The RTM codes fit on an index card, and we've covered what they say in an earlier article. This one is about the harder question: what to look at when choosing the software your program will run on. The gap between clinics that bill RTM sustainably and clinics that quietly abandon it after three months usually isn't the codes. It's the platform decisions made before the first patient was enrolled.
Start with the FDA question
RTM billing requires that data come through a product meeting the FDA's definition of a medical device, and CMS has indicated software alone can qualify. That requirement hides a trap: most exercise apps deliberately stay on the wellness side of the FDA line by avoiding claims about treating or managing a condition, and the FDA's 2026 general wellness guidance restates exactly where that line sits. An app positioned as general wellness to stay clear of regulation is, by the same positioning, a shaky foundation for RTM claims. Ask a vendor directly how their product meets the device definition, and be wary of an answer that amounts to marketing confidence.
The 2026 code changes reward flexible platforms
Until this year, a month with fewer than 16 days of data paid nothing. The 2026 Medicare fee schedule added codes for 2 to 15 days of data (98984 and 98985) and for 10 to 19 minutes of monthly management time (98979), which turns previously unbillable partial months into modest but real claims. The workflow catch is that the partial-month and full-month codes are mutually exclusive within a period, so the platform needs to count data-days accurately and steer each patient-month to the right tier. Ask to see how the software surfaces the day count, and what happens at the boundary.
Objective data is the billing substrate
The data-day thresholds assume the days are real. A 2018 study in JOSPT hid accelerometers inside the ankle cuff weights of 54 adults doing a 12 week home program and compared the sensors against the patients' own exercise diaries. The diaries recorded 220 sessions; the accelerometers measured 176. Roughly a quarter of self-reported sessions never happened, and these were patients who didn't know they were being checked. Self-report has clinical uses, but a program that counts diary entries as data-days is building claims on it. Platforms that capture sessions objectively, through sensors or a camera, give you numbers you can defend.
Will the monthly review survive a real caseload?
The management codes are where programs die. 98980 requires at least 20 documented minutes and one interactive communication per calendar month, and interactive communication means real-time, two-way audio at minimum. Portal messages and emails don't qualify. Patterns that draw reviewer attention include:
- Data collected but never opened by a clinician, which reads as billing for passive access.
- Time logs showing exactly 20 minutes for every patient, every month.
- Monthly notes copy-pasted between patients or between months.
- Setup claims (98975) with no evidence the patient ever activated the product.
So evaluate the review workflow at caseload scale. Twenty enrolled patients means twenty documented reviews, twenty conversations, and twenty distinct notes a month. If the platform doesn't make each of those fast, with queued activity, time tracking, and notes that reference actual session data, the honest math is that the codes won't get billed.
Price the model, not the pitch
Vendor pricing splits roughly into per-active-patient software fees, revenue-share arrangements that take a percentage of collections, and per-clinician licences. Any of these can work. What matters is comparing them against what a patient-month actually reimburses in your payer mix, and the payer mix is the honest caveat: Medicare rates are published, but commercial coverage for RTM is variable and often opaque, and state Medicaid coverage is patchy. A projection built on Medicare rates across your whole caseload overstates the program.
Where KineTrue sits in this
KineTrue approaches these questions from the patient-completion end: camera-guided sessions capture completed reps, movement quality, and pain reports objectively, and the therapist workspace puts between-visit activity, session detail, messaging, and appointments in one review surface. If you're evaluating platforms, we'd rather you ask us the FDA question, the day-count question, and the workflow question directly than take any of this on faith.
This is an evaluation framework, not billing advice. Payment amounts, code definitions, and payer policies change yearly and vary by payer. Verify current specifics against the CMS Physician Fee Schedule, APTA's practice advisory, and your own payer contracts.