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What Changed in the CY2026 Medicare Physician Fee Schedule Final Rule (RTM & Testing Codes)

The CY2026 Medicare Physician Fee Schedule final rule (CMS-1832-F), effective January 1, 2026, left the core Remote Therapeutic Monitoring codes (98975, 98980, 98981) structurally unchanged but added new short-duration device-supply and treatment-management codes, revised the existing device-supply code descriptors, and made no changes to the neuropsychological testing code family (96116–96146).

This page provides general educational information about CPT and RTM billing codes. It is not coding advice, a guarantee of reimbursement, or a substitute for your own compliance review. Payer coverage and documentation requirements vary by plan and can change — verify current requirements with CMS, your Medicare Administrative Contractor, and each payer before billing.

What Stayed the Same

The three codes that carry the most volume for concussion, cognitive-health, and mental-health monitoring programs did not change in structure for 2026:

  • 98975 — initial set-up and patient education on RTM equipment, still billed once per episode of care, not monthly.
  • 98980 — RTM treatment management, first 20 minutes of clinical staff/physician/QHP time per calendar month, still requiring at least one real-time interactive communication with the patient or caregiver.
  • 98981 — the add-on code for each additional 20 minutes, still paired with 98980.

The neuropsychological and psychological testing code family — 96116/96121, 96132/96133, 96136/96137, 96138/96139, and 96146 — was not revised in the CY2026 rule. The general supervision requirements, time-based billing conventions, and same-date multiple-code allowances described in CMS's Psychological and Neuropsychological Testing FAQ continue to apply unchanged.

What Changed: Device-Supply Code Descriptors

The existing 16-day-minimum device-supply codes were re-worded for 2026 to specify a bounded 16–30 day range within a 30-day period, rather than an open-ended "16 days or more":

  • 98976 (respiratory system monitoring) — now 16–30 days of data within 30 days.
  • 98977 (musculoskeletal system monitoring) — now 16–30 days of data within 30 days.
  • 98978 (cognitive behavioral therapy monitoring) — now 16–30 days of data within 30 days. This is the device-supply code most directly relevant to Kavera's assessment battery, since it covers between-visit CBT-related monitoring data supply rather than device set-up or clinician time.

The re-wording formalizes the upper bound of the reporting window rather than changing the underlying clinical requirement — practices already documenting 16 or more days of patient-reported or device-collected data in a 30-day period should not need to change their workflow to stay compliant.

What's New: Short-Duration RTM Codes

The CY2026 rule set introduced new codes covering shorter monitoring and management windows, intended to address patients who engage with monitoring for fewer than 16 days or need treatment management before a full 20-minute monthly threshold is reached:

For a concussion or cognitive-health monitoring program, 98986 and 98979 are the two most relevant additions: 98986 gives practices a billable pathway for patients whose between-visit data submission falls short of 16 days in a given month, and 98979 gives a billable pathway for months where clinical staff time falls between 10 and 19 minutes rather than reaching the 20-minute threshold that 98980 requires.

Why CMS Added These Codes

According to the AMA's CPT 2026 code set release, the shorter-duration codes were added because clinical evidence supports patient benefit from monitoring and management over shorter windows than the original thresholds required, and to remove what amounted to an all-or-nothing billing cliff — a patient who submitted 14 days of data or received 18 minutes of staff time previously generated no billable device-supply or management code at all, despite genuine clinical engagement.

Billing Mechanics That Apply to the New Codes

  • One device-supply code per 30-day period. A practice bills either the standard-duration code (98976/98977/98978) or the short-duration counterpart (98984/98985/98986) for a given monitoring category and period — never both for the same period.
  • One treatment-management base code per month. A practice bills either 98979 or 98980 (with 98981 as needed) for a given calendar month — not both.
  • Real-time interactive communication is still required for both 98979 and 98980/98981. CMS has clarified that this can be satisfied through audio-only calls in addition to audio-video, though practices should confirm current requirements directly with CMS before relying on any broader interpretation.
  • "Sometimes therapy" designation. The new codes 98979, 98984, and 98985 carry a "sometimes therapy" designation requiring GP/GO/GN therapy modifiers when furnished by physical therapists, occupational therapists, or speech-language pathologists, as distinct from when furnished by a physician or other qualified health care professional. Whether 98986 carries the same designation should be confirmed against the current-year CPT code book before billing, as sourcing on this specific point is less consistent.
  • Practitioner eligibility unchanged. CMS reaffirmed that RTM billing-practitioner eligibility remains limited to physicians, physical therapists, occupational therapists, speech-language pathologists, and qualifying assistants under existing supervision rules, and explicitly declined to extend RTM billing eligibility to pharmacists or dietitians for 2026.
  • Assistant billing rules unchanged. The existing CQ/CO modifier requirements for services furnished in part by a physical therapist assistant or occupational therapy assistant continue to apply to the new codes the same way they apply to 98980/98981.

Common Denial Reasons Under the CY2026 Rules

  • Billing both a standard-duration and short-duration device-supply code for the same monitoring category in the same 30-day period.
  • Billing both 98979 and 98980 for the same calendar month.
  • Billing 98979, 98984, or 98985 for a PT/OT/SLP-furnished service without the required therapy modifier.
  • Billing a device-supply code without documentation of at least the applicable minimum days of transmitted data (2 days for short-duration codes, 16 days for standard codes) within the 30-day window.
  • Billing a treatment-management code without documenting at least one real-time interactive communication during the calendar month.

Worked Example Scenario

A sports-medicine practice enrolls a post-concussion patient in between-visit monitoring. In a given month, the patient submits symptom and cognitive-domain data on 12 of 30 days, and clinical staff spend 15 minutes reviewing the data and completing one phone check-in with the patient. Under the CY2026 code set, this month's engagement pattern — fewer than 16 days of data and fewer than 20 minutes of staff time — is now billable under the short-duration pathway (98986 for the device-supply component, 98979 for the treatment-management component), where previously it would have fallen below both thresholds and generated no RTM billing at all. The following month, if the same patient submits data on 20 of 30 days and staff spend 25 minutes on review and outreach, the practice would instead bill the standard-duration codes (98978 and 98980/98981) for that period.

How Kavera Handles This

Kavera tracks both the 16-day and 2–15-day device thresholds and both the 10-minute and 20-minute time thresholds per patient per month, so the 2026 codes are billable without a spreadsheet. Patients who used to fall short now qualify for 98979. Self-Serve practices run this with their own staff. On Managed, Juliet Mott's team runs it and bills it under your credentials. Educational, not coding advice. Verify requirements with CMS, your MAC and each payer.

Sources

  • CMS, "Calendar Year (CY) 2026 Medicare Physician Fee Schedule Final Rule" fact sheet: cms.gov
  • CMS, "Psychological and Neuropsychological Testing FAQ": cms.gov
  • AMA, "AMA releases CPT 2026 code set": ama-assn.org

FAQ

Common questions

Do I need to change how I document RTM monitoring because of the CY2026 rule?
Not necessarily. If your patients typically reach 16 or more days of data submission and your staff typically spend 20 or more minutes per month on treatment management, the standard-duration codes you were already using (98978, 98980, 98981) still apply, just with a formally bounded upper range in the descriptor. The new codes primarily add a billable pathway for engagement that previously fell below the old thresholds.
Can I bill both the short-duration and standard-duration device-supply code in the same month?
No. Only one device-supply code — either the standard-duration or short-duration variant for that monitoring category — may be billed per patient per 30-day period.
Are the exact new RTM code numbers (98979, 98984–98986) confirmed on CMS.gov directly?
The code numbers are well-corroborated across the AMA's CPT 2026 code set release and multiple independent billing-industry sources, but this page relies primarily on the AMA release rather than a CMS.gov page that itemizes the code numbers directly. Confirm current code numbers and descriptor language against the CPT 2026 code book or the Federal Register text of CMS-1832-F before finalizing internal billing policy.
Did the neuropsychological testing codes (96116–96146) change for CY2026?
No. The CY2026 final rule's changes described here are specific to the RTM code family. The testing code family's structure, time rules, and supervision requirements are unchanged.
Who can bill the new short-duration treatment-management code 98979?
The same practitioner types eligible to bill 98980 — physicians, physical therapists, occupational therapists, speech-language pathologists, and qualifying assistants under existing supervision rules — subject to the same real-time interactive communication requirement.

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