ACCESS pays a co-management fee per review to the primary care or referring clinician who reviews the ACCESS care update and documents coordination. It can be billed at most once every four months per patient, with a one-time add-on the first time. Whether a PT practice qualifies as that co-managing clinician is the first question to settle, not the last: CMS frames the role around primary care, and we will not tell you it is answered when it isn't. JointCoach provides exercise tracking and a range-of-motion record.
If your practice is the ACCESS participant, it bills only ACCESS G-codes for a patient during that patient's care period, so RTM stops. RTM pays per code (see the pilot), so there is no honest per-patient figure to put on this page.
JointCoach RTM runs 1–3 months before ACCESS enrollment — ordered at the patient's in-person visit for their presenting complaint, so the billing-practitioner relationship and initiating visit are already in place. Establishes the exercise habit and a range-of-motion baseline; your practice collects the PROMs. Revenue continues during this phase.
RTM ActiveCMS pays the participant a capped yearly amount per MSK patient, including the 20% coinsurance a participant may waive. Half of Medicare's share is held back until the 12-month care period ends, and full payment needs at least half of aligned patients to complete the period and meet their outcome targets. Only ACCESS G-codes bill for the patient during the care period, so RTM stops. A referring clinician who reviews ACCESS updates can bill co-management, at most once every four months.
ACCESSRTM can restart once a patient's ACCESS care period ends, billed per code as before. From April 1, 2027, CMS adds a follow-on track for chronic MSK pain, so a patient who continues stays in ACCESS; its payment was not yet in CMS's payment table as of September 2026.
Per codeEvery PT practice is different. Practices inside ACO networks follow a different on-ramp than post-discharge orthopedic practices. These are the two ways RTM can sit around an ACCESS care period; JointCoach does not run either for you.
Your ACO or PCP partner identifies beneficiaries with chronic MSK via claims analysis or HIE queries. Chronic MSK pain > 3 months required.
PT performs initial functional evaluation under FFS. Confirms eligibility and biopsychosocial complexity. Low-complexity patients route digital-first.
The ACCESS participant enrolls the patient; JointCoach tracks the home exercise and range of motion, and your practice collects the PROMs. PT remains clinical hub for triage and care decisions throughout the 12-month period.
Deliver standard in-person care for the presenting complaint. JointCoach RTM runs in parallel during the FFS episode — building baseline data and digital habits.
Flag patients with chronic MSK near discharge — those likely to remain symptomatic or benefit from longitudinal support. JointCoach does not collect PROM instruments yet; your practice identifies transition candidates.
Enroll for 12-month longitudinal support and outcome tracking. RTM stops during the ACCESS care period and can restart per code when it ends; from April 2027 a follow-on MSK track can extend the period.
CMS ACCESS requires audit-ready PROM collection at baseline, quarterly, and end-of-period. JointCoach does not collect these instruments yet, so your practice keeps collecting them the way it does now.
| Category | Instrument | Indication | Success Threshold | Collection Schedule |
|---|---|---|---|---|
| Generic | PROMIS Physical Function 6b/CAT | All MSK | ↑ 2-pt T-score | BQE |
| PROMIS Pain Interference 6a/CAT | All MSK | ↑ 2-pt T-score | BQE |
|
| Site-Specific | KOOS JR | Knee | ↑ 10 pts | BQE |
| HOOS JR | Hip | ↑ 10 pts | BQE |
|
| Oswestry (ODI) | Back | ↓ 8 pts | BQE |
|
| Neck Disability Index (NDI) | Neck | ↓ 8 pts | BQE |
|
| QuickDASH | Shoulder/Arm | ↓ 10 pts | BQE |
|
| Pain | NRS 0–10 | All MSK | ≤ 2-pt increase | BQE |
| Global | PGIC | All MSK | Qualitative anchor | E |
B Baseline (Day 0–60) · Q Quarterly (Month 3, 6, 9) · E End-of-Period (Day 425 + PGIC) · Goal: ≥50% of enrolled patients meeting improvement threshold (OAT).
Half of every ACCESS payment is withheld until the end of the 12-month period — released only if pain and function actually improved. A patient who stops answering in month seven scores the same as one who never got better. The money doesn't turn on who you enrolled. It turns on what you can prove.
Objective movement and range-of-motion capture in the JointCoach app — not a patient's recollection. Self-reported activity tracks only weakly against what a sensor sees, so the record has to be measured to be trusted.
02 · Risk-adjustedA raw change score misclassifies — it flatters an easy panel and punishes a complex one. Adjusting for each patient's baseline is what separates real improvement from case mix, and it is the standard CMS itself applies to outcome measures. JointCoach does not risk-adjust outcomes today; it measures the range of motion an adjustment starts from.
03 · AttestedA named clinician reviews the outcome and signs it — so the number that releases your withheld payment stands up at reconciliation and under audit. The software measures; a licensed human attests.
That standard — measured, risk-adjusted, attested — is the difference between a dashboard and a defensible payment. An enrollment tool can get a patient onto a program. Only an outcome you can prove releases the half CMS holds back.
MSOs, PE-backed groups, and practices with complex ownership structures: the affiliation and substitute spend rules are the most consequential part of ACCESS. Read them before you structure any partnership.
For large PT groups or MSO-backed practices: if your management company or PE sponsor owns ≥5% of the ACCESS entity you create, your entire PT practice loses FFS billing capability for those patients. Structure carefully.
JointCoach's RTM billing intentionally pauses during the 12-month ACCESS period to keep your SST below 10%. This is not an accident — it's the sequencing that protects your reconciliation payment. Pre- and post-ACCESS RTM remains fully billable.
Two rules above can cut your revenue. This one hands you a window the operating surgeon cannot enter — and almost nobody in orthopaedics has read it.
“For global periods of surgery, remote physiologic monitoring and RTM may be billed by practitioners that are not receiving the global service payment.”
The operating surgeon is receiving the global payment. So for the 90 days after a joint replacement — the exact window this product was built around — the surgeon cannot bill RTM on their own patient and you can. That is not a loophole and it is not a workaround. It is the rule, and it is why a therapy practice is the correct party to hold post-operative monitoring rather than an incidental one.
Only one practitioner may bill remote monitoring for a given patient in a 30-day period. The monthly slot is exclusive. Whoever enrols the patient holds it — so post-operative monitoring is not a service line you add at your convenience later, it is a position somebody occupies. Enrol at discharge or the window closes without you.
Source: telehealth.hhs.gov, “Billing for remote patient monitoring,” page last updated 17 January 2025, read 10 September 2026. Coding guidance changes and payment varies by locality and year — confirm against the current Physician Fee Schedule and your own compliance review. Not billing or legal advice. The wider argument is at solvinghealth.com/model.
The program went live in July 2026 with Cohort 1 underway. Applications CMS receives before October 1, 2026 are considered for the January 1, 2027 start, and later cohorts start quarterly. JointCoach does not file ACCESS applications and is not an ACCESS implementation partner. The RTM pilot is the way to talk to us.