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RTM Data-Days: The 16-Day Threshold, Demystified

Device-supply billing turns on how many days the patient logs. Here’s how data-days are counted and why 16 is the number that matters.

RTMData-DaysDevice Supply9897798985
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The BoneArc Team
February 2026 · 5 min read
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On this pageWhat a data-day isThe two thresholdsThe 30-day windowHelping patients hit it

Key takeaways

  • Device-supply billing depends on distinct days of data in a 30-day period, not on total data points.
  • 98977 requires 16–30 data-days (at least 16); the new 98985 covers 2–15 days.
  • They're mutually exclusive — one device-supply code per 30-day episode.
  • Adherence is the lever: more days logged moves a patient up to the higher-value supply code.
As of the CY2026 Medicare Physician Fee Schedule (final rule CMS-1832-F, effective January 1, 2026). General educational information, not billing or legal advice. Coverage, codes, and payment vary by payer and locality — confirm specifics with your biller.

RTM device-supply billing has a deceptively simple driver: how many distinct days the patient transmits data. Get that count right and the device-supply code falls out automatically. Get it fuzzy and you'll either under-bill or bill a code the documentation can't support.

What counts as a data-day

A data-day is a distinct calendar day on which the patient logs recovery data — pain, range of motion, exercise adherence, and so on. It's about days, not volume: logging ten times in one day is still one data-day. Sixteen different days, each with a log, is sixteen data-days.

The two thresholds, after 2026

For 2026 there are two musculoskeletal device-supply codes, split by the day count in the period:

Sixteen is the number that matters — it's the line between the two device-supply codes, and only one of them bills per episode.

They're mutually exclusive: you bill either 98985 or 98977 for a given 30-day episode, based on where the day count lands — never both. (Dollar amounts for these vary by MAC and locality — confirm with your biller.)

The 30-day window

Data-days are counted within the device-supply period — a 30-day window, not strictly a calendar month. That distinction matters when an episode straddles month boundaries; the count follows the episode's window. Tracking the window per patient is what keeps the right code attached to the right period.

Helping patients actually hit 16

The threshold is an adherence problem more than a billing problem. The practices that consistently reach 16+ data-days are the ones that make logging a daily habit early: clear expectations at enrollment, gentle reminders, and a provider who's visibly paying attention to the data. Every additional logged day is both better clinical signal and, at the margin, the difference between the two supply codes.

BoneArc tracks data-days as they accrue and shows progress toward the threshold, so you can nudge the patients who are close rather than discover the shortfall at month-end.

RTM left on the table is usually a bookkeeping problem, not a coding one.

BoneArc tracks data-days, review time, and the attested call — so the billable work is documented as it happens.

See it on your panel →
Sources & verification. Reflects the 2026 CPT code set and CMS CY2026 Physician Fee Schedule final rule (CMS-1832-F), effective January 1, 2026. Code identities, descriptors, and day/minute thresholds are stated as published; the one national dollar figure given is 98975 = $21.71 (non-facility) — all other amounts vary by MAC, locality (GPCI), and contract and are described as ranges. Educational information, not billing or legal advice — verify against current CMS guidance and your fee schedule.