RTM after surgery: a global period is not a blanket ban

Start with the payment recipient, not the surgery date

Consider this hypothetical clinic situation.

A patient arrives for outpatient physical therapy after surgery. The referral includes the surgery date. Your biller sees that the patient is still within the surgical global period and flags proposed RTM for review.

The treating therapist works at an independent clinic. The surgeon performed the operation elsewhere. Nobody has yet recorded how the proposed RTM practitioner relates to the global surgical payment.

The biller has identified a question, not answered it. Counting days since surgery will not establish who receives that payment. Neither will looking at the clinic's name.

The useful next step is to establish the payment relationship. Then your biller can distinguish a therapist outside the global payment from a practitioner receiving it. Any remaining uncertainty belongs in the clinic's billing review, not in a guessed yes or no.

This example describes a proposed manual workflow. It is not a coverage determination or a reason to change clinically indicated care.

What CMS actually finalized

The Centers for Medicare & Medicaid Services (CMS) addressed this question in its 2024 Physician Fee Schedule final rule. That is Medicare's annual rule for payment under the physician fee schedule.

Here, a global period means the period covered by the surgical package payment. The key question is whether the proposed RTM practitioner receives that global service payment.

Commenters specifically asked how the global-period rules applied to physical and occupational therapists.

CMS answered that its global-period prohibition applies to billing practitioners receiving the global service payment. It then finalized a distinction for practitioners, including therapists, who are not receiving that payment because they did not furnish the global procedure.

For that practitioner, CMS permits RTM during the global period.

Keep the whole condition together:

• The practitioner did not furnish the global procedure.
• The practitioner is not receiving the global service payment for that reason.

Do not shorten this to "PT is always exempt." Do not replace it with "a different clinic can always bill."

A separate National Provider Identifier (NPI), clinic name or address is not the condition CMS states. Treat those details as identifiers, not as substitutes for establishing the payment relationship.

Why the shorter CMS summary can sound different

The December 2025 CMS remote-monitoring booklet, page 13, describes monitoring during a surgical global period using an unrelated underlying condition.

The earlier discussion in the 2024 final rule also uses that unrelated-condition language.

But the rule then addresses the specific question about therapists. Its finalized response states the distinction based on who receives the global payment.

Read the short summary alongside that response. Do not turn the booklet's abbreviated description into a blanket instruction to reject every postoperative therapist's RTM.

The reverse shortcut is wrong too. The therapist-specific response does not give a practitioner receiving the global payment unrestricted permission to bill related RTM separately.

If your case involves that practitioner, this article has not resolved it. Ask your billing specialist to review the arrangement and applicable policy.

Route the question according to what you know

This is a suggested clinic decision table, not a CMS-required form.

Keep same-group arrangements and transferred postoperative care out of a quick yes-or-no shortcut. This article does not determine how global payment is attributed in those cases.

That limit matters. The article explains the distinction CMS stated. It does not provide a rule for every organizational arrangement.

Record the reason, not only the conclusion

For the hypothetical independent clinic, a useful handoff would identify:

• The global procedure and the practitioner who furnished it.
• The practitioner proposed to furnish and bill the RTM.
• What establishes whether that practitioner receives the global service payment.
• The policy source the biller reviewed.
• Any unanswered question, who will resolve it, and when the clinic will review it again.

These are suggested working notes, not a new Medicare documentation checklist. Use the clinic's existing billing record rather than creating an unnecessary copy of the patient's chart.

Avoid a note that says only "post-op, cannot bill." It does not show whether anyone checked the practitioner distinction.

Avoid "separate NPI, approved" too. It records an identifier while leaving the payment relationship unexplained.

The practical output is a narrow conclusion: the global period does not itself rule out this practitioner's proposed RTM, or the question remains unresolved.

Do not turn that conclusion into "all RTM requirements met."

Keep the other RTM questions separate

The global surgical payment and another practice's remote-monitoring services are different questions.

A therapist may fit the global-period distinction while the clinic still needs to check whether another practice is providing remote monitoring. Use the separate guide to monitoring already provided by another practice for that coordination question.

Resolving the global-period issue also does not select a billing code or establish the required service.

Review the actual documentation for the proposed claim. The 30-day versus calendar-month guide addresses reporting periods. The management minutes and live-interaction guide addresses a different set of requirements.

The clinic still determines eligibility and medical necessity. Nothing in this article promises reimbursement.

This explanation concerns Original Medicare. Do not use it as a coverage decision for a Medicare Advantage or commercial plan.

A request for a policy change is not a new rule

In the 2026 final rule, commenters requested several remote-monitoring changes, including global-period billing.

CMS responded that it would consider the information for future rulemaking. It also referred readers back to the 2024 rule.

That response is not a new blanket exception for 2026. For the specific therapist distinction explained here, use the finalized 2024 response rather than treating a later comment as adopted policy.

Recheck the primary sources when CMS changes the policy or updates its summary guidance.

Where HepBuddy fits

HepBuddy supports RTM device-code documentation. The clinic independently determines eligibility and medical necessity.

The suggested payment-relationship review in this article is a manual clinic step, not an automated HepBuddy feature.

The useful distinction stays the same: identify who receives the global surgical payment before ruling out RTM solely because surgery was recent.