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A practical guide to CPT code 98985, the 2026 RTM device supply code for 2–15 days of monitored data, billing rules, documentation, and reimbursement.
CPT code 98985 is one of the most operationally useful additions in the 2026 RTM update. It opens up a billing pathway for monitoring windows that previously didn’t qualify under any device supply code. Think of patients whose engagement was real but didn’t reach the old 16-day threshold in a 30-day window. The old structure left these short-engagement patients in a billing dead zone.
This article walks through how CPT code 98985 works in practice. It covers what counts as a monitored day, when shorter monitoring is clinically appropriate, and how 98985 pairs with the other five RTM codes.
CPT code 98985 is CMS recognizing a clinical reality: RTM doesn’t have to be a daily, all-month commitment to be valuable. Shorter monitoring windows produce useful data and deserve reimbursement when patients are genuinely engaged with their plan of care.
The practical reality this addresses is familiar in rehab clinics. Patients in late-stage rehab, acute injury recovery, or tapering monitoring programs often generate 6, 9, or 12 days of data in a 30-day window. That’s meaningful engagement that informs treatment decisions but falls outside the old billing window. The broader impact is that clinics can now design RTM programs around clinical need rather than around the 16-day threshold.
A monitored day is a calendar day on which the patient transmitted data through the qualifying RTM platform. Not enrollment days, not days the platform sat open without input, not days the clinician logged into the dashboard. The patient has to actually transmit something for the day to count.
A few common confusions are worth clarifying. A single transmission generally registers the day, even if brief. Missed days within the 30-day window create gaps that affect the threshold count. There’s no rolling average or partial credit. Partial-day transmissions count if the platform logs them.
Monitored-day counting is where most CPT code 98985 billing mistakes originate. Clinics that don’t track transmissions in real time often miscount at the close of the 30-day period. They either submit 98977 when the patient generated 14 days (denial) or miss 98985 entirely because no one realized the threshold had been met.
Clinics bill CPT code 98985 on a 30-day rolling period from the date of enrollment, not on a calendar month. A patient enrolled on January 12 has a window running through February 10. A patient enrolled on March 23 has a window running through April 21. The billing clock starts when the patient starts, regardless of where that falls in the calendar.
This 30-day clock runs independently from the calendar-month clock that the management time codes (98979, 98980, 98981) use. The two timelines run in parallel and don’t need to align. That means clinics tracking RTM billing manually have two separate timelines to manage for every patient.
CPT code 98985 fits specific clinical scenarios: short episodes of care, acute injury recovery, late-stage rehab where daily monitoring isn’t needed, and tapering programs where engagement intentionally drops as patients improve.
The code supports honest clinical judgment about monitoring intensity. Clinics don’t have to keep patients on intensive monitoring just to clear the 16-day threshold. If the appropriate decision is to scale back as a patient nears discharge, 98985 lets that happen. The clinic doesn’t lose the ability to bill for the device supply. The flip side: 98985 should reflect actual clinical decisions, not workflow gaming to capture revenue on patients who simply disengaged.
The either/or rule is simple. 98985 covers 2–15 monitored days in a 30-day period, and 98977 covers 16 or more days in that same period. Clinics can bill only one per patient per 30-day window. There is no scenario where both apply.
The critical mechanic is that the choice isn’t optional. The actual transmission count at the close of the 30-day period determines it, not which code the clinic prefers or which reimburses more.
The most common denial pattern under the pre-2026 structure was billing 98977 for patients who only generated 12 or 14 days of data. That was close to the threshold but not over it. CPT code 98985 exists specifically so that scenario now has a clean billing path instead of a denied claim.
Clinics cannot bill CPT code 98985 if the patient transmitted fewer than 2 monitored days in the 30-day period. This is the floor that determines whether the code applies at all.
The practical implication: a patient who enrolls but never uses the platform doesn’t generate billable activity under 98985. A patient who transmits data once and never again falls below the floor. The clinic’s setup work was real. But the floor exists to keep RTM tied to actual patient engagement rather than to enrollment alone. It protects the integrity of RTM billing by ensuring the device supply code reflects programs the patient actually participated in.
One operational reality specific to CPT code 98985 is patient drop-off mid-window. Patients often start strong, transmit consistently for the first 10 days, and then taper. A clinic might watch monitored days plateau at 8 or 10 with a week left in the 30-day window.
At that point, there’s a decision to make. Clinics can re-engage the patient to push toward the 16-day threshold and bill 98977 instead. Or they can accept that 98985 will be the right code for this period. Neither choice is wrong; the question is whether the clinical case supports continued engagement or whether the natural tapering is appropriate.
Strong RTM programs track this in real time. The decision then happens consciously, not by accident at the end of the 30-day clock. A clinic that discovers the patient hit 9 monitored days on day 30 has already made the decision by default. A clinic that sees the plateau on day 23 still has options.
CPT code 98985 stacks with the other RTM codes within the same period. The setup code (98975, once per episode of care) and the management time codes (98979, 98980, 98981) can all appear alongside 98985 when each meets its own requirements.
A sample first-month scenario: a patient enrolls January 12 and transmits 10 days of data by February 10, with 25 minutes of management time during January. The billing: 98975 (setup, after the 2-day floor is met) + 98985 (for the 30-day device-supply window) + 98980 (for January management time). The deeper code-by-code breakdown sits in the 2026 RTM CPT code overview. Worth noting: the 30-day device-supply clock and the calendar-month management clock can produce mismatched billing months. That’s normal under the 2026 structure and isn’t a billing error.
Audit-ready CPT code 98985 documentation needs to include:
The failure pattern that surfaces in payer reviews is vague records or counts reconstructed at the end of the 30-day window. The cleanest approach is for the platform itself to maintain the transmission log automatically. If the clinic records monitored days manually, the audit risk is significantly higher. The documentation burden then falls on the clinical team rather than the technology.
Medicare recognizes CPT code 98985 for physicians, PTs, OTs, and SLPs. The 2024 CMS Final Rule also clarified that PTAs and OTAs can deliver RTM services under general supervision, meaning the device supply and patient education work can be administered by an assistant on a later date of service, as long as inclusion and necessity are documented in the overseeing clinician’s initial evaluation plan of care, and the assistant documents the work at the time of service. For these device supply codes, no assistant modifier is required even when a PTA or OTA does the work, since 98985 and 98977 are exempt from the de minimis standard. The CQ (PTA) or CO (OTA) modifier applies only to 98975, 98979, 98980, and 98981.
Coverage isn’t uniform across all payers. SLP-billed RTM has been inconsistent under Medicare in practice. Chiropractors aren’t currently covered under Medicare for RTM. And some commercial plans may not yet have updated their billing systems to recognize 98985. Verifying coverage per patient before enrollment is faster than chasing denials after submission.
Wibbi tracks patient transmissions in real time against both the 98985 (2–15 day) and 98977 (16+ day) thresholds. It surfaces the correct code based on actual monitored days at the close of the 30-day window. The threshold determination isn’t something the clinic has to calculate.
The platform also flags patients approaching threshold transitions. Clinicians can then make conscious clinical decisions about re-engagement rather than discovering the count at the end of the period. Wibbi supports RTM programs across rehab disciplines, applying the same monitored-day logic across PT, OT, SLP, pediatric, chiropractic, and pelvic health workflows.
Bill CPT code 98985 when a patient transmitted 2–15 days of monitored data in the 30-day period. Bill 98977 instead when the count reaches 16 or more. The two codes never appear together on a claim for the same patient in the same window.
The denial triggers to watch:
The 2026 national average reimbursement for CPT code 98985 is $39.77, though actual payments vary by Medicare locality.
This article is informational and does not constitute billing or legal advice. Clinics should verify the latest guidance with CMS and their billing team before submitting claims.
