RTM billing basics
98975 in 2026: two monitoring days do not prove setup happened
Direct answer
For Medicare services paid under the 2026 Physician Fee Schedule, the 98975 monitoring threshold is two days in a 30-day period. It is no longer 16 days. But two monitoring days do not prove that initial setup and patient education happened. Read the current rule, then check the service record separately.
When two instructions disagree
Imagine reviewing a physical therapy clinic's remote therapeutic monitoring (RTM) charge packet. This is a hypothetical example, not a patient record.
An older worksheet says to hold the setup charge until 16 monitoring days have accumulated. A newer summary says two days. The monitoring record shows two dates, so someone asks whether the charge can move forward.
There are two questions hiding in that request.
First, which duration instruction applies to this Medicare service in 2026? Second, where is the record of the setup and education actually provided?
An answer to the first question does not answer the second. Correcting an outdated threshold should not turn a monitoring extract into evidence of a different service.
Read the comment and the agency response together
The 2026 Medicare final rule addresses 98975 directly on Federal Register page 49402.
The Centers for Medicare & Medicaid Services (CMS) summarizes a request about changing this code's requirement from 16 monitoring days to two. Its response then adopts the 2026 codebook changes for remote monitoring, including 98975.
Those two passages belong together. The number appears in the summary of comments. The agency's response adopts the relevant changes.
This is not a deduction from the newer short-duration device-supply codes. It is a setup-specific discussion.
For this Medicare 2026 question, do not keep a blanket 16-day setup instruction because another document repeats it. Check the code, year, payer scope, and agency response behind the instruction.
Do not extend that conclusion to every commercial or Medicare Advantage plan. This guide addresses the Medicare Physician Fee Schedule.
A current document can contain conflicting examples
The American Physical Therapy Association's January 29, 2026 advisory illustrates why a document's date is not enough.
In the PDF checked on October 23, page 5 gives two-day reporting guidance for 98975. A worked example on page 11 also uses two days.
Examples on pages 9 and 10 retain 16-day wording for that code.
That does not establish how the different wording arose. We did not inspect the advisory's revision history.
It does mean a reader can find different thresholds in the same document. Resolve the 2026 duration question with the final rule's specific discussion and adoption response, not by choosing an example in isolation.
The advisory remains useful supporting guidance. Its page 5 also recommends documenting the device, the education and training provided, and any required setup.
Compare the monitoring record with the service record
CMS's original implementation notice for 98975, on PDF page 2, identifies initial setup and patient education on equipment use.
That notice took effect in 2022. It identifies the service here; it is not the source for the 2026 duration change.
Monitoring dates tell a different part of the story from a record describing that service.
Continue the hypothetical clinic example. Assume a reviewer has already checked that October 6 and October 8 are qualifying monitoring days.
Here is a two-record comparison the clinic could make. It is our review method, not a CMS-required form.
| Record in this example | What the reviewer can establish | What remains open |
|---|---|---|
| Monitoring extract shows October 6 and October 8 | The example has two checked monitoring days. | The dates do not describe the setup or education provided. |
| Invitation log shows a link sent October 5; no setup or education note has been located | The clinic has evidence of an invitation. | The reviewer still needs to locate or clarify the service record. |
The duration question may be resolved while the service-evidence question remains open.
A missing note does not prove the service never happened. Ask the responsible clinician to locate the existing documentation or clarify what was provided.
Do not replace that review with an assumption that an invitation, download, or login documents patient education.
If another note records the service, review that note alongside the monitoring evidence. Neither record should silently stand in for the other.
Correct the instruction, not the history
Our recommendation is to record why an old duration instruction no longer applies.
Name the code and payer scope. Link the 2026 final rule and identify its 98975 discussion. Keep that source decision separate from the review of what happened.
For the worked example, the result might be: duration instruction corrected; setup documentation still being located.
That is more precise than marking the whole charge ready because the day count changed.
The same final rule, on page 49396, retains the requirement that services be reasonable and necessary. Two monitoring days are not a payment guarantee.
This guide does not establish a claim's date of service, the monitoring period's start, or when another setup charge may be reported. It is not a complete billing-eligibility checklist.
Device-supply periods and management months are separate questions. Our RTM timing guide explains that distinction without using either clock to decide setup eligibility.
For product information, see HepBuddy's overview. The worked review above is not a claim about a software feature.