Learn what CPT code 98985 covers, who can bill it, documentation requirements, and 2026 Medicare reimbursement rates for Remote Therapeutic Monitoring.
Remote Therapeutic Monitoring (RTM) added new billing flexibility for 2026, and CPT code 98985 is one of the additions driving that change. It closes a gap that left many shorter, lower-intensity monitoring periods unbillable under the previous code set.
Here's what practices need to know about the code, how it fits into the broader RPT CPT codes 2026 updates, and what it pays.
What Is CPT Code 98985?
CPT 98985 is a device supply code for Remote Therapeutic Monitoring. It covers the technology used to collect and transmit non-physiological data - things like therapy adherence, pain levels, and functional response - specifically for the musculoskeletal system.
The defining feature of 98985 is its data-transmission window:
- Covers 2 to 15 days of data transmission within 30 days
- New for calendar year 2026
- Applies specifically to musculoskeletal (MSK) monitoring
- Billed once per 30-day episode of care
Before this code existed, MSK device supply billing required at least 16 days of data in 30 days (CPT 98977). Patients who engaged for fewer days - post-op patients in an early recovery window, or those with inconsistent app use - generated monitoring data that couldn't be billed at all.
Where 98985 Fits in the RTM Code Set
RTM now spans eight CPT codes across three categories. Seeing 98985 next to the others makes its purpose clearer:
- Setup and education: 98975 - billed once per episode of care
- Device supply, 2–15 days: 98984 (respiratory), 98985 (musculoskeletal), 98986 (cognitive behavioral)
- Device supply, 16–30 days: 98976 (respiratory), 98977 (musculoskeletal), 98978 (cognitive behavioral)
- Treatment management: 98979 (10–19 minutes), 98980 (first 20 minutes), 98981 (each additional 20 minutes)
The 2–15 day codes and the 16–30 day codes are mutually exclusive for the same condition track in the same 30-day period. A practice bills whichever matches the actual number of transmission days - not both. Tracking which threshold applies is exactly the kind of detail an RTM software platform is built to flag automatically rather than leaving to manual chart review.
Who Can Bill CPT 98985
98985 can be billed by physicians, other qualified healthcare professionals, and - under specific conditions - therapists.
- Physicians and QHPs bill it as part of standard RTM workflows
- Therapists must furnish the service under a documented therapy plan of care
- When a physical therapist assistant or occupational therapy assistant is involved, the appropriate CQ or CO modifier applies if that assistant performed the service
CMS designates 98985 as a "sometimes therapy" code, meaning its treatment depends on which provider type furnishes it. One detail worth flagging for billing teams: the de minimis standard does not apply to CPT 98985. Unlike some other RTM codes, there's no allowance for assistant time to count toward a physician-billed claim under the 10% threshold rule.
Documentation Requirements
Clean claims for 98985 depend on documentation that clearly supports the transmission window and the device's clinical purpose. At minimum, records should show:
- The specific number of days data was transmitted (2–15) within the 30 days
- That the device or software is being used to monitor the musculoskeletal system specifically
- The initial setup and patient education already completed (typically billed separately under 98975)
- That no overlapping claim was submitted under 98977 for the same period
Because 98985 is a device supply code, it does not require real-time interactive communication with the patient - that requirement applies to the treatment management codes (98979, 98980, 98981), not to the supply codes.
2026 Reimbursement Rate for CPT 98985
Medicare's national non-facility payment for CPT 98985 ranges from roughly $40 to $51, depending on the source and locality adjustments applied. Rates are calculated from Outpatient Prospective Payment System cost data divided by the 2026 Physician Fee Schedule conversion factor, and they shift with:
- Geographic Practice Cost Index (GPCI) adjustments
- Facility vs. non-facility setting
- Individual payer contracts, for non-Medicare claims
Because national averages vary by locality and reporting source, practices should confirm exact, location-specific rates using the CMS PFS Look-Up Tool rather than relying on a single published figure.
Why This Code Matters for RTM Programs
The practical effect of 98985 is that it recognizes monitoring that's real but short. A few groups benefit most directly:
- Post-surgical MSK patients in an early recovery window with fewer engagement days
- Patients with episodic conditions, where symptoms and app use fluctuate month to month
- Practices previously losing revenue on partial engagement that fell under the old 16-day threshold
This shift was formalized under CMS's proposed rule, which introduced 98985 alongside its RPM counterpart specifically to reward shorter, clinically real engagement. For programs managing this alongside device-based monitoring, reliable connected health devices matter just as much as code selection - a device that transmits inconsistently undermines even perfect documentation.
Conclusion
CPT 98985 fills a specific, previously uncovered gap in RTM billing: musculoskeletal monitoring that runs shorter than a full month. It doesn't replace 98977 - it works alongside it, with the choice between the two determined entirely by how many days of data were actually transmitted.
For practices running MSK-focused RTM programs, the code represents recovered revenue from engagements that were already happening but weren't billable before 2026. Getting the documentation and mutual-exclusivity rules right from the start - and understanding how it fits into overall RPM and RTM revenue - is what turns that opportunity into clean, audit-ready claims.
FAQ
Can I bill CPT 98985 and 98977 for the same patient in the same month?
No. CPT 98985 and 98977 are mutually exclusive. Use 98985 when the patient transmits data for 2–15 days during 30 days, and 98977 when data is transmitted for 16–30 days within the same billing period.
Does CPT 98985 require a live conversation with the patient?
No. A live patient interaction is not required for CPT 98985. That requirement applies to the RTM treatment management codes (98979, 98980, and 98981), not to device supply codes such as 98985.
Is CPT 98985 only for Medicare patients?
No. While CPT 98985 is recognized by Medicare, Remote Therapeutic Monitoring (RTM) codes are increasingly being adopted by commercial insurers and some state Medicaid programs. Coverage policies vary by payer, so providers should verify reimbursement requirements with each insurer.
How often can I bill CPT 98985?
CPT 98985 may be billed once per 30-day episode of care, provided the patient meets the required 2–15 transmission-day threshold and the code is not billed together with CPT 98977 for the same 30-day period.
What types of conditions are commonly monitored using CPT 98985?
CPT 98985 is primarily used for musculoskeletal conditions that benefit from Remote Therapeutic Monitoring, such as post-operative rehabilitation, chronic back pain, arthritis, joint replacement recovery, sports injuries, and physical therapy programs. It helps providers monitor therapy adherence, pain levels, and functional progress between in-person visits.
Does CPT 98985 require an FDA-approved medical device?
Yes. The device or software used for Remote Therapeutic Monitoring should meet the applicable CPT requirements for collecting and electronically transmitting therapeutic data. Providers should also ensure the technology complies with CMS and payer-specific requirements before submitting claims for CPT 98985.
Can CPT 98985 be billed with RTM treatment management codes?
Yes. CPT 98985 can be billed alongside RTM treatment management codes such as 98979, 98980, and 98981, provided all billing requirements are met. The device supply code covers data collection and transmission, while the treatment management codes reimburse the clinician's time spent reviewing the data and managing the patient's care.