Through Dec 31, 2027
Section 6209, CAA 2026
- PTs, OTs, SLPs and audiologists may furnish Medicare telehealth; from January 1, 2028 they cannot [3]
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The Therapy Operator · Issue 1 · November 2026
RTM just got harder to bill. Here is the new order of operations.
Three stories. The CY 2027 PFS proposed rule limits RTM to established patients, requires an initiating visit and counts only employed clinical staff from January 1, 2027 if finalized. The telehealth FAQ of October 8 adds modifiers BB and BC; therapy telehealth ends after December 31, 2027. The January numbers: conversion factor down 1.68%, KX threshold proposed at $2,540.
98975 to 98981 · unchanged for now
Jan 1, 2027 · proposed RTM conditions
BB and BC · telehealth modifiers
$2,540 · proposed KX threshold
Edition
Issue 1 Nov 2026
Focus
RTM · telehealth
Codes
98975 to 98981
Metric
$32.84 CF, proposed
Effective date
Jan 1, 2027
Horizon
Dec 31, 2027
RTM gets three conditions of payment on January 1
Published July 14, 2026, comments closed September 14, final rule expected November. It keeps the codes and changes who can be billed for them and by whom [2].
01
The patient must already be established
Condition 1
The rule RPM returned to after the public health emergency; no RTM at the first visit.
02
A face-to-face initiating visit, with RTM discussed
Condition 2
In person or by telehealth, RTM discussed, consent obtained; separately billable. A visit where RTM was not discussed does not count.
03
Only employed clinical staff count
Condition 3
Direct employees under general supervision only; CMS wrote that contracted third-party staff cannot give adequate oversight.
04
Codes stay, for now
Solicitation only
CMS seeks comment on collapsing 17 remote monitoring codes into four G-codes, GRTM1 set-up and GRTM2 monthly bundle among them. 98975 to 98981 and 98984 to 98986 remain the plan for January.
What to do in DecemberList every patient on RTM, confirm the established relationship and the visit at which RTM was discussed, and decide who the employed staff will be if a vendor monitors today. The rest of the rule: CY 2027 therapy impact note.
Two new modifiers in January, one cliff in 2027
From Jan 1, 2027
Modifiers BB and BC
- BB: contracted virtual platform; BC: incident to a practitioner
- Required; no payment implications
Lapse, Oct to Nov 2025
Government shutdown
- Claims paid as before October 1, 2025, as if the flexibilities never lapsed
Claim template changeAdd BB and BC from January 1, 2027 with a rule that picks the right one from how the visit was delivered. Put December 31, 2027 on the planning calendar for any service line built on video home visits.
Conversion factor down, KX threshold up, all still proposed
Nonqualifying APM conversion factor
Down $0.56 as the one-year 2.50% increase expires; qualifying APM $33.57 to $33.17
$33.40CY 2026 final100%
$32.84CY 2027 proposed98.3%
KX threshold, PT and SLP combined; OT separately
$2,480 times an estimated 2.5% MEI, rounded to $10
$2,480CY 2026in force
$2,540CY 2027proposed
| Item | CY 2026 | CY 2027 proposed | What it does |
|---|---|---|---|
| KX threshold, PT and SLP combined | $2,480 | $2,540 | Above it KX attests medical necessity; without KX the claim denies |
| KX threshold, OT | $2,480 | $2,540 | Separate OT accrual |
| Targeted medical review threshold | $3,000 | $3,000 | Unchanged through 2027; indexed from 2028 |
The RTM roster check
Export every patient with an RTM code billed in the last 60 days, add three columns. Any no, blank or vendor is a January decision.
| Patient | RTM start | Established before start? | Initiating visit, RTM discussed | Monitoring by | January action |
|---|---|---|---|---|---|
| Example A | Sep 3, 2026 | Yes | Sep 3, 2026 | Employed PT | None |
| Example B | Oct 1, 2026 | No, first visit | Blank | Vendor | Document the initiating visit; bring monitoring in-house or stop billing |
Takeaway
Established patient, initiating visit, employed staff: in that order, documented before January. Everything here is proposed until the final rule.
Before December
Run the RTM roster checkEvery patient billed in the last 60 days.
Add BB and BC to the claim templateEffective January 1, 2027, picked from how the visit was delivered.
Load $32.84 and $2,540 as draftsRe-verify against the final rule before go-live.
New from our therapy deskEvery cell of the therapy payer matrix re-fetched at source October 25, 42 jurisdictions, a verbatim quote behind each. Two new guides on the 2027 figures: OT billing guide 2027, PT billing services scorecard.
Frequently asked questions
Can a new patient start remote therapeutic monitoring in 2027?
Not under the proposed rule: RTM only for established patients, started during a separately reportable visit at which RTM is discussed. Final rule expected November 2026.
Can a third-party company run our RTM program in 2027?
Under the proposal, no. Only clinical staff who are direct employees of the billing practice, under general supervision; contracted third-party time would not count.
What are modifiers BB and BC?
Per the FAQ of October 8, 2026, BB marks telehealth through a virtual platform the practitioner contracts with or pays for, BC telehealth incident to a practitioner's service. Required from January 1, 2027; no payment implications.
- CMS fact sheet, Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule (July 14, 2026)
- Federal Register public inspection, CMS-1847-P, CY 2027 PFS proposed rule (comments closed September 14, 2026)
- CMS Telehealth FAQ, updated October 8, 2026
- CMS, Therapy Services: KX thresholds, RTM codes, CAA 2026 section 6209
- CMS fact sheet, CY 2026 Physician Fee Schedule final rule: CY 2026 conversion factors
Checked October 25, 2026. Rules change; confirm against the source. Proposed items are not final until the final rule publishes.
Want your RTM roster and telehealth template checked before January?
We run the roster check on your data, mark patients and vendors that would miss the proposed conditions, and set the BB and BC rule in your template.