98985 that designation effective January 1, 2026, alongside the existing RTM codes. When a therapist furnishes them, they’re always under a therapy plan of care and the claim needs a GP, GO, or GN modifier — a correct code with a missing modifier still denies. The assistant modifiers work differently: CQ and CO apply to 98975, 98979, 98980 and 98981, and never to a device-supply code — those represent the patient transmitting data, not work the assistant performed. Which disciplines can bill RTM covers the modifier and supervision rules in full.

When do you bill CPT 98985 instead of 98977?

When the patient transmitted data on 2 to 15 days within the 30-day period. At 16 or more days, bill 98977 as before; at zero or one day, no device-supply code applies. The surprising part is the valuation: 98985 pays at exact parity with 98977 on the 2026 national fee schedule — a partial-logging period doesn’t shrink the device-supply payment, it just routes through a different code.

That makes the practical job code selection, not revenue rescue: you need an accurate day count per patient per 30-day period, so each period lands on the right code the first time.

Worth being precise about what that period is, because it’s the detail most often described wrongly: the 30-day period runs from the patient’s RTM start date, and the next period begins the day the previous one ends. It is a sequence of fixed windows, not a rolling window you can re-measure to find a better 30 days, and it is not the calendar month.

When do you bill CPT 98979 instead of 98980?

When the calendar month’s RTM management time lands between 10 and 19 minutes. At 20 or more minutes, bill 98980 (with 98981 for each additional full 20). The two are mutually exclusive in the same month — one or the other, never both.

Everything else about treatment management carries over:

• The interactive-communication requirement still applies. 98979 needs at least one real-time, synchronous conversation with the patient or caregiver during the month. An audio-only phone call is enough; so is video; so is an in-person conversation at a clinic visit, provided that time isn’t also counted toward the billable visit. Texts, emails, and portal messages don’t qualify.
• The same time rules apply. Count reviewing monitoring data, communicating with the family, and adjusting the program. Don’t count general documentation or other billable services.
• Payment is roughly half of 98980, so the 20-minute threshold still matters — it’s just no longer the difference between paid and unpaid.

Do the 16-day and 20-minute rules still matter?

Yes — they now decide which code you bill, rather than whether you bill at all. The mechanics are unchanged and still worth knowing cold:

• The day count governs the device-supply codes (98976, 98977, 98978 — and now the 2–15-day trio 98984, 98985, 98986). It does not apply to treatment management, a common misreading that causes clinics to skip billable review work whenever a patient’s logging dips. Note 98975 is neither: it’s the one-time setup-and-education code, reported once per episode of care, not per monitoring period.
• A “day” counts once, no matter how many sessions the patient logs that day. A child who does morning and evening sessions and logs both has produced one day, not two.
• A logged missed session can still count. Per APTA’s practice advisory, data indicating a lack of engagement may qualify as a day of transmission — but only if you follow up on it in a timely way. Teach families to log the bad days too, and document what you did about them.
• The clocks differ: device-supply codes run on sequential 30-day periods counted from the RTM start date, while management codes run on the calendar month. Over a multi-month episode the two drift apart by a day or two each cycle, which is why one spreadsheet column eventually produces a claim error. Expect months where a management code is billable well before the device-supply period has closed — a patient who starts on the 26th will hit month-end within a week.
• Each day needs a timestamp. If a payer asks which days qualified, the answer must come from logs, not memory.

What should you bill when a patient falls short?

The decision table, updated for 2026:

The strategic read: the moderately compliant middle of the caseload — patients logging 8–14 days — went from unbillable to billable at full device-supply parity. But the full management code still pays about double the rescue code, so the highest-leverage move is unchanged: surface at-risk patients mid-month, while there’s still time to re-engage the family, not on the 29th when the period is already set. In pediatrics the parent is the logger, so the fix is making logging take seconds — a text-message link beats an app the parent has to remember.

How do clinics track this without spreadsheets?

The 2026 changes make manual tracking harder, not easier: per-patient day counts, each on its own 30-day period starting whenever that patient enrolled, now route to one of two codes; per-clinician minutes per calendar month route to one of three; and every management claim needs a live-communication flag — across an entire caseload, on two clocks that never line up. This is precisely the layer Sulo automates for pediatric clinics: every qualifying day and review minute is counted in the background, patients trending toward 98985 territory get flagged early enough to intervene, and month-end billing comes from an audit-ready report instead of reconstruction. See how the whole loop runs in the RTM guide, check which disciplines can bill these codes in Can PTs, OTs, and SLPs bill RTM?, or follow the step-by-step build in how to start an RTM program.