RTM Coding Updates: CPT Code 98975

Remote therapeutic monitoring (RTM) is increasingly part of how healthcare organizations deliver care, particularly for populations with musculoskeletal, respiratory, and other chronic conditions. One key code to understand is CPT 98975—the code used for initial setup and patient education associated with RTM devices and programs. 

As of January 1, 2026, reimbursement, billing thresholds, and code families will change in meaningful ways, creating both opportunities and complexities for healthcare organizations. Below, we break down what 98975 covers, what’s changing in 2026, and how organizations can prepare for smoother billing, stronger documentation, and more scalable RTM workflows.

• CPT Code 98976: Remote Respiratory Monitoring Devices

• CPT Code 98977: Maximizing Reimbursement for RTM Devices

• CPT Code 98980: RTM Treatment Management & Provider Guidelines

• CPT Code 98981: Extended RTM Treatment

What is CPT Code 98975?

CPT 98975 applies to the initial setup and patient education required for remote therapeutic monitoring. When a patient is enrolled in an RTM program that uses a connected device or software, this code reimburses the time spent onboarding the patient and confirming understanding.

Typical activities include:

• Setting up the RTM device or software

• Reviewing the purpose of monitoring and expected benefits

• Educating the patient on how to use the device or platform

• Ensuring the patient can operate the system and transmit data independently

This service is billed once per episode of care, meaning it is not repeated unless a new episode begins. In practice, 98975 is the on-ramp to the RTM journey. Once a patient is successfully onboarded, clinicians can begin billing the device-specific and interactive communication codes that follow.

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What’s changing in 2026—and how it affects CPT 98975

Although the core descriptor of CPT 98975 does not change, the surrounding RTM ecosystem shifts significantly in 2026. The Final Rule adopts new CPT code descriptors, new parenthetical notes, and new minimum-day requirements that modify how organizations structure their RTM programs.¹

Here’s what matters most:

Updated minimum-day requirement for CPT 98975

Beginning in 2026, the CPT codebook introduces a new requirement: To bill CPT 98975, at least two days of RTM data must be collected within a 30-day period. CMS confirmed that it will adopt this change exactly as written in the 2026 CPT manual.¹

This updates the previous alignment with the 16-day standard and makes RTM setup more accessible to:

• Short-term rehabilitation episodes

• Post-surgical care

• Transitional care

• Patients who engage in intermittent or low-volume monitoring

This change expands eligibility to patients who engage for shorter monitoring periods.²

New RTM codes that expand billing flexibility

For 2026, CMS is adopting several new CPT codes that allow clinicians to bill for shorter periods of monitoring and fewer interactive minutes.¹ These codes reshape how 98975 functions within the broader RTM workflow.

New for 2026:

• 98984 – Device supply and data transmission for fewer than 16 days.

• 98985 – Interactive communication for fewer than 20 minutes.

• 98979 – Shorter-duration interactive treatment management.

In addition, 98976, 98977, and 98978 include revised descriptors specifying updated minimum-day requirements.

The result: Clinicians can now bill RTM even when patients participate for as few as two to fifteen days—a major shift that broadens eligibility and supports more flexible monitoring plans.

The current treatment-management codes (98980 and 98981) require 20 minutes of interactive communication per month. In 2026, CPT 98985 will allow billing for interactive communication totaling fewer than 20 minutes per month, offering more flexibility for shorter follow-up sessions.²

How the new RTM codes reshape the role of CPT 98975

Because 98975 is required to begin every RTM episode, these new codes make 98975:

• More frequently usable, since the two-day rule is far easier to meet

• More flexible for varied plans of care and shorter episodes

• More valuable organizationally, because it enables a wider range of monitoring and management codes

Although CPT 98975 itself is unchanged, its context within the RTM code family shifts significantly. Organizations will still use 98975 to initiate an RTM episode, but will now choose among updated monitoring and management codes based on patient engagement and data-transmission duration.

Documentation expectations under the 2026 framework

The new thresholds mean documentation becomes even more important. Organizations must accurately record:

• Device activation

• Education time

• Patient confirmation of understanding

• Initial data transmission

CPT 98975 anchors the episode and verifies that setup and education occurred.³

Strategic opportunities created by the new RTM structure

These adjustments allow organizations to extend RTM to patient populations that previously fell outside the sixteen-day requirement. This includes short rehab episodes, surgical recovery, and other lower-acuity or lower-volume cases.

It’s a meaningful opportunity to expand RTM adoption and improve reimbursement efficiency—as long as onboarding workflows, documentation practices, and staff training are updated accordingly.

Example of CPT 98975 in use

A physical therapist is working with a patient recovering from rotator cuff repair and plans to use remote therapeutic monitoring to track shoulder range of motion and activity levels during early rehab.

Setup and education

During the initial visit, the therapist:

• Sets up the wearable musculoskeletal sensor and connects it to the patient’s mobile app

• Demonstrates how the device collects and transmits data

• Reviews safe use, expected wear time, and what the patient will see in the app

• Ensures the patient can sync the device and submit a test data transmission

• Documents completion of setup, education, and patient demonstration

Once the patient begins transmitting data, the therapist bills CPT 98975 for this one-time setup and onboarding service.

Monitoring and follow-up

Over the next 30 days:

• The patient transmits device data on 12 days—which qualifies for 98984, the new device supply and data-transmission code for fewer than 16 days

• The therapist spends 15 minutes reviewing data trends and providing interactive communication (progress check-in and brief virtual guidance), which qualifies for 98985, the shorter-duration interactive communication code

This workflow demonstrates how CPT 98975 initiates the RTM episode, while the new 2026 codes (98984, 98985, and 98979 where appropriate) give clinicians greater flexibility to bill based on actual patient engagement and time spent.

Preparation and best practices for 2026

1. Revise onboarding workflows

Create a standardized education protocol that covers device setup, data flow, expected monitoring frequency, and patient responsibilities. Ensure staff document each step of the setup and education process, as CPT 98975 requires confirmation that onboarding was completed.

2. Update code selection processes

Develop a clear decision pathway to guide clinicians and billing teams when choosing between existing RTM codes and the new 2026 codes based on the number of data-transmission days and interactive communication minutes. Confirm that EHR and billing systems are updated to support the new CPT codes and revised descriptors.

3. Educate clinical and billing teams

The new minimum-day and communication thresholds require careful tracking. Teams should understand which activities qualify for each RTM code, what constitutes interactive communication, and how to document appropriately under the updated 2026 guidelines.

4. Maintain detailed documentation

Ensure consistent tracking of onboarding time, device activation, patient demonstration of understanding, data-transmission logs, and interactive communication minutes. Accurate documentation is essential for billing across the revised RTM code family.

5. Monitor payer policies

Medicare’s Final Rule sets the national framework, but commercial payers may differ in adoption timelines and coverage criteria. Regularly review payer updates and advocate for consistent reimbursement of RTM services.

6. Integrate RTM strategically

With new flexibility around monitoring days and communication time, RTM can be applied to shorter or lower-acuity episodes. Consider connecting RTM workflows with chronic care management (CCM), transitional care management (TCM), or digital care pathways to maximize clinical and organizational impact.

Ensuring success under the 2026 RTM framework

CPT 98975 remains the essential starting point for every RTM episode of care, but its role becomes even more important under the 2026 framework. With the new two-day minimum requirement and expanded RTM code family, organizations have more flexibility to support shorter episodes, lower-acuity cases, and patients who engage intermittently.

By updating onboarding workflows, documentation practices, code-selection pathways, and team training now, healthcare organizations can ensure smooth adoption of the 2026 RTM updates. When implemented strategically, CPT 98975 serves as the foundation for scalable, data-driven hybrid care—helping clinicians stay connected between visits and enabling organizations to deliver more efficient, patient-centered monitoring.

For organizations looking to operationalize RTM at scale, Medbridge One Care offers a fully integrated digital care platform that supports remote monitoring, patient-reported outcomes, engagement tracking, and plan-of-care adjustments—all in one place. By connecting clinicians and patients through guided digital pathways, One Care enables smarter workflows, stronger clinical oversight, and seamless documentation to support compliant use of RTM codes.

The information presented here is for educational purposes only and is not meant to be interpreted as billing or legal advice. Please consult with your payors and their policies for more information on your requirements for this service. Information provided is sourced from the 2025 APTA Practice Advisory and the 2026 AMA CPT Manual, Professional Edition. 

References

1.  Centers for Medicare & Medicaid Services. (2025, November 5). Medicare and Medicaid programs; CY 2026 payment policies under the physician fee schedule and other revisions to Part B payment policies. Federal Register. https://www.federalregister.gov/documents/2025/11/05/2025-19787/medicare-and-medicaid-programs-cy-2026-payment-policies-under-the-physician-fee-schedule-and-other

2. Brody, M. (2024, November 1). New remote monitoring codes for 2026: EMR/EHR, public policy. AdvancedMD. https://www.advancedmd.com/blog/new-remote-monitoring-codes-for-2026/

3. Nixon, C. (2025, July 18). Remote monitoring in the 2026 MPFS: New codes, old concerns, and a call to action for stakeholders. Nixon Law Group. https://www.nixonlawgroup.com/resources/remote-monitoring-in-the-2026-mpfs-new-codes-old-concerns-and-a-call-to-action-for-stakeholders