Last Chance to Comment on the 2026 Physician Fee Schedule

Read CEO Donovan Campbell's comments to CMS on the 2026 Proposed Physician Fee Schedule below—and submit your own comments here before the September 12, 2025 deadline!

September 12, 2025

Centers for Medicare & Medicaid Services

Department of Health and Human Services

Attention: CMS-1832-P

Baltimore, MD 21244-8016

 

RE: Comments on the CY 2026 Physician Fee Schedule Proposed Rule (CMS-1832-P)

Submitted electronically on http://www.regulations.gov

Medbridge appreciates the opportunity to provide comments on the proposed changes impacting Remote Therapeutic Monitoring (RTM) for musculoskeletal care in the CY 2026 Physician Fee Schedule (CMS-1832-P).

Medbridge is a digital health company supporting over 360,000 clinicians across physical therapy, occupational therapy, speech-language pathology, nursing, and related specialties. Our platform enables providers to prescribe and monitor adherence to evidence-based home exercise programs and to deliver digital health services, including RTM. To date, clinicians using Medbridge have assigned more than 86 million programs, the majority focused on musculoskeletal care.

Support for CMS’s Adoption of New 2–15 Day and <20 Minute RTM Codes

Medbridge agrees with CMS that strengthening the RTM code set can increase reimbursement, encourage broader adoption of digital monitoring, and improve patient outcomes. In particular, the proposed 2–15 day and <20 minute RTM codes, as well as the equal valuation of RTM device-supply codes 98XX5 and 98977, help align reimbursement with the care actually delivered rather than requiring providers to meet thresholds that add administrative steps without clinical benefit. We therefore urge CMS to finalize these proposals as drafted, effective January 1, 2026.

Medbridge Recommends that RTM Code 98975 Require Only Two Days of Data Transmission

In our work with over 4,500 clinician groups and healthcare organizations, Medbridge has seen firsthand how reimbursement uncertainty limits RTM adoption. Many organizations remain hesitant to implement RTM because billing for 98975 is only triggered after extended patient interaction, leaving providers unsure they can recover upfront costs.

The AMA CPT Editorial Panel addressed this challenge directly by recommending coding instructions that state:

Codes 98975, 98XX4, 98XX5, and 98XX6 are not reported if cumulative monitoring is less than 2 days in a 30-day period.

Medbridge urges CMS to update the proposed instructions in the final rule to align with the CPT Editorial Panel’s February 2025 recommendation and to permit billing of 98975 following two days of data transmission. This change would eliminate a key barrier to adoption, support CMS’s stated goal of expanding RTM use, and improve patient outcomes. This refinement ensures consistency across the RTM code family, since CMS has already recognized 2–15 day monitoring for other RTM services.

Alignment with RUC Recommendations and Device-Supply Code Parity

Musculoskeletal care is delivered across a diverse clinician landscape. For RTM to succeed, adoption must extend beyond the largest providers to include practices of every size, from solo practitioners to multi-state groups. While Medbridge recognizes the strength of the OPPS data CMS has relied upon, we encourage CMS to also weigh the RUC’s recommendation based on the AMA’s CPI data to ensure reimbursement levels that support adoption across the full provider spectrum.

We believe this balance can be achieved by finalizing CMS’s proposal to maintain the current RVU of 0.61 for CPT code 98980 and assigning 0.39 RVUs for 98XX7 in alignment with the RUC’s recommendation. Doing so will both acknowledge the value of the data CMS requested/received and strengthen provider incentives to use RTM to engage patients across musculoskeletal care. We also support CMS’s proposal to maintain equal valuation for RTM device-supply codes 98XX5 and 98977, which provides needed consistency and predictability for providers.

As a digital health company and RTM platform, Medbridge urges you to consider our comments and to consider the role that physical therapists and other rehab providers can play in making RTM successful through improved clarity and reimbursement. Please do not hesitate to reach out if we can assist or support your work on behalf of Medicare beneficiaries.

Sincerely,

Donovan Campbell

CEO, Medbridge

Phone: 760-331-3185

Email: [email protected]