98975 vs 98977 vs 98985: Which RTM Device-Supply Code, When

Q: Can I bill 98977 and 98985 in the same 30-day period?

No. They cover the same rolling 30-day device-supply window and are mutually exclusive — the billing practitioner bills whichever one code matches the number of distinct data-days actually logged that period, not both.

Q: How many times can I bill 98975 for one patient?

Once per episode of care, not once per month. An episode runs from when RTM is initiated until the targeted treatment goals are met; a new 98975 isn't billed again during that same episode just because a new calendar month starts.

Q: Is 98985 the same value as 98977?

Under the CY2026 Medicare Physician Fee Schedule, CMS valued 98985 the same as 98977, on the reasoning that the device is supplied for the full 30-day period regardless of how many days of data are actually transmitted.

Q: What happens if a patient logs fewer than 2 days of data in the 30-day period?

Neither device-supply code is billable for that period. 98985's floor is 2 distinct data-days in the rolling 30-day window; below that, the device-supply codes don't apply for that period regardless of what other RTM activity occurred.

On this page

The short answer 98975: setup, once per episode 98977 vs 98985: the device-supply split Side by side Which code to bill, by data-days Common mistakes FAQ

Key takeaways

98975 bills RTM initial setup and patient education, once per episode of care — not once a month.
98977 and 98985 both bill the same rolling 30-day device-supply period, split by data-days logged: 98985 for 2–15 days, 98977 for 16–30 days.
98977 and 98985 are mutually exclusive — bill whichever one matches that period's actual data-day count, never both.
CMS valued 98985 equal to 98977, since the device is considered supplied for the full 30 days regardless of how many days of data come back.

CPT 98975 bills RTM initial setup and patient education on the device — once per episode of care, not every month. CPT 98977 and CPT 98985 both bill the device-supply component for the same rolling 30-day period, and the only thing that decides which one to use is how many distinct days of monitoring data the patient actually logged that period: 98985 covers 2–15 data-days, and 98977 covers 16–30. They're mutually exclusive — a given 30-day period bills one or the other, never both, and neither if the patient logged fewer than 2 days.

As of the CY2026 Medicare Physician Fee Schedule. Educational information, not billing or legal advice. Confirm current thresholds and rates with your MAC and payer contract before billing.

98975: initial setup, once per episode

98975 is the RTM code for initial device setup and patient education on how to use the equipment. It's billed once per episode of care — an episode runs from when RTM monitoring is initiated for that patient until the targeted treatment goals are met, not on a fixed monthly cadence. A patient who starts a new RTM episode later, after a prior episode has closed out, can generate a new 98975; a patient continuing an existing episode into a new calendar month does not.

CMS's CY2026 rule set the reporting floor for 98975 at 2 days of monitoring in a 30-day period — a change from the prior 16-day floor. That's a documentation gate on when setup becomes billable, not a repeat-billing trigger; 98975 still only bills the one time per episode.

98977 vs 98985: the device-supply split

Where the code family actually branches is the device-supply component, which reflects the RTM device transmitting scheduled recordings and/or programmed alerts over a rolling 30-day period. CY2026 split what used to be a single threshold into two codes, based purely on how much data came back in that 30-day window:

98985 — 2 to 15 distinct data-days logged in the 30-day period. New for CY2026.
98977 — 16 to 30 distinct data-days logged in the same 30-day period.

Both codes describe the same underlying service — the device being supplied to the patient for that period — priced identically by CMS on the reasoning that the practice incurs the device-supply cost for the full 30 days regardless of how many of those days the patient actually logged data. The distinction exists to acknowledge lighter-adherence periods rather than to pay more for more data. For the full code ladder alongside the treatment-management codes (98979, 98980, 98981), see the 2026 RTM CPT codes guide.

Side by side

Code	What it covers	Billing frequency	Data-day threshold	CY2026 national non-facility rate
`98975`	Initial setup + patient education on the device	Once per episode of care	≥2 days in 30-day period (reporting floor)	$21.71
`98985`	Device supply, lighter-adherence tier	Per rolling 30-day period	2–15 days	$51.44
`98977`	Device supply, full-adherence tier	Per rolling 30-day period	16–30 days	$51.44

National non-facility amounts, non-QP conversion factor $33.4009, CY2026 Medicare Physician Fee Schedule. Locality-adjusted and payer-contracted rates will differ — see Sources & verification below for citations, and the full CPT codes guide for the treatment-management codes and worked dollar examples.

Which code to bill, by data-days logged

Count the distinct data-days in the rolling 30-day period
What to check: how many separate days the patient's device transmitted or the patient logged qualifying data in that specific 30-day window, not the calendar month.
0–1 days
Result: neither device-supply code is billable for that period. Continue monitoring toward the next period's count.
2–15 days
Result: bill 98985.
16–30 days
Result: bill 98977.
New episode starting?
Also check: if this is the first time RTM is being initiated for this patient's current episode, 98975 applies once, alongside whichever device-supply code the period's data-days support.

Common mistakes with these three codes

Billing both 98977 and 98985 for the same period. They're mutually exclusive — the data-day count for that specific 30-day window determines exactly one of the two, never both.
Re-billing 98975 every month. It's an episode-level code. A continuing episode into a new calendar month doesn't generate a new 98975.
Confusing the 30-day device-supply window with the calendar month. The device-supply period is a rolling 30 days tied to the patient's episode timeline, which won't always line up neatly with calendar-month boundaries the way the treatment-management codes (billed per calendar month) do.
Assuming 98985 pays less than 98977 because it requires fewer days. CMS priced them identically — the device-supply cost doesn't scale down with fewer logged days.

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FAQ

What's the difference between 98975, 98977, and 98985?

98975 bills RTM initial setup and patient education, once per episode of care. 98977 and 98985 both bill the RTM device-supply period — the same rolling 30 days — split by data-days logged: 98985 for 2–15 days, 98977 for 16–30 days. Only one of 98977/98985 is billed for a given period, never both.

Can I bill 98977 and 98985 in the same 30-day period?

No. They cover the same rolling 30-day window and are mutually exclusive — bill whichever one matches the actual data-days logged that period.

How many times can I bill 98975 for one patient?

Once per episode of care, not once a month. A new episode can generate a new 98975; continuing an existing episode into a new month does not.

Is 98985 the same value as 98977?

Under the CY2026 fee schedule, CMS valued 98985 equal to 98977, reasoning that the device is supplied for the full 30-day period regardless of how many days of data are actually transmitted.

What happens if a patient logs fewer than 2 days of data in the 30-day period?

Neither device-supply code is billable for that period — 98985's floor is 2 distinct data-days in the rolling 30-day window.

Sources & verification. Code descriptions, the once-per-episode basis for 98975, the 2-day CY2026 reporting-floor change for 98975, the 98977/98985 mutually-exclusive device-supply split (2–15 days vs 16–30 days), and the CY2026 national non-facility rates ($21.71 / $51.44 / $51.44) reflect the CY2026 Medicare Physician Fee Schedule final rule (CMS-1832-F, 90 FR 49266, RTM discussion 90 FR 49394–49404, specifically 90 FR 49397 and 90 FR 49403–4, plus the CPT parenthetical adopted at 90 FR ~49401-2), consistent with correction notice FR 2026-04797 (91 FR 12071, effective 2026-03-12). These figures and citations are drawn from this repository's independently verified canonical source, payer-rules/medicare-baseline.json (status: verified; retrieved and cross-checked 2026-07-03 against an independent CMS carrier pricing file to the cent). On 2026-08-14, this run attempted to independently re-fetch the primary sources directly (cms.gov, federalregister.gov, govinfo.gov, ecfr.gov, medicare.gov); every one of those domains was blocked by this environment's network egress policy. No new dollar amount, day threshold, or citation is introduced in this article beyond what that already-verified canonical source establishes — this is flagged in the accompanying pull request as the item needing a manual re-verification pass once primary-source network access is available. Educational information, not billing or legal advice.