How CMS 2026 Medicare Proposed Rules Will Affect Telehealth & RPM

The CMS 2026 Medicare Physician Fee Schedule proposed rule represents the most transformative shift in telehealth and remote patient monitoring policy since the COVID-19 pandemic. With the removal of arbitrary frequency limits, expansion of covered services, and introduction of new RPM billing flexibility, these changes create unprecedented revenue opportunities for healthcare providers while simultaneously introducing new compliance considerations and operational challenges.

For healthcare organizations that have been navigating the uncertain terrain of temporary COVID-era waivers, this proposed rule offers something invaluable: permanence and clarity. However, with a comment period closing on September 12, 2025, and implementation beginning January 1, 2026, providers have a limited window to understand these changes, provide feedback, and prepare their operations.

This comprehensive analysis breaks down what the CMS 2026 proposed rules mean for your practice, the financial implications, and the strategic steps you should take now to position your organization for success.

The Regulatory Burden Finally Lifts

For years, healthcare providers trying to offer telehealth services had to navigate a long and confusing approval process. Understanding whether a service could qualify for future Medicare coverage often required outside regulatory experts — slowing down innovation and making long-term planning difficult.

The CMS 2026 proposed rule simplifies this structure by removing the two most difficult approval steps. The first three steps — which focus on clear clinical and administrative criteria — will remain. But CMS is eliminating the complicated “provisional vs. permanent” designations that created uncertainty for providers.

What this means for healthcare organizations:
Less paperwork, clearer approvals, and more confidence to invest in telehealth services that support both care delivery and sustainable revenue.

What This Means for Your Practice

Under the new framework, when a service successfully makes it onto the Medicare Telehealth Services List, it receives permanent status from day one. This eliminates the provisional designation that previously left providers uncertain about whether their telehealth investments would remain viable year after year.

This change enables healthcare organizations to develop comprehensive telehealth strategies with confidence, make substantial technology investments without fear of policy reversals, and build sustainable virtual care programs that integrate seamlessly with in-person services. The administrative burden reduction alone will free up resources that practices can redirect toward patient care and program improvement.

Expanded Telehealth Service Coverage

CMS has approved several new telehealth services that address significant gaps in virtual care delivery. These additions reflect the agency's growing recognition that telehealth can effectively deliver a broader spectrum of healthcare services than traditional policy frameworks acknowledged.

Group Behavioral Counseling for Obesity (G0473)

With more than one-third of American adults affected by obesity, access to behavioral counseling represents a critical public health need. The addition of group behavioral counseling via telehealth eliminates transportation barriers that previously prevented many patients from accessing these services consistently.

From a practice perspective, group sessions allow providers to serve multiple patients simultaneously, improving efficiency while maintaining clinical effectiveness. Patients benefit from peer support and the convenience of participating from home, factors that significantly improve long-term adherence to behavioral modification programs.

Multiple-Family Group Psychotherapy (CPT 90849)

Anyone who has attempted to coordinate family therapy sessions understands the logistical nightmare of getting multiple family members to a single location at the same time. The telehealth expansion for CPT 90849 — Multiple-Family Group Psychotherapy — removes these coordination barriers entirely.
Families can now participate from different locations — whether separated by neighborhoods or state lines — making it possible to conduct therapy sessions that would have been logistically impossible under traditional in-person requirements. This flexibility is particularly valuable for families dealing with geographic separation due to work, education, or other circumstances.

Infectious Disease Add-On Services (G0545)

Complex infectious disease management requires frequent monitoring and expert consultation. The approval of telehealth for infectious disease add-on services (G0545) enables specialists to provide timely guidance without requiring patients to make potentially risky trips to healthcare facilities when they're already immunocompromised or actively infectious.

This change arrived at a particularly opportune moment, as healthcare systems continue managing both endemic infectious diseases and preparing for potential future outbreaks. Telehealth consultations reduce disease transmission risk while ensuring patients receive appropriate specialist oversight.

Auditory Rehabilitation Services (92622 & 92623)

Specialized hearing care often requires expertise that isn't available in many communities, particularly rural areas. By approving telehealth delivery for auditory rehabilitation services (codes 92622 and 92623), CMS has opened access to specialized care for patients who previously couldn't obtain it due to transportation challenges or geographic isolation.

The Telemedicine E/M Disappointment

Not every proposal succeeded. CMS declined to approve telemedicine evaluation and management services (98000–98015) for separate reimbursement, citing failure to meet the agency's criteria for distinct payment. This decision represents one of the few areas where CMS maintained conservative boundaries around telehealth expansion.

Frequency Limits Eliminated: The Biggest Revenue Impact

Perhaps the most significant change in the CMS 2026 proposed rule is the permanent elimination of arbitrary frequency limits on telehealth services. Before the COVID-19 pandemic, CMS imposed strict restrictions that often conflicted with sound clinical judgment:

• Subsequent inpatient visits: once every three days
• Subsequent nursing facility visits: once every 14 days
• Critical care consultations: once per day

These limitations attempted to micromanage clinical decision-making based on regulatory convenience rather than patient needs. Patients don't conveniently schedule their medical complications around CMS billing cycles, and these restrictions created situations where providers knew patients needed care but couldn't deliver it via telehealth.

The Data That Changed Everything

CMS examined their own utilization data and discovered that less than 5% of Medicare beneficiaries received these services via telehealth, and providers rarely approached the frequency limits even when they were in place. This evidence led the agency to a remarkable conclusion: perhaps they should trust physicians to determine when their patients need care.

Services Now Freed from Frequency Restrictions

The elimination applies to several critical service codes:

Subsequent Inpatient Visits (99231, 99232, 99233): Hospital-based providers can now use telehealth to check on patients as frequently as clinically indicated, rather than being restricted to once every three days.

Subsequent Nursing Facility Visits (99307, 99308, 99309, 99310): Nursing home residents can receive telehealth follow-up care as often as necessary, eliminating the previous 14-day waiting period between visits.

Critical Care Consultations (G0508, G0509): Critically ill patients can receive multiple specialist consultations per day via telehealth when their clinical condition warrants it.

Financial Implications

For hospital systems, multi-site practices, and organizations serving nursing facilities, this change creates immediate new revenue opportunities. The ability to provide more frequent telehealth follow-up visits means:

• More billable services for complex patients who require frequent monitoring
• Better clinical outcomes through timely intervention
• Reduced need for in-person visits that consume more provider time
• Improved patient satisfaction through convenient access to care

Healthcare organizations should model the financial impact by analyzing their current patient populations and identifying cases where frequency limits previously restricted telehealth utilization. The revenue increase could be substantial, particularly for practices serving complex, high-acuity patient populations.

Virtual Supervision Becomes Permanent Policy

One of the most operationally significant changes in the proposed rule involves the permanent authorization of virtual supervision for Medicare Part B services, effective January 1, 2026.

Understanding the Policy Shift

Historically, "direct supervision" requirements meant that a supervising physician had to be physically present in the same building where services were being provided. The COVID-19 public health emergency forced CMS to temporarily allow virtual supervision through real-time audio-video technology, and the experience proved that virtual oversight could maintain quality and safety standards.

The CMS 2026 rule makes this flexibility permanent, with some important caveats. Virtual supervision must occur via real-time audio-video technology—audio-only supervision doesn't meet the standard. The visual component ensures supervising physicians can actually observe what's happening during patient encounters, not just hear about it afterward.

Important Exceptions

High-risk surgical procedures identified by global surgery indicators 010 or 090 still require in-person supervision. This exception makes sense given the immediate intervention requirements and hands-on nature of surgical oversight. For these procedures, CMS has determined that physical presence remains the appropriate standard.

Operational Advantages

The permanent authorization of virtual supervision creates significant operational benefits:

Geographic Flexibility: Supervising physicians can oversee services at multiple locations without spending hours commuting between offices. A physician in one city can provide supervision for services delivered at satellite clinics or partner facilities across a broad geographic area.

Improved Resource Utilization: Healthcare organizations can deploy supervising physicians more efficiently, reducing downtime and maximizing productive capacity. Instead of one physician supervising one location, that same physician can provide oversight across multiple sites simultaneously.

Faster Response Times: When questions or complications arise, virtual supervision can often provide faster guidance than waiting for a supervising physician to physically travel to a location. Real-time audio-video consultation enables immediate problem-solving.

Cost Reduction: Reducing the travel requirements for supervising physicians cuts overhead costs significantly, particularly for organizations operating multiple facilities spread across large geographic areas.

Technology Requirements

The catch is that virtual supervision isn't something you can accomplish with consumer-grade video conferencing tools. Healthcare organizations need robust, HIPAA-compliant audio-video technology that integrates with electronic health record systems and meets medical supervision standards.

This requirement creates an immediate implementation challenge: practices must assess their current technology infrastructure, identify gaps, and make necessary upgrades before January 1, 2026. The technology investment pays for itself through improved efficiency, but it must be in place and functioning reliably when the new rules take effect.

Digital Mental Health Investment Expands

CMS is significantly expanding Medicare coverage for digital mental health treatment by including FDA-authorized digital therapeutic devices for attention-deficit/hyperactivity disorder (ADHD). This expansion represents a major policy acknowledgment that digital therapeutics—when properly validated and authorized—constitute legitimate medical interventions worthy of Medicare reimbursement.

Beyond Simple Mobile Apps

These aren't recreational wellness apps or general mindfulness programs. FDA-authorized digital therapeutics are validated medical devices that have undergone rigorous clinical testing to demonstrate safety and efficacy. They complement traditional therapy and medication management, offering patients additional treatment tools that can improve outcomes.

The Pricing Challenge

The technology is evolving so rapidly that CMS acknowledges they lack sufficient data to establish national pricing for some digital therapeutic devices. In the interim, local Medicare Administrative Contractors will determine payment rates on a case-by-case basis.

This approach creates both opportunity and uncertainty. Early adopters may find favorable local pricing, but the lack of national standardization makes it difficult to project revenue or plan large-scale implementation. Providers should engage with their MAC to understand local payment policies before investing heavily in these technologies.

Future Expansion Trajectory

CMS isn't stopping with ADHD treatments. The agency is actively soliciting input on expanding coverage to digital therapeutics for gastrointestinal conditions, sleep disorders, and fibromyalgia. This proactive approach suggests that digital mental health and digital chronic disease management will continue expanding throughout the Medicare program.

Healthcare organizations should monitor these developments closely and consider pilot programs that position them to scale quickly when additional coverage becomes available.

Remote Patient Monitoring Gains Critical Flexibility

The CMS 2026 proposed rule introduces substantial changes to remote patient monitoring (RPM) billing that make programs more flexible and financially sustainable. These modifications address two of the most significant operational challenges that have limited RPM adoption: rigid time requirements and inflexible data collection periods.

Shorter Management Time Requirements

Under current rules, providers must accumulate at least 20 minutes of monitoring and management time before they can bill for RPM services. This threshold creates situations where clinical staff provide 15 or 18 minutes of valuable monitoring and patient interaction but receive no reimbursement because they didn't reach the 20-minute mark.

The new proposal introduces billing codes that allow reimbursement for 10–19 minutes of monitoring and management time. This change dramatically improves the financial viability of RPM programs by ensuring that shorter but still clinically meaningful interactions generate appropriate revenue.

For RPM programs, this flexibility means staff can provide timely, focused interventions without feeling pressured to extend interactions artificially just to reach billing thresholds. The result should be more efficient care delivery and improved staff satisfaction.

Flexible Data Transmission Windows

Current RPM billing requires device data collection on at least 16 days within a 30-day period. While this standard makes sense for many chronic disease monitoring scenarios, it creates challenges for patients who experience intermittent symptoms or conditions that don't require such frequent monitoring.

The proposed rule introduces flexibility by allowing reporting periods of 2–15 days to qualify for certain RPM codes. This change enables providers to design monitoring protocols that match clinical needs rather than forcing all patients into the same data collection schedule.

Financial Impact for RPM Programs

Organizations already operating sophisticated RPM platforms will find these changes create immediate new revenue opportunities. The ability to bill for shorter management time means more patient interactions become reimbursable, while flexible data transmission windows allow programs to serve a broader patient population.

Healthcare systems should analyze their current RPM patient panels to identify:

• Patients currently receiving 10–19 minutes of management time who will now generate reimbursement
• Clinical scenarios where 2–15 day monitoring periods would be more appropriate than 16-day requirements
• Opportunities to expand RPM services to patient populations that didn't fit previous billing criteria

The cumulative financial impact across large patient populations could be substantial, potentially transforming marginally profitable RPM programs into significant revenue centers.

Financial Updates and Payment Adjustments

The telehealth originating site facility fee will increase from $31.01 to $31.85 for calendar year 2026. While this $0.84 increase won't transform practice economics, it demonstrates CMS's commitment to maintaining the financial infrastructure that makes telehealth accessible.

The more significant financial opportunities come from the structural changes discussed throughout this analysis: expanded service coverage, eliminated frequency limits, and new RPM billing flexibility. These changes affect fundamental revenue streams rather than providing modest cost-of-living adjustments.

Healthcare organizations should conduct comprehensive financial modeling that examines:

• Additional telehealth visits made possible by frequency limit removal
• Revenue potential from newly covered services relevant to their patient population
• RPM revenue increases from flexible time and data collection requirements
• Cost savings from virtual supervision reducing travel and facility expenses

The cumulative effect of these changes will vary significantly by organization type, patient population, and current telehealth utilization levels. However, for most providers already engaged in telehealth and RPM, the financial impact should be meaningfully positive.

Critical Unresolved Issues

The Home Address Privacy Concern

One significant issue remains unresolved despite strong provider advocacy: whether practitioners can list their practice location instead of their home address when delivering telehealth visits from home.

This may appear to be a minor administrative detail, but it carries major implications for provider safety, privacy, and operational efficiency. Many clinicians, particularly women and those practicing in contentious medical specialties, have legitimate concerns about having their personal home addresses appear in billing systems accessible to patients and potentially exposed through data breaches.

During the comment period, numerous providers raised these concerns and advocated for flexibility in address reporting. However, CMS has not yet addressed the issue in the proposed rule. This represents a notable gap, especially considering that similar flexibility was extended through 2025 with broad stakeholder support.

If this issue affects your practice, the comment period represents your opportunity to make your concerns known to CMS before the rule is finalized.

The Looming September 30 Telehealth Cliff

While providers welcome the expansion of telehealth services by Centers for Medicare & Medicaid Services (CMS), a major risk is lurking: the expiration of COVID-19 emergency flexibilities on September 30, 2025.

What’s Set to Expire on September 30

• Geographic restrictions: The temporary rule letting patients anywhere access telehealth may end — meaning many could be limited again to rural areas or designated shortage zones.
  
   
• Home as originating site: The flexibility allowing patients to use their homes for telehealth visits might vanish, forcing them to go to qualified healthcare facilities instead.
  
   
• Cross-state licensing: The ease of providing telehealth services across state lines may disappear — disrupting care for patients working with out-of-state specialists.
  
   

The Contradiction

On one hand, CMS is approving more telehealth codes and services. On the other hand, if the access‐enabling flexibilities expire, those newly approved services could become unusable for many patients.
In short: more “what” can be done via telehealth — but fewer “who” and “where” can actually use it.

Why It Matters

If these flexibilities aren’t extended:

• Patients in rural areas or with limited mobility could lose telehealth access.
  
   
• Clinics and health systems that built business models around broad telehealth access could face sudden drops in eligible patient volume and revenue.
  
   
• The strategic assumptions underpinning future investments in telehealth infrastructure could unravel.
  
   

What Needs to Happen

Only Congress has the power to extend or make permanent these flexibilities. CMS cannot do so on its own.
Therefore: healthcare organizations, provider groups, and patient advocates must mobilize to push Congressional action before September 30.

What Healthcare Providers Should Do Now

Before September 12, 2025

The comment period closing on September 12, 2025 represents your opportunity to influence the final rule. Healthcare organizations should:

Review the Proposed Rule: At minimum, review the sections directly relevant to your practice specialty and patient population. Understanding the specific changes affecting your operations is essential for strategic planning.

Submit Formal Comments: If any proposed changes would create operational challenges, financial hardships, or unintended consequences for your patient population, submit detailed comments explaining your concerns. CMS reviews and considers stakeholder feedback when finalizing rules.

Address Unresolved Issues: If the home address privacy issue or other unresolved concerns affect your practice, this is your chance to advocate for policy changes before the rule is finalized.

Engage Professional Associations: Work through your specialty societies and professional associations to submit coordinated comments on issues affecting your field.

Before January 1, 2026

Implementation planning should begin immediately after the final rule is published (typically in November 2025):

Technology Infrastructure Assessment: Evaluate your current audio-video capabilities against the requirements for virtual supervision. Identify gaps and develop an upgrade timeline that ensures compliance by January 1, 2026.

Staff Training Programs: Develop comprehensive training on new billing codes, documentation requirements, and operational procedures. Staff need to understand not just what changed, but how those changes affect their daily workflows.

Policy and Procedure Updates: Review and revise organizational policies to reflect new flexibilities, eliminate obsolete restrictions based on old frequency limits, and establish protocols for new services.

Financial Modeling: Create detailed financial projections that account for revenue opportunities from frequency limit removal, new services, and RPM billing flexibility. Use these models to set realistic targets and measure performance.

Compliance Review: Ensure billing systems, documentation templates, and quality assurance processes align with new requirements. The flexibility CMS is providing doesn't mean reduced compliance obligations—it means different compliance obligations.

Throughout 2026 and Beyond

Performance Monitoring: Track key metrics including revenue by service type, telehealth utilization rates, patient outcomes, and operational efficiency. Compare actual results against your financial models to identify variances.

Process Optimization: Use real-world experience to refine workflows, improve efficiency, and address bottlenecks. The first few months of implementation will reveal opportunities for improvement.

Ongoing Policy Engagement: Telehealth policy will continue evolving. Stay engaged with CMS guidance, MAC policy updates, and Congressional action on telehealth flexibilities. What works in early 2026 may need adjustment as additional guidance emerges.

Technology Evolution: Digital health technology advances rapidly. Regularly reassess your technology infrastructure to ensure it supports your clinical and operational objectives while maintaining compliance with evolving standards.

Strategic Implications for Digital Health Organizations

The CMS 2026 proposed rule represents a watershed moment in telehealth policy. For the first time since COVID-19 emergency declarations, CMS is expanding virtual care not as a temporary crisis response but as a permanent, integral component of the Medicare program.

The agency's approach signals a fundamental philosophical shift: CMS now trusts clinical judgment rather than attempting to micromanage every patient interaction through arbitrary restrictions. This trust creates opportunities for innovation, program development, and sustainable virtual care models.

Competitive Advantages for Early Adopters

Organizations that have already invested in telehealth infrastructure, established operational workflows, and trained staff possess significant competitive advantages. These early adopters can immediately capitalize on new revenue opportunities without delays for infrastructure development or staff training.

For organizations still developing their digital health capabilities, the CMS 2026 rule serves as an urgent call to action. The telehealth transformation is no longer approaching—it has arrived and is accelerating. Healthcare systems that delay investment risk falling behind competitors who can offer more comprehensive, convenient services to Medicare beneficiaries.

Building Sustainable Programs

The permanence of these policy changes enables long-term strategic planning that was impossible under temporary emergency waivers. Healthcare organizations can now:

• Make substantial technology investments with confidence in multi-year returns
• Develop comprehensive training programs that integrate telehealth throughout operations
• Design facility and staffing plans that assume virtual care delivery as a core component
• Create patient engagement strategies built around convenient telehealth access

The Bottom Line

The CMS 2026 Medicare Physician Fee Schedule proposed rule delivers the most significant expansion of virtual care opportunities in Medicare's history. By removing bureaucratic barriers, eliminating arbitrary frequency limits, and creating new billing flexibility for remote patient monitoring, CMS has fundamentally altered the economics and operations of virtual care.

The question facing healthcare providers isn't whether these changes will impact their practice—it's whether they'll be prepared to maximize the opportunities these changes create. CMS has signaled that virtual care is permanent, integral, and trusted. The agency is removing obstacles and relying on provider judgment.

Success requires immediate action: engaging in the comment period, planning technology upgrades, training staff, updating policies, and modeling financial impacts. Organizations that move decisively will gain competitive advantages in patient access, operational efficiency, and financial performance.

For Medicare beneficiaries, these changes promise more convenient access to care, reduced transportation burdens, and better management of chronic conditions. For healthcare providers, they offer sustainable business models built around virtual care that complements and enhances traditional in-person services.

The future of Medicare has arrived, and it includes telehealth as a permanent foundation. The only question is how quickly your organization will adapt to capitalize on the opportunity.

Frequently Asked Questions

Q: What is the CMS 2026 Medicare Physician Fee Schedule proposed rule?

The CMS 2026 proposed rule represents the most significant telehealth and RPM policy update since COVID-19, removing frequency limits, expanding covered services, streamlining approval processes, and adding new billing flexibility. It takes effect January 1, 2026.

Q: When will the CMS 2026 changes take effect?

Most provisions become effective January 1, 2026. The comment period closes September 12, 2025, with the final rule typically published in November 2025, giving providers about two months for final implementation planning.

Q: What are the biggest telehealth changes in 2026?

The elimination of arbitrary frequency limits on subsequent hospital and nursing facility visits, permanent virtual supervision authorization, streamlined service approval processes, and expanded coverage for group obesity counseling, family therapy, and infectious disease consultations.

Q: What new services are covered under CMS 2026?

New covered services include group behavioral counseling for obesity (G0473), multiple-family group psychotherapy (90849), infectious disease add-on services (G0545), and auditory rehabilitation services (92622 & 92623).

Q: What is changing with frequency limits?

CMS is permanently eliminating frequency restrictions on subsequent inpatient visits (99231-99233), subsequent nursing facility visits (99307-99310), and critical care consultations (G0508-G0509). Providers can now deliver these services as frequently as clinically indicated.

Q: What does "virtual supervision" mean under CMS 2026?

Virtual supervision allows supervising physicians to oversee Medicare Part B services via real-time audio-video technology rather than requiring physical presence in the same building. This excludes high-risk surgical procedures (global surgery indicators 010 or 090) which still require in-person supervision.

Q: How does CMS 2026 impact Remote Patient Monitoring (RPM)?

The rule adds billing codes for shorter management time (10-19 minutes instead of requiring 20+ minutes) and creates flexible data transmission windows (2-15 day periods) instead of rigid 16-day requirements, making RPM more financially viable.

Q: What does this mean for provider revenue?

Revenue opportunities expand through more billable telehealth visits (no frequency limits), new reimbursable services, additional RPM billing scenarios, and improved operational efficiency through virtual supervision. Financial impact varies by organization but should be meaningfully positive for active telehealth providers.

Q: What risks or challenges remain?

Critical challenges include the September 30, 2025 expiration of COVID-era geographic and originating site flexibilities (requiring Congressional action), unresolved home address privacy concerns, technology infrastructure requirements for virtual supervision, and the need for comprehensive staff training on new billing codes.

Q: What is the "telehealth cliff"?

The telehealth cliff refers to the September 30, 2025 expiration of COVID-19 flexibilities including waived geographic restrictions, home as originating site, and cross-state licensing provisions. Without Congressional action, these critical access provisions will end even as CMS expands covered services.

Q: Who benefits most from CMS 2026 changes?

Organizations serving complex patient populations (hospitals, nursing facilities), practices with established telehealth infrastructure, RPM programs with sophisticated platforms, multi-site healthcare systems that can leverage virtual supervision, and Medicare beneficiaries needing convenient access to chronic disease management.

Q: How should providers prepare now?

Before September 12: submit comments on the proposed rule. Before January 1, 2026: upgrade audio-video technology for virtual supervision, train staff on new billing codes, update policies and procedures, model financial impacts, and ensure compliance systems address new requirements.

Q: What will be the impact on Remote Patient Monitoring revenue?

RPM revenue should increase significantly through billing for 10-19 minute management sessions (previously unreimbursed), flexible 2-15 day data collection periods (expanding eligible patient populations), and the ability to serve more patients with monitoring protocols that match clinical needs rather than arbitrary billing requirements.

Q: Will the COVID-19 telehealth flexibilities be extended beyond September 30, 2025?

Extension requires Congressional action, which CMS cannot provide administratively. Healthcare organizations must advocate for legislative extension of geographic restrictions waivers, home as originating site provisions, and cross-state licensing flexibilities to prevent massive telehealth access reduction.