CPT Code 98977: 2026 RTM Billing Guide for PT Clinics

CPT 98977 covers musculoskeletal remote therapeutic monitoring device supply for 16–30 qualifying days within a 30-day period. In 2026, CPT 98985 covers the shorter 2–15-day range. For PT clinics, selecting the correct code starts with documenting the supplied device, qualifying data days, and connection to the therapy plan of care.

What CPT 98977 covers

CPT 98977 reports the device-supply component of remote therapeutic monitoring, or RTM, for musculoskeletal conditions. The service supports monitoring of therapeutic information such as exercise adherence, symptoms, and response to treatment.

The CMS Therapy Code List: 2026 Annual Update, MM14250, published in 2025 and effective January 1, 2026, specifies a 16–30-day monitoring range within a 30-day period. Initial setup and education, and the clinician’s treatment-management work, have separate codes.

For a PT clinic, this means supplying a qualifying monitoring tool is different from spending time interpreting its data or adjusting treatment. Both activities may occur during the same episode, but each must meet its own reporting requirements.

An exercise app does not automatically qualify

APTA’s Practice Advisory: Remote Therapeutic Monitoring Codes Under Medicare, July 2025, explains that RTM can use patient-entered information, but the device must meet the FDA definition of a medical device. Payers may impose additional requirements.

Software can meet that definition, including software running on a mobile platform, as explained in the FDA’s Device Software Functions Including Mobile Medical Applications guidance. A phone app’s availability or ability to display exercises does not, by itself, establish eligibility for 98977.

Ask the platform provider to identify the device or software being supplied and explain how it supports the intended RTM service. Retain that information with your billing documentation.

CPT 98977 vs. 98985: select the code by qualifying days

The 2026 update adds a shorter-duration option for musculoskeletal device supply. CPT 98977 still requires at least 16 qualifying days.

These are alternative codes for the same category of service. Do not report both for the same patient and monitoring period. The coding notes published in ASHA’s CPT and HCPCS Code Changes for 2026 explicitly prohibit reporting 98985 with 98977.

For example, a patient who reaches 12 qualifying days falls in the 98985 range. If the same period ultimately contains 18 qualifying days, the supported device-supply code is 98977. Crossing the threshold does not create a second device-supply service.

Meeting a day threshold establishes only one part of claim eligibility. The device, clinical purpose, provider, and payer requirements still apply.

How to count monitoring days for CPT 98977

Count qualifying dates, not the number of individual entries.

Three symptom reports on one date do not become three monitoring days. Likewise, enrollment for 30 days does not establish 30 days of qualifying monitoring.

The coding instructions describe cumulative monitoring within the period. The qualifying days do not need to be consecutive. Keep a dated record that connects each counted day to the underlying monitoring data.

A useful distinction is the difference between a report of nonadherence and an absence of data. APTA’s 2025 practice advisory explains that transmitted data showing a patient did not complete the prescribed program can qualify as a transmission day. A missing entry should not automatically be treated as equivalent evidence.

Keep the device period separate from the calendar month

Device supply follows a 30-day period. Treatment management follows a calendar month.

For example, an October 12–November 10 device-supply period spans two calendar months. Its qualifying days belong to one device period, while treatment-management time must be allocated to October and November separately.

Your tracking system should display both timelines. A single field labeled “monthly activity” makes it difficult to verify either one.

Who can bill CPT 98977 and which modifiers apply

Physical therapists can report eligible RTM services under Medicare. When a therapist furnishes the service, CMS requires a therapy plan of care and the appropriate therapy modifier.

For physical therapy, that modifier is GP. GO applies to occupational therapy and GN to speech-language pathology.

CMS also distinguishes device supply from services involving assistant time. The CQ and CO assistant-modifier rules apply to specified setup and treatment-management codes, not to 98977. These requirements appear in CMS MM14250, Therapy Code List: 2026 Annual Update.

Provider eligibility also depends on scope of practice, enrollment, setting, and payer policy. An assistant’s participation does not make the assistant an independent billing practitioner.

CPT 98977 reimbursement in 2026

The October 2026 CMS relative value file assigns both 98977 and 98985 a total non-facility value of 1.54 RVUs.

Using the conversion factors in that file produces the following national amounts before geographic adjustments:

These figures are calculated from the CMS Physician Fee Schedule October 2026 release, RVU26D: 1.54 × $33.4009 for non-QPs and 1.54 × $33.5675 for Qualifying APM Participants. They are fee-schedule benchmarks, not guaranteed clinic collections.

Earlier 2026 tables may show different amounts. CMS’s March 12, 2026 correction, CMS-1832-F2, Federal Register document 2026-04797, updated the practice-expense values for 98977 and 98985, with applicability to January 1, 2026.

For your clinic’s estimate, use the CMS Physician Fee Schedule lookup with the relevant year, locality, setting, and clinician status. Commercial payer contracts may use different amounts.

The equal national benchmarks do not make the codes interchangeable. Select the code supported by the documented day count.

How 98977 fits with other RTM codes

Keep the role of each code clear when building the claim.

Treatment-management reporting requires at least one real-time interactive communication with the patient or caregiver during the calendar month. That interaction can contribute to the total time; the entire time requirement does not have to consist of the conversation.

Do not combine 98979 with 98980 or 98981. These time and combination rules are detailed in ASHA’s 2026 coding update.

Reaching the 98977 day threshold does not automatically qualify the patient’s treatment-management service for billing.

What the 2026 changes mean for small PT clinics

The practical benefit is a more specific way to report the service actually delivered:

• A period with 2–15 qualifying days now has an MSK device-supply pathway through 98985.
• A period with 16–30 qualifying days remains within 98977.
• Separate day and time records let the clinic assess device supply and treatment management independently.

This does not establish a reason to enroll every patient or extend monitoring to reach a billing threshold. Monitoring should support the patient’s clinical needs. CMS’s Telehealth & Remote Monitoring booklet, MLN901705, December 2025, identifies medical necessity as a remote-monitoring requirement.

A practical documentation workflow for CPT 98977

Use the following workflow to make the supporting evidence easy to locate.

1. Confirm clinical purpose and coverage. Record why monitoring is appropriate, how it supports the plan of care, and the applicable payer requirements.
2. Identify what the clinic supplied. Record the device or software name, its monitoring function, and the responsible practitioner.
3. Define the monitoring period. Store its start date, end date, and dated evidence for each qualifying day.
4. Keep clinical work in a separate log. Document treatment-management activities, time, decisions, and required communication independently.
5. Review the claim against the record. Match the device code to the day count, check modifiers, and resolve overlapping monitoring services before submission.

For the device-supply review, a compact record might contain:

The point is traceability: another reviewer should be able to connect the selected code to the service and its evidence.

For the broader process, read our 2026 RTM month-end billing workflow for PT clinics, which explains how to bring data days, treatment-management time, and claim documentation together.

Common CPT 98977 billing mistakes

CMS’s Telehealth & Remote Monitoring, MLN901705, states that RPM and RTM cannot be billed together and limits remote-monitoring billing to one practitioner per patient within a 30-day period.

CPT 98977 in practice: three illustrative scenarios

• A patient with knee pain has 18 qualifying monitoring days. The day count supports 98977 if the remaining requirements are met.
• A patient with low back pain has 12 qualifying days. The applicable MSK device-supply range is 98985.
• A patient activates the system but produces only one qualifying day. Neither MSK device-supply code meets its minimum threshold.

In each example, assess treatment-management billing separately from the device-supply decision.

CPT 98977 FAQ

Does CPT 98977 require 20 minutes of clinician time?

No. CPT 98977 is a device-supply code with a qualifying-day requirement. The 20-minute threshold belongs to 98980, a separate treatment-management code.

Do the 16 monitoring days have to be consecutive?

No. The requirement is cumulative qualifying days within a 30-day period. Keep dated evidence for each counted day.

Can CPT 98977 and 98985 be billed together?

No. They represent alternative day ranges for MSK device supply. Report the code supported by the qualifying-day count for the monitoring period.

Can a smartphone app qualify for CPT 98977?

Potentially. The supplied software must meet the relevant medical-device and RTM requirements. A generic exercise app, reminder, or patient portal does not automatically qualify.

Can CPT 98977 be billed with remote patient monitoring?

Medicare does not allow concurrent RPM and RTM billing. Check for an existing monitoring program and coordinate with the other practitioner before submitting a claim.

Turn Your Understanding of CPT 98977 Into a Revenue Opportunity

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