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CPT 98980: RTM Treatment Management Billing Rules (2026)

CPT 98980 covers the first 20 minutes of remote therapeutic monitoring treatment management each month. See the 2026 billing rules, documentation, and how it pairs with 98979 and 98981.
October 28, 2026

Key takeaways

• CPT 98980 is the Remote Therapeutic Monitoring (RTM) treatment management code for the first 20 minutes of clinician time in a calendar month, including time spent reviewing patient data and communicating with the patient.

• Billing CPT 98980 requires at least one live, two-way interactive conversation with the patient or caregiver by phone, video, or in person. Texts and emails do not count.

• CPT 98980 is billed once per calendar month. Report either 98979 or 98980 for a patient in a given month, not both.

• Physical therapists, occupational therapists, speech-language pathologists, and physicians can bill CPT 98980, and PTAs and OTAs can provide the service under general supervision.

Remote Therapeutic Monitoring CPT® Code 98980: Monitoring/Treatment Management Services, First 20 Minutes

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The 2026 Medicare Physician Fee Schedule expanded the remote therapeutic monitoring (RTM) CPT code set. For musculoskeletal (MSK) care, there are now six codes: one for setup, two for device supply, and three for treatment management

In this blog, we'll cover CPT Code 98980, it's billing requirements, who can bill, when to document and how it fits with 98979 and 98981.

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CPT 98980 at a glance

Treatment management
What it coversRemote Therapeutic Monitoring treatment management, first 20 minutes in a calendar month
RequiresAt least one live interactive communication with the patient or caregiver during the month
Who can billPhysicians and qualified health care professionals, including PTs, OTs, and SLPs. PTAs and OTAs can furnish services under general supervision.
Billing frequencyOnce per calendar month, at the end of the month
Related codes98979 (10 to 19 minutes) and 98981 (each additional 20 minutes)
2026 national Medicare rate$54.11
National average for non-qualifying APM participants. Rates vary by locality and payer. Source: CMS Medicare Physician Fee Schedule, 2026. For informational purposes only; not billing or legal advice.

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Code Description

Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes.

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How to Choose Between 98979, 98980 or 98981

According to the American Medical Association, 98980 and 98981 are not reported for less than 20 minutes. Starting in 2026, 98979 covers months with 10 to 19 minutes, so shorter months no longer go unbilled. Because 98979 and 98980 both describe the first block of time, report only one of them in a given month

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What counts toward the time?

  • Reviewing and interpreting the patient’s transmitted data, such as exercise adherence and pain scores
  • Live interactive communication with the patient or caregiver about their program
  • Adjusting the home exercise program or plan of care based on that data

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What is interactive communication?

  • Phone Call
  • Two-way audio-video (for example, FaceTime, Zoom, or Microsoft Teams)
  • An in-person conversation, as long as that time is not also counted toward therapy services billed that day

Text messages and email do not qualify because they are not real-time. In the 2026 Final Rule, CMS was asked whether secure messaging, asynchronous chat, and AI prompts could count. It deferred to the CPT requirement for a live, interactive communication. Evaluate any communication tool for HIPAA compliance.

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Who Can Bill 98980

According to the Centers for Medicare & Medicaid Services (CMS), the CPT® codes for RTM can be billed by “physicians and other eligible qualified healthcare professionals.” This includes the following clinicians:

  • Physicians
  • Physical Therapists
  • Occupational Therapists
  • Speech Language Pathologists

The 2024 CMS Final Rule brought clarification to the rules of General Supervision. This important provision allows Physical Therapists and Occupational Therapists in private practice to provide general supervision for RTM services furnished by their PTAs and OTAs, respectively. This supports RTM management services to be performed outside of the clinic, which is instrumental to providing comprehensive at-home support for patients.

Only one practitioner can bill RTM CPT code 98980 in a 30-day period, even if the patient has been provided multiple medical devices from multiple practitioners.

In all cases, providers must practice in accordance with applicable state and scope of practice laws.

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Is a CQ or CO modifier needed for RTM?

If CPT codes 98975, 98979, 98980, and/or 98981 are provided in whole or in part by a physical therapist assistant (PTA) or an occupational therapy assistant (COTA), you will need to append the CQ or CO modifier respectively to those codes on the claim form. These codes are subject to the de minimis standard and the reduced payment rate for assistant-furnished services. The modifiers do not apply to the MSK device supply codes, 98977 and 98985.

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Billing Frequency: Calendar Month vs. 30-day Period

  • 98980 (and 98979, 98981): billed once per calendar month, at the end of the month.
  • 98977 and 98985: billed per 30-day period of device supply, which often does not line up with the calendar month.

Because the periods differ, you can bill treatment management for a calendar month even when the device supply code for an overlapping 30-day period can’t be billed.

Day-count requirements apply only to the device supply codes. Starting in 2026, 98985 covers 2 to 15 days of data in a 30-day period and 98977 covers 16 to 30 days. Neither can be billed for fewer than 2 days. Treatment management codes like 98980 are based on time, not days of data, as CMS clarified in the 2024 Final Rule.

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Clinical Example for billing 98980:

During March, a physical therapist spends 15 minutes reviewing a patient’s home exercise data and pain scores. Then the PT calls the patient for 10 minutes to talk through theresults and adjust their exercises.

  • Total time for the month: 25 minutes
  • Interactive communication: Yes, one phone call

That’s more than 20 minutes with a live conversation, so the PT bills 98980 at the end of March.

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Required Documentation for 98980:

  • Document the date and minutes that the therapist or assistant analyzed the transmitted data
  • Document the date and minutes of each interactive communication with the patient and/or caregiver, the format of the interactive communication, and what was discussed during each interactive communication
  • Document any changes to the plan of care because of the data analyzed and/or patient/caregiver interactive communication(s)

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RTM CPT Code Questions?

Created alongside clinicians and experts in billing and compliance, Limber Health's RTM Billing & Coding Guide offers an in-depth look at all of the Remote Therapeutic Monitoring CPT codes, best practices for billing and documentation and answers your frequently asked questions. Click the button below to download your free copy of the guide.

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The information provided here about the Remote Therapeutic Monitoring CPT Codes is for informational purposes only and does not constitute billing or legal advice.

Frequently asked questions

How many minutes does CPT code 98980 require?

CPT code 98980 requires 20 minutes of Remote Therapeutic Monitoring (RTM) treatment management time in a calendar month, plus at least one real-time interactive communication with the patient or caregiver. Qualifying time includes work such as reviewing pain and exercise adherence data and talking with the patient about their program. At 19 minutes, 98980 does not qualify.

What if I spend less than 20 minutes on treatment management?

Starting in 2026, CPT code 98979 covers 10 to 19 minutes of Remote Therapeutic Monitoring (RTM) treatment management in a calendar month, and it also requires at least one real-time interactive communication with the patient or caregiver. For a given patient in a given month, bill 98979 or 98980, not both. Below 10 minutes, neither code is billable.

What counts as interactive communication for CPT code 98980?

A phone call or two-way audiovisual communication, such as FaceTime, Zoom, or Microsoft Teams, counts as interactive communication. Text messaging and email do not qualify. Evaluate any communication tool for HIPAA compliance.

Does CPT code 98980 require 16 days of data?

No. In the 2024 Final Rule, CMS clarified that the 16-day data requirement does not apply to Remote Therapeutic Monitoring (RTM) treatment management services. Data day thresholds apply to the device supply codes instead, such as 98977 for 16 to 30 days and 98985 for 2 to 15 days.

How often can CPT code 98980 be billed?

CPT code 98980 may be billed once per calendar month, at the end of the month. If you provide additional treatment management time beyond the first 20 minutes, add CPT code 98981 for each additional 20 minutes. 98981 can only be billed after 98980.

Can a PTA or OTA provide treatment management for Remote Therapeutic Monitoring (RTM)?

In most states, yes. The 2024 CMS Final Rule allows physical therapists and occupational therapists in private practice to provide general supervision for RTM services furnished by their PTAs and OTAs. When a PTA or OTA provides all or part of the service, append the CQ or CO modifier to 98980. State practice acts still apply, and some states restrict PTAs from furnishing RTM services, so confirm the rules in your state.

Can more than one provider bill CPT code 98980 for the same patient?

No. Only one practitioner can bill Remote Therapeutic Monitoring (RTM) treatment management codes (98979, 98980, and 98981) for a patient in a calendar month, even if the patient has been given medical devices by more than one practitioner.

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