The fourteen RTM questions practices ask before a pilot, answered from the primary sources.

Who can bill Remote Therapeutic Monitoring?

Physicians and other qualified health care professionals, and that includes physical therapists, occupational therapists and speech-language pathologists. CMS had initially treated the RTM codes as "incident to" services, which would have excluded PTs; after APTA's comments, the CY2023 final rule confirmed that PTs are permitted to bill them.

Since the CY2024 rule, PTs and OTs in private practice bill RTM under general supervision, which is what makes a practice-owned program workable without the supervising clinician in the room.

Assistants: supervision rules for PTAs and OTAs differ by setting and have changed recently. Confirm the current rule for your setting with your compliance lead before an assistant furnishes the monitoring minutes.

Sources: APTA practice advisory on the RTM codes (March 2023) · CMS CY2024 Physician Fee Schedule final rule fact sheet

What counts as a device for the device-supply codes?

The device-supply codes (98975 setup, 98977 and 98985 supply) require that the monitoring device or software meet the FDA's definition of a medical device under section 201(h) of the Food, Drug, and Cosmetic Act. That is a definitional test; software can qualify, and it does not by itself require FDA clearance or approval.

JointCoach is not FDA-cleared. Its device-listing path is under review with a regulatory consult. Until that is settled, plan a pilot on the management codes and treat device-supply revenue as upside. We will say plainly when that changes.

Sources: APTA practice advisory (device as defined by the FDA) · the CPT table and footnote on the homepage

What is the 16-day rule, and what changed in 2026?

98977 (device supply, musculoskeletal) may be reported only if at least 16 days of data were collected in a 30-day period. Since January 1, 2026, a new code, 98985, covers 2 to 15 days of data, so a patient who does not reach 16 days no longer produces nothing. In 2026 both pay the same national-average rate, $51.44, after CMS's January practice-expense update. Only one device-supply code is reported per 30-day period.

Sources: APTA practice advisory (16-day requirement) · 2026 rates and the 98985 note on the homepage

What does the monthly management code require?

• 98980: at least 20 minutes of qualified professional time in the calendar month, and at least one interactive communication with the patient or caregiver by phone, video or in person. Do not report it for less than a full 20 minutes.
• 98981: each additional full 20 minutes in the same month.
• 98979 (new for 2026): 10 to 19 minutes.
• Under 10 minutes: nothing is billable that month.

The interaction requirement is the reason JointCoach treats the billing rule as the safety rule: the code cannot be billed unless a named clinician actually closed the loop with the patient that month.

Sources: APTA practice advisory (98980/98981 descriptors) · who closes the signal

Can RTM and RPM be billed for the same patient?

Not in the same month. Remote therapeutic monitoring and remote physiologic monitoring are mutually exclusive for a patient in a given period, and only one practitioner can bill RTM for that patient in the period. If a primary care practice already has the patient on RPM, coordinate before enrolling.

Source: APTA practice advisory · the CPT footnote on the homepage

Does RTM need an order, and what do I document?

Yes. RTM is ordered by the treating practitioner and lives in the plan of care. Keep, per patient and per month:

• the order and the reason for monitoring;
• the device or software used and the date of setup and education (98975);
• the number of days with data in the 30-day period;
• the minutes of management time and who furnished them;
• the date and mode of the interactive communication;
• the patient's agreement to participate.

JointCoach's monthly summary is built to carry the first four; the practice records the interaction and the agreement in its own chart.

Source: APTA practice advisory (ordering and documentation)

What does the CY2027 proposed rule change?

Three conditions of payment, each quoted on our CY2027 page: the clinical time must be furnished by a direct employee of the billing practice (no contracting out to third-party companies); RTM may be furnished only to established patients; and it must be initiated at a face-to-face or telehealth visit. The rule is proposed, not final. Comments close September 14, 2026.

If finalized as written, vendor-staffed monitoring ends and software supplied by a vendor continues. That is why the pilot is built around a PT you already employ.

Sources: CMS CY2027 proposed rule fact sheet · docket CMS-2026-2377 · our reading of the primary text

Do commercial plans and Medicaid pay for RTM?

Many commercial plans recognize the RTM codes; coverage and rates vary by plan and have to be verified per contract, and RTM has been adopted by commercial payers more slowly than RPM. Medicaid coverage varies by state. Plan the pilot's economics on Medicare and confirm each payer before enrolling its members.

Source: the coverage note on the homepage; verify against your own payer contracts.

What does the patient need?

A smartphone with a camera, the program you prescribed, and agreement to participate. No wearable and nothing to charge. The video stays on the phone; the measurements (joint angle, reps, session length, pain score) are what leave it. Patients can try the measurement before enrolling: the camera demo runs in the browser with no signup.

Source: the demo itself; what it captures.

How much clinician time does RTM take per patient?

About 20 minutes per patient per month for 98980, plus one live interaction, which can be a short call. Plan on the review not happening every month: in a real-world outpatient program the management code was billed in roughly 53% of monitored months. Our calculator rounds that to a 55% default; assuming every month overstates revenue about twofold.

Source: Hohl et al., Remote Monitoring Enhanced Outpatient Physical Therapy: A Mixed-Methods Implementation Study, J Neurol Phys Ther 2026 · the calculator

Why do RTM claims get denied?

• Fewer than 16 days of data reported under 98977, when 98985 should have been used.
• No documented interactive communication in the month 98980 was billed.
• Minutes not recorded, or fewer than the full 20.
• RPM billed for the same patient in the same month, or two practitioners billing RTM.
• A device or software that does not meet the FDA definition.
• No order in the record, or monitoring begun without a plan of care.

The pilot asks your billing contact to tell us what was paid and what was denied, so the economics on this site stay honest.

Sources: the code requirements in questions 02 to 06; what the practice does in the pilot.

Is the camera measurement accurate?

The measurement comes from a deterministic pose model running on the phone; no generative AI decides anything. Joint angles are estimates for trend review, not a substitute for in-person goniometry, and accuracy depends on lighting, camera placement and clothing. The same angle computed the same way on every session and every phone is the point: comparability across sessions and sites, not a new number.

Video-based motion analysis is already common in the profession: roughly half of physical therapists report using it, with established methodological standards.

Sources: video-based motion analysis in physiotherapy practice (International Journal of Osteopathic Medicine, 2023) · how the camera measures · the evidence page

What is JointCoach not?

• Not a physical therapist. Your clinician prescribes, reviews and decides.
• Not a staffing vendor. We never supply the person whose time you bill.
• Not a biller. Claims go out under your NPI, from your system.
• Not FDA-cleared, and not carrying any certification of its own.
• Not a guarantee of payment from any payer.

A business associate agreement with the practice is part of setup; no patient data flows before it is signed.

Source: the clinician page · the pilot's fit check

What does JointCoach cost, and how do we start?

The 90-day pilot has no software fee for up to 25 patients. After the pilot: $19 per patient-month, charged only in a month the practice bills a device-supply code (98977 or 98985), and nothing in any other month. That leaves the practice about 82% of a standard month and 100% of a management-only month. Pilot pricing is set for 2026.

Start by telling us about the practice on the pilot page. A person reads it and replies with a start plan or an honest no.

Source: the economics table on the pilot page