Two Things to Settle Before You Forecast
98978 and 98986 have no national rate. Both cognitive behavioral therapy device supply codes are contractor priced, which means your Medicare Administrative Contractor sets the amount, and no published national average applies. CMS finalized that position at 90 FR 49403 over objections from commenters who asked for active pricing, on the grounds that “the technologies for this service are still evolving and there is significant pricing variability.” If you are building a digital therapeutic with a custom digital therapeutics program behind it, your revenue model needs a MAC-specific number, not a national one.
Most of the family sits on the New Technology list. CMS placed the RTM codes it lists at 90 FR 49395, which covers 98975, 98976, 98977, 98979, 98980, 98981, 98984 and 98985, on that list for review once three years of utilization data under the new code structure are available, which the rule puts at April 2030. Valuation is stable for now and explicitly under review later, which is a reasonable input to a build-timing decision.
Choosing the Window: 2 to 15 Days, or 16 to 30
The version of this rule in circulation is often more permissive than what CMS wrote, which is the costly direction to be wrong in.
The final rule is unambiguous. At 90 FR 49397: “The 2 to 15 day codes (99445, 98984, 98985, and 98986) and 16 to 30 day codes (99454, 98976, 98977, 98978) are not additive and are not a base and add-on code structure. Billing practitioners would only bill for one of those codes for the appropriate number of days of data transmission per 30 days.”
One device supply code per patient per 30 days. Not one per condition type, not one from each window. The set is treated as a single choice.
What trips practices up is that two independent decisions get collapsed into one. Condition type decides which of the three families applies: respiratory, musculoskeletal, or cognitive behavioral therapy. Days transmitted decides the window within it. A musculoskeletal patient at 9 days is 98985; the same patient at 20 days is 98977. There is never a month where both are billable.
Before 2026 this was a cliff. The 16-day threshold was all or nothing, so a patient transmitting 12 days generated no device supply payment at all. For a three-week post-surgical protocol, that made RTM a poor fit for the population it was designed around. The 2 to 15 day codes removed the cliff, and what they pay for it is covered in the rate section.
The Time Codes and the Communication They Require
Treatment management works the same way, and CMS says so directly at 90 FR 49397: “the treatment management services describing the first 10 minutes (99470 and 98979) and first 20 minutes (99457 and 98980) of service are also not additive. Billing practitioners would choose the most appropriate code for the time spent that calendar month.” You pick one, not both.
What gets left on the table is what comes next, three sentences later in the same passage: “In instances where more than 20 minutes of treatment management is needed after either 99457 or 98980 is billed, 99458 or 98981 can be used.” So 98981 bills each additional 20-minute increment beyond 98980. A practice operating on the belief that one management code applies regardless of time spent is under-billing its own documented work.
Every treatment management code carries a communication requirement. The rule adopts the CPT language directly: codes 98979, 98980, 98981, 99470, 99457 and 99458 “require a live, interactive communication with the patient/caregiver. The interactive communication contributes to the total time, but it does not need to represent the entire cumulative reported time of the treatment management service.” One live interaction per calendar month, and it counts toward the total rather than sitting outside it.
The 2026 clarification worth knowing is about what qualifies. Commenters asked CMS whether audio-only telephone calls, secure messaging, asynchronous chat, automated bi-directional messaging and AI prompts count toward that interactive communication time. CMS declined to narrow it: “We are not specifying further exclusions for the types of communications that can be had with the patient/caregiver, so long as they meet the CPT specifications.” For anyone designing the engagement layer of a monitoring product, that is a wide door, and it was not obviously open before.
Who Can Bill RTM
Physical therapists, occupational therapists and speech-language pathologists can bill RTM. That much is well covered. The operational half, how the claim actually has to be constructed, is the half that gets it paid.
The mechanism is the “sometimes therapy” designation, and it covers the whole RTM family rather than only the new codes. CMS confirmed at 90 FR 49397 that the new codes 98979, 98984 and 98985 carry the designation “since they are based on RTM codes we designated as sometimes therapy in the CY 2022 PFS final rule.” The original codes were designated first; the 2026 rule extends the same treatment to their new siblings. A therapist can bill across the set, not just the three codes named in the 2026 discussion.
CMS defines what the designation means precisely: these services “can be billed outside a therapy plan of care (POC) by a physician and certain NPPs, when appropriate; and always require a POC therapy modifier when furnished by a physical therapist (PT) or occupational therapist (OT), or by a therapy assistant under the PT’s or OT’s supervision, or speech-language pathologist.”
Read that second clause carefully. When a therapist furnishes RTM, a plan-of-care modifier is not optional; a claim without one is incomplete.
One document appears to say the opposite, and it is worth knowing why. MLN901705, the CMS booklet on remote monitoring, states plainly: “Only physicians and non-physician practitioners eligible to provide evaluation and management services can bill remote monitoring services.” Taken literally, that sentence tells a physical therapy practice it cannot bill RTM at all.
It is a simplification, and the Physician Fee Schedule rule governs. The rule is more specific and more recent, addresses RTM directly rather than remote monitoring generally, and describes in detail how a therapist bills these codes, which would be incoherent if therapists could not. The booklet’s sentence is accurate for remote physiologic monitoring and over-broad as applied to RTM. If a payer or an internal compliance review raises it, the citation that resolves it is 90 FR 49397 and the “sometimes therapy” designation carried forward from the CY2022 final rule at 86 FR 65116.
I flag the conflict rather than quietly picking a side, because a practice that finds that sentence alone will reasonably conclude the program is closed to it.
The Modifier Layer Underneath
The plan-of-care modifier is the first layer. The CY2026 rule names two of them in the context of RTM: GP for physical therapy and GO for occupational therapy. Speech-language pathology services are furnished under their own plan of care and carry the corresponding modifier for that discipline; the RTM discussion in this rule does not address it, so it is governed by the general outpatient therapy modifier rules rather than by anything RTM-specific.
There is a second modifier layer underneath. When a physical therapist assistant or occupational therapy assistant does part of the work, CQ or CO respectively is required on top of the plan-of-care modifier, once the de minimis 10% threshold is met. And there is a distinction here that I have found nowhere except in the rule itself, at 90 FR 49398: the CQ and CO modifiers “apply to the new RTM code 98979. However, the CQ/CO are not applicable to the RTM device codes 98984 and 98985 as they are based on the existing codes 98976 and 98977.” So the assistant modifiers attach to the treatment management code, and not to the two device supply codes named. CMS gives its reasoning, that 98984 and 98985 inherit the treatment of 98976 and 98977, which is the same basis on which those older device codes were handled in CY2022. The rule does not extend the statement to the cognitive behavioral therapy device codes, so treat those separately. This reads narrower than the “sometimes therapy” point above for a reason: there CMS said the new codes inherit the designation from the originals, which invites generalizing. Here it named two codes and gave a basis for those two only. This is the kind of rule that produces a denial nobody can explain three months later.
Talk to us about your RTM coding and modifier logic
PakarPBN
A Private Blog Network (PBN) is a collection of websites that are controlled by a single individual or organization and used primarily to build backlinks to a “money site” in order to influence its ranking in search engines such as Google. The core idea behind a PBN is based on the importance of backlinks in Google’s ranking algorithm. Since Google views backlinks as signals of authority and trust, some website owners attempt to artificially create these signals through a controlled network of sites.
In a typical PBN setup, the owner acquires expired or aged domains that already have existing authority, backlinks, and history. These domains are rebuilt with new content and hosted separately, often using different IP addresses, hosting providers, themes, and ownership details to make them appear unrelated. Within the content published on these sites, links are strategically placed that point to the main website the owner wants to rank higher. By doing this, the owner attempts to pass link equity (also known as “link juice”) from the PBN sites to the target website.
The purpose of a PBN is to give the impression that the target website is naturally earning links from multiple independent sources. If done effectively, this can temporarily improve keyword rankings, increase organic visibility, and drive more traffic from search results.
