Major changes in RTM billing
2026
Now 2-15 days monitoring accepted under new code
Lowered requirements for patient management time, only 10 minutes needed
Broader patient access
Now 2-15 days monitoring accepted under new code
Lowered requirements for patient management time, only 10 minutes needed
Broader patient access
2025
Minimum 16 days monitoring
Minimum 20 minutes management
Limited to consistent engagers
Minimum 16 days monitoring
Minimum 20 minutes management
Limited to consistent engagers
Increased accessibility, new RTM codes
The 2026 RTM code expansion represents the most significant enhancement to remote pain management reimbursement since RTM was introduced in 2022.
Starting January 1, 2026, RTM may be billed for patients who record 2–15 days of monthly data and for 10–19 minutes of management time, instead of the current 20-minute threshold.
These changes may allow RTM services to be billed for a larger number of patients, depending on individual clinical and documentation requirements.
The following section outlines the finalized policy updates and considerations for implementation.
Revised Existing Codes
Codes 98976, 98977, and 98978 now explicitly specify 16-30 days of data transmission per 30-day period, clarifying the distinction between full-month and partial-month monitoring.
What's Changing?
New CPT Codes Effective January 1, 2026
Shorter monitoring windows
98985: Musculoskeletal device supply, 2-15 days of data transmission per 30-day period
Lower time threshold
98979: Treatment management services, 10-19 minutes of interactive communication per month
Why These Changes Matter for Pain Management
1. Lower Engagement Threshold Expands Access
Patients living with persistent pain can have engagement patterns that fall below the 16-day threshold in given months due to illness, travel, improved function, or other life circumstances. These patients can now remain billable.
- Patients with acute pain episodes and variable engagement patterns
- Post-surgical rehabilitation patients with tapering monitoring needs
- Patients experiencing episodic flares in chronic conditions
- Transitional care following procedures or hospitalizations
- Patients new to digital monitoring (trial periods)
2. Shorter Time Threshold Increases Efficiency
The introduction of a 10–19 minute management time option enables brief monthly check-ins that support continuity of care for patients who do not require intensive monitoring every month, while also allowing these interactions to be reimbursed.
Clinical and patient impact
This creates flexibility for both patients and providers and is particularly valuable for:
Stable patients who benefit from light-touch follow-up without unnecessary burden
Younger, tech-savvy patients with straightforward conditions who prefer efficient, digital-first care
Patients transitioning from an initial period of intensive monitoring to less frequent, maintenance-level follow-up
3. "Sometimes Therapy" Designation Expands Provider Eligibility
CMS designated New CPT codes 98979, and 98985 as "sometimes therapy" services.
What this means:
- Can be billed by physicians and non-therapist providers outside a therapy plan
- Can be billed by physical/occupational therapists within therapy plans
- Increases flexibility for interdisciplinary pain teams
Critical Billing Rules for 2026
Engagement Requirements
Codes 98985 cannot be billed if cumulative monitoring is less than 2 days within a 30-day period
Short-duration codes (2-15 days) cannot be billed concurrently with existing 16-30 day supply codes within the same 30-day period
Choose the appropriate tier based on actual patient engagement:
- 2-15 days → Use new codes 98985
- 16-30 days → Use existing codes 98977
Communication Requirements
Code 98979 requires at least one real-time interactive communication with the patient or caregiver during the calendar month.
Critical clarification: Interactive communication must involve live, synchronous, two-way audio interaction.
Text messaging alone does NOT qualify
- Phone call qualifies
- Video call qualifies
- Audio + text together qualifie
This mirrors requirements for existing codes 98980 and 98981.
Patient Populations That May Benefit Most
1. Post-Surgical Patients with Tapering Needs
Example: Total knee replacement patientGreat stories have a personality. Consider telling a great story that provides personality. Writing a story with personality for potential clients will assist with making a relationship connection. This shows up in small quirks like word choices or phrases. Write from your point of view, not from someone else's experience.
1
Post-op
Weeks 1-4
- High engagement
- Daily check-ins
- Use 16-30 day codes
2
Rehabilitation
Weeks 5-8:
- Improving function
- 3x/week check-ins
- Use 2-15 day codes
3
Monitoring
Weeks 9-12:
- Monitoring progression
- Week check-ins
- Use 2-15 day codes
Previously, this patient would become ineligible for billing after week 4. Now, monitoring remains reimbursed throughout the full recovery.
2. Chronic Pain Monitoring with Variable Engagement
Example: Fibromyalgia patient with high disease variability
Some months exceed 16 days of engagement; others fall to 8-12 days due to flares, depression, or life circumstances. These patients can now remain in billable RTM programs continuously rather than cycling in and out. This enables identification of changes faster.
4. Trial/Onboarding Periods
Example: Patient hesitant about long-term RTM
Offer 2-week trial period with 2-15 day code. If successful, transition to full 16-30 day monitoring. Previously, trial periods were not reimbursable.
3. Acute-on-Chronic Pain Episodes
Example: Chronic low back pain patient with acute exacerbation
Intensive monitoring during 2-3 week flare can be billed using new short-duration codes, then return to standard monitoring (or discontinue) based on clinical needs.
Preparing for January 1, 2026: Action Plan
Q4 2025: Pre-Launch Preparation
Billing System Updates
- Add new CPT codes (98979, 98985) to EHR/billing system
- Update billing systems
- Train billing staff on code distinctions
Clinical Workflow Adjustments
- Develop protocols for both 2-15 day and 16-30 day monitoring tiers
- Create documentation templates for 10-19 minute interactions (98979)
- Establish criteria for when to use each code tier
Patient Identification
- Review current patient roster for those who previously didn't meet 16-day threshold
- Identify post-surgical and acute pain populations for expanded access
- Plan outreach to patients previously excluded
Technology Validation
- Confirm RTM platform can track and document 2-15 day engagement periods
- Ensure automated time tracking captures both 10-19 minute and 20+ minute sessions
- Verify system automatically flags which billing tier applies each month
Staff Education
- Train clinicians on "sometimes therapy" designation and eligibility
- Educate care coordinators on interactive communication requirements
- Review live communication standards (no text-only communication)
Are you prepared?
Paindrainer's platform is being updated to support all 2026 code requirements:
Automated tier tracking
System identifies whether patient engagement qualifies for 2-15 day or 16-30 day codes each month
Time-stamped documentation
Captures both 10-19 minute and 20+ minute management sessions with automatic code suggestion
Interactive communication logging
Documents live audio/video interactions to meet CMS requirements
Flexible monitoring protocols
Supports both short-duration and full-month monitoring without manual workflow changes
Compliance dashboards
You can edit colors and backgrounds to highlight features.
Seamless transition support
No practice disruption as new codes go live
Ready to Leverage the 2026 Expansion?
Practices that prepare now will be positioned to delivering better care to more patients.
- See Paindrainer CARE system in action—watch our video now.
- Book a demo of PD Care system
Learn more about RTM fundamentals: Read Part 1 - Why Functional Monitoring Matters
Ready to implement in your practice: Read Part 2 - Implementation Guide
Important Notice: Paindrainer is a Class I medical device intended for activity pacing and therapeutic monitoring. Individual results may vary. The information provided here is for educational purposes and does not constitute medical advice. Healthcare providers should use their professional judgment when implementing RTM programs and selecting patients. All billing and reimbursement information should be verified with payers.
202512_EN033