The Monitoring You Already Do, but Don't Bill For
Here is a scenario that plays out in orthopedic practices every day: a patient is two weeks post-TKA. She has been using your practice's app to log pain scores and exercise completion. Your PT reviewed the data, noticed her flexion progress stalling, and called her to adjust the home exercise program. Total time: maybe 12 minutes.
That interaction — the data collection, the review, the clinical response — was worth $77 in reimbursement. But most practices never billed for it, because until January 2026, the remote therapeutic monitoring codes required 16 days of patient data transmission in a 30-day period. That threshold was unrealistic for post-surgical populations, and CMS knew it.
They fixed it. And the fix is significant enough that any orthopedic practice doing post-surgical monitoring needs to understand what changed.
What Changed in 2026
The 2026 CMS Physician Fee Schedule final rule introduced CPT 98985 — a new device supply code for musculoskeletal remote therapeutic monitoring covering 2 to 15 days of data transmission per 30-day period[1].
Previously, you needed CPT 98977, which required 16-30 days of transmission. The clinical reality is that many post-surgical patients — especially in the early recovery window when monitoring matters most — do not reliably transmit data for 16 out of 30 days. The new lower-tier code acknowledges this and creates a billable pathway for exactly the monitoring pattern most practices already see[2].
| CPT Code | Description | Payment | Threshold |
|---|---|---|---|
| 98985 | MSK remote therapeutic monitoring device supply (2-15 days/30-day period) | $51.00 | 2-15 days of data |
| 98977 | MSK remote therapeutic monitoring device supply (16-30 days/30-day period) | Existing rate | 16-30 days of data |
| 98979 | RTM treatment management, first 10 minutes | $26.00 | 1+ real-time interaction |
| 98980 | RTM treatment management, additional 20+ minutes | Existing rate | 20+ cumulative minutes |
Additionally, CMS designated RTM codes as "sometimes therapy services"[5]. This means physical therapists, occupational therapists, and speech-language pathologists can now bill these codes directly. The billing responsibility no longer sits exclusively with the physician.
The Revenue Math
The minimum reimbursement per patient per 30-day period, using the lower-tier codes:
- 98985 (device supply, 2-15 days): $51
- 98979 (treatment management, 10-19 minutes): $26
- Per patient per month: $77
Scale this across your post-surgical volume:
| Monthly RTM Patients | Monthly Revenue | Annual Revenue |
|---|---|---|
| 50 | $3,850 | $46,200 |
| 100 | $7,700 | $92,400 |
| 200 | $15,400 | $184,800 |
These are the floor numbers. Patients with higher engagement (16+ days of data) qualify for 98977 + 98980, which reimburse at higher rates. And these dollars were previously zero — the clinical work was happening, but the revenue capture was not.
What Counts as RTM-Billable Monitoring
CMS does not mandate a specific device or application. What matters is that the data is structured, patient-generated, and digitally transmitted. Within the MSK category, the following activities qualify[3]:
- PROM collection: pain VAS/NRS, functional outcome scores (KOOS-JR, ASES, DASH, etc.)
- Exercise adherence tracking: documented completion of prescribed home exercise programs
- Wound photo submission: structured digital image uploads for incision monitoring
- ROM measurement data: joint range of motion transmitted via app or wearable device
- Structured patient-reported data: daily check-ins, symptom questionnaires, medication adherence logs
If your practice uses any digital platform for post-surgical patient engagement — and the platform captures structured data — you likely already have an RTM-billable data stream. The gap is not clinical. It is administrative.
Billing Rules and Gotchas
The mutual exclusivity rules are where practices will make mistakes. Get these wrong and the claim gets denied[1].
Rule 1: Device supply codes are mutually exclusive. You cannot bill both 98985 (2-15 days) and 98977 (16-30 days) for the same patient in the same 30-day period. If a patient transmits data on 18 of 30 days, you bill 98977 only. If they transmit on 8 days, you bill 98985 only. One or the other, never both.
Rule 2: Treatment management codes are mutually exclusive. 98979 (10-19 minutes) and 98980 (20+ minutes) cannot both be billed in the same period. Time is cumulative across the 30 days. If you spent 22 minutes total on RTM-related activities for that patient, bill 98980.
Rule 3: One set per 30-day period. Each patient gets at most one device supply code and one treatment management code per billing cycle.
Rule 4: Real-time interaction required. The treatment management codes (98979/98980) require at least one synchronous interaction with the patient during the billing period. A phone call counts. A video visit counts. An in-app synchronous message exchange counts. Passively reviewing a dashboard does not.
Rule 5: Documentation. You need to document the number of days data was transmitted, the total time spent on treatment management, and the nature of at least one real-time interaction. Your RTM platform should be generating this audit trail automatically. If it is not, that is a problem you need to solve before you start billing.
The Bigger Picture
The RTM threshold change is not happening in isolation. Three converging forces make this the moment to act.
The TEAM model is live. As of January 2026, 741 hospitals are in CMS's mandatory Transforming Episode Accountability Model — a 30-day bundled payment for joint replacement and other procedures. Hospitals that can monitor patients remotely, detect complications early, and reduce readmissions will outperform their target prices. RTM reimbursement is additive revenue on top of bundle savings.
Outpatient surgery is accelerating. An estimated 51-60% of TKA procedures will be performed on an outpatient basis by end of 2026[6]. Average length of stay for TKA has dropped to 0.89 days. Patients are leaving the hospital faster than ever, and the monitoring gap between discharge and the first follow-up visit is widening.
The evidence base is mature. At AAOS 2026, researchers presented data on 1,699 TKA patients showing that RTM is safe, cost-effective, and validated in geriatric populations[4]. A broader systematic review of 25 RCTs covering 4,402 patients concluded that telerehabilitation outcomes are non-inferior to — and in most comparisons, superior to — traditional in-person therapy.
These three trends are not going to reverse. The question is not whether your practice will do remote monitoring. It is whether you will get paid for it.
How to Start Billing
If your practice is already collecting digital patient data post-surgery, the operational lift is smaller than you think. Here is the practical path:
Step 1: Audit your current data flow. Are you collecting structured, digitally transmitted patient data? Pain scores, exercise logs, PROM surveys? If yes, you already have the clinical substrate for 98985.
Step 2: Verify your platform produces an audit trail. CMS requires documentation of transmission days and clinician time. Your RTM platform needs to generate this automatically — manual tracking will not scale and will create compliance risk.
Step 3: Establish the treatment management workflow. Designate who reviews RTM data (can be a PT, OT, or physician), ensure at least one real-time patient interaction per 30-day cycle, and track cumulative time. This is the basis for 98979/98980.
Step 4: Update your billing codes. Work with your billing team or RCM vendor to add 98985 and 98979 to your charge capture workflow. Ensure they understand the mutual exclusivity rules.
Step 5: Set realistic expectations. Not every patient will hit even the 2-day threshold. Target your highest-volume, highest-engagement patient populations first — post-TKA and post-THA are natural starting points.
The $77-per-patient floor is modest in isolation. At scale — across your entire post-surgical population, compounding monthly — it represents a meaningful new revenue stream built on clinical work your team is already performing.
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