RTM for Occupational Therapy and Chiropractic: A 2026 Guide

Quick Answer: Remote Therapeutic Monitoring (RTM) can support occupational therapy and chiropractic workflows by connecting patient feedback between visits to clinical decisions. Coverage depends on the provider and service: occupational therapists can bill qualifying Medicare RTM services, while RTM furnished by chiropractors falls outside Original Medicare's chiropractic benefit. Begin with a care goal, then verify coverage and billing requirements.

Consider a patient who leaves your clinic with a home program but struggles to follow it. You learn about the difficulty at the next appointment, after days of uncertainty or missed activities. For a small OT or chiropractic practice, the operational challenge is deciding how to collect that information, who will review it, and what should happen next.

RTM provides a framework for connecting information from home to ongoing care. Its usefulness depends on the clinical purpose and the team's ability to respond. Reimbursement requires a separate review.

This guide focuses on musculoskeletal OT and chiropractic practice workflows, with PT as a comparison point. It explains potential uses, practical implementation, and the provider-specific billing distinctions to check before starting.

What RTM Tracks Between Visits

RTM collects therapeutic information such as symptoms, participation in a prescribed program, and response to treatment. A clinician reviews the information and uses it to guide care. CMS describes these nonphysiological data, including patient-reported information, in Telehealth & Remote Monitoring (2025, MLN901705).

For an OT or chiropractic practice considering monitoring, the practical opportunities include:

• Recording difficulties with a home program before the next scheduled visit.
• Giving patient feedback a consistent place in the clinical review process.
• Connecting follow-up decisions to the information that prompted them.

These are workflow capabilities, not promises of better outcomes or additional revenue. Reminders and activity logs become useful when someone reviews them and determines whether follow-up is needed.

For billable RTM, the technology must meet the applicable medical-device requirements. The APTA's 2026 RTM Practice Advisory explains the FDA medical-device definition and the connection to an active therapy plan of care. A messaging app or exercise library does not qualify simply because patients use it at home.

RTM for Occupational Therapy: Connect Home Activities to Functional Goals

For an OT practice, the starting point is the patient's functional goal and the information needed to support it between sessions. AOTA describes this use of monitoring in Remote Therapeutic Monitoring for Occupational Therapy (2023): information about treatment response can inform adjustments between visits.

In an appropriate musculoskeletal case, the OT might want to understand whether symptoms or uncertainty about the prescribed home program are interfering with a daily activity. The useful record explains what the patient reported and how that information affected the clinician's next decision.

An OT workflow should define the monitoring purpose, the information patients will submit, and the clinician responsible for review. It should also distinguish clinical management from reminders, scheduling, and routine technical support.

An Illustrative Hand-Therapy Workflow

This hypothetical example shows a process, not a clinical protocol or a reported patient outcome:

• An OT working with an appropriate wrist-rehabilitation patient connects the prescribed home program to a functional goal, such as managing a dressing task.
• The patient reports difficulty with part of the program through a qualifying platform. The OT reviews the information and contacts the patient to clarify the problem.
• The OT records the clinical assessment and any resulting instruction or plan change. The billing team separately checks whether the delivered services meet reporting requirements.

A hand or wrist diagnosis alone does not establish RTM eligibility. The monitoring must fit the plan of care, technology, provider scope, and patient's coverage. Our RTM patient eligibility checklist is written for PT clinics, but its screening questions can help an OT practice structure its own review.

RTM for Chiropractic Practices: Plan Follow-Up and Verify Coverage

For a chiropractic practice considering between-visit monitoring, first define what patient information would be useful within the clinician's scope of practice. For example, a workflow could collect reported symptoms or difficulty following an already prescribed home program, then route that information to the clinician responsible for follow-up.

The practice needs a review schedule and a clear response process. A stream of patient entries adds little operational value if no one owns the next action.

One hypothetical process is to ask a patient to report difficulty with prescribed activities, review those reports before the next appointment, and contact the patient when clarification is needed. Whether that process qualifies as billable RTM depends on the technology, actual service, rendering provider, and payer. It should not be presented as an established reimbursement pathway for chiropractors.

Original Medicare Has a Specific Chiropractic Limitation

CMS Chiropractic Services guidance (updated 2026) limits coverage to spinal manipulation to correct a subluxation. CMS coverage article A57889 states that other diagnostic or therapeutic services furnished or ordered by a chiropractor are not covered.

RTM furnished as a chiropractic service therefore falls outside Original Medicare's chiropractic benefit. Clinical usefulness and software availability do not change that limitation.

Commercial plans require their own provider-specific coverage review. In a multidisciplinary clinic, eligibility depends on the professional who actually furnishes the service and meets the applicable requirements. Having an eligible clinician on staff does not make every clinic service billable under that clinician's credentials.

How OT and Chiropractic Differ From PT Under Medicare

PT provides a useful comparison for OT billing, but it is not a universal template for rehabilitation practices.

The therapy requirements follow CMS Therapy Code List: 2026 Annual Update (2025, MM14250). The chiropractic distinction follows the CMS coverage guidance above. A patient's commercial coverage must be checked separately.

The Billing Essentials for Musculoskeletal RTM in 2026

For eligible OT and PT services, the relevant musculoskeletal RTM code family is shared. These short descriptions summarize reporting paths, not complete CPT descriptors. The table does not establish coverage for a chiropractor.

CMS MM14250 (2025, effective January 1, 2026) explains the therapy-code changes. The APTA's 2026 advisory describes 98975 as requiring device activation and at least two days of cumulative monitoring within a 30-day period. Enrollment alone is insufficient.

Keep device-supply periods separate from calendar-month management totals. Do not combine 98985 with 98977 for the same monitoring period, or 98979 with 98980 or 98981. Code 98981 is an add-on to 98980. Management reporting also requires the qualifying real-time patient or caregiver interaction; the full management total does not need to consist of conversation time. See ASHA's 2026 CPT reporting notes.

OTA and PTA Participation

For Medicare, OT uses GO and PT uses GP. CO identifies qualifying OTA involvement; CQ identifies qualifying PTA involvement. Under CMS MM14250, codes 98975, 98979, 98980, and 98981 are subject to the assistant de minimis policy. Device-supply codes 98976, 98977, 98984, and 98985 are not.

The rule generally concerns an assistant independently providing more than 10% of the applicable service or unit. Any participation does not automatically require the modifier. Follow CMS's code-specific CQ/CO calculation examples, rather than applying one percentage across all monthly services.

The CMS CY 2025 Physician Fee Schedule Final Rule fact sheet (2024, CMS-1807-F) confirms general supervision for both OTAs and PTAs in private practice for applicable therapy services. State scope and other payer requirements still apply.

How to Introduce Monitoring in a Small Practice

Build a process the team can carry out consistently. These are implementation suggestions, not additional CMS requirements.

1. Choose a clear care purpose. Identify what information from home would help the clinician make a decision.
2. Verify feasibility before enrollment. Check patient participation, qualifying technology, provider eligibility, coverage, and any required consent or cost-sharing discussion.
3. Assign a clinical owner. Specify who reviews patient information, responds to difficulties, and records the resulting decisions.
4. Explain the process to patients. Show what to submit, when the team reviews it, and how follow-up will happen.
5. Review both care delivery and reporting. Check whether the information was useful, whether follow-up occurred, and whether any proposed claim is supported.

For eligible services, our 2026 month-end RTM billing workflow provides a more detailed operational reference. OT clinics should adapt its PT-oriented examples and modifiers to their own services.

Common Implementation Problems and Practical Fixes

These are workflow suggestions. The Medicare therapy-modifier distinctions follow CMS MM14250.

Frequently Asked Questions

Can occupational therapists bill for RTM?

Yes. OTs can bill qualifying Medicare RTM services under an OT plan of care, using the appropriate modifiers and meeting code and coverage requirements. CMS Therapy Code List: 2026 Annual Update, MM14250 describes the therapy framework.

Can chiropractors bill Original Medicare for RTM?

RTM furnished as a chiropractic service falls outside Original Medicare's limited chiropractic benefit. Commercial plans and services actually furnished by another eligible professional require separate assessment. The basis is CMS's chiropractic coverage limitation.

Do OT clinics need different RTM codes from PT clinics?

Eligible musculoskeletal OT and PT services use the same relevant code family. The therapy modifier differs: GO for OT and GP for PT. Select the service code based on the care and monitoring actually delivered.

Does sending a home exercise program count as RTM?

Sending instructions alone does not establish a billable RTM service. The record must support the particular service claimed, including qualifying technology and applicable monitoring, management, communication, and documentation requirements. The APTA's 2026 RTM advisory explains those distinctions.

Does any OTA involvement require the CO modifier?

No. Apply the relevant assistant-reporting rules to the specific service or unit. CMS's CQ/CO guidance distinguishes independent assistant work from work performed together with the therapist and explains the de minimis calculation.

Is RTM considered telehealth?

Not under Medicare's statutory telehealth benefit. The CY 2026 Medicare Physician Fee Schedule Final Rule (2025, CMS-1832-F), clarification on DMHT/RPM/RTM, places RTM outside section 1834(m) and states that a telehealth place of service is not used under the current regulation. Check other payers' claim instructions separately.

See How Between-Visit Care Could Fit Your Practice

For an OT or chiropractic practice, the next step is to connect the home program, patient feedback, and clinical review in a workable process. PhyxUp AI brings clinical documentation, home-program creation, and between-visit monitoring into one workflow, with billing support for qualifying services. Licensed clinicians retain responsibility for care decisions.

Educational information, not individualized billing or legal advice. Requirements vary by setting, state, and payer.