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The RTM 2-Day Rule: How 98985 Changed Device-Supply Billing

CPT 98985 pays device supply from just two logged days in a 30-day period — same rate as the 16-day code. How the 2-day rule works, and why panels running old eligibility rules are leaving it unbilled.

RTMCPT CodesMedicare BillingOrthopedicsPhysical Therapy
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RTM billing · 6 min read · July 30, 2026

The RTM 2-Day Rule: How 98985 Changed Device-Supply Billing

How many days does a patient need to log for RTM device-supply billing in 2026? Two. That is the whole headline. CPT 98985, new for 2026, pays the device-supply service when a patient records as few as 2 days of data in a 30-day period — at the same national rate as the 16-day code it sits beside. Most MSK practices are still running their eligibility rules against the old 16-day threshold, which means their least-engaged patients — the majority of any real panel — generate monitoring work and zero revenue.

The two device-supply codes, side by side

CodeLogged days required (per 30-day period)2026 national rate
98985 (new 2026)2–15 days$51.44
98977 (musculoskeletal)16 or more days$51.44

Two things matter in that table. First, the rates are deliberately equal — CMS set 98985 at parity so practices are not punished for imperfect patient engagement (90 FR 49403–4). Second, the codes are mutually exclusive within a period: a patient bills one or the other, never both. Sixteen-plus days earns 98977; two to fifteen days earns 98985; zero or one day earns nothing.

Why this changes the economics of a PT panel

Under the old regime, device supply was all-or-nothing at 16 days. A post-op knee who logged dutifully for two weeks and then trailed off produced the same reimbursement as a patient who never opened the app: zero. Panels routinely lost the device-supply code on a large share of enrolled patients.

The 2-day rule inverts that. Two logged days in thirty is a threshold almost any enrolled patient clears if anyone is paying attention in week one. The practical consequence: the difference between $0 and $51.44 per patient per month is now a single follow-up nudge — "log tonight, it takes 30 seconds" — not a month of perfect adherence.

What still has to be true

The mistake we keep seeing

Billing teams hard-coded "16 days" into eligibility checks years ago, and those checks quietly filter out every 2-to-15-day patient before a claim is ever considered. If your RTM report only ever shows 98977, that is the tell. The fix is not clinical — those patients already qualify — it is a billing-rules update.

How BoneArc handles it

BoneArc counts logged days per rolling 30-day episode window automatically and selects the correct device-supply code — 98985 at 2–15 days, 98977 at 16-plus — with the pair-exclusivity enforced at the database level, so double-billing is structurally impossible. The certification step shows the day count behind every line before anything is submitted. Related reading: the full 2026 RTM code guide and whether PTs can bill RTM directly.

Rates shown are 2026 national Medicare allowed amounts; locality adjustments apply. This article is general billing information, not advice for a specific claim.