CMS 2026 Proposed Rule: Complete Provider Guide to Simplified RPM

The Centers for Medicare & Medicaid Services (CMS) released the 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule in July 2025, with the Final Rule published in November 2025. 

This annual update brings sweeping changes to Medicare payments, with a strong focus on simplifying digital care reimbursement, enhancing remote care delivery, and supporting small and independent practices.

At the heart of the 2026 update is a significant redefinition of Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) policies. CMS prioritizes flexibility in RPM and RTM services, making it easier for clinicians to deliver, document, and bill for these remote care modalities. 

This evolution reflects CMS's broader vision to promote patient-centered, efficient digital care that extends beyond traditional clinical settings.

The CMS 2026 rule marks a turning point redefining how clinicians can deliver, document, and bill for remote care.

This guide helps providers, administrators, and billing teams understand the key changes, implications, and preparation steps needed to leverage the new RPM and RTM provisions effectively in 2026.

Historical Context: Evolution of Remote Patient Monitoring Under Medicare

The Foundation (2019-2020)

Remote Patient Monitoring (RPM) under Medicare has markedly evolved from 2019 to 2025, both in policy scope and practical use. The 2019 Medicare Physician Fee Schedule first introduced dedicated RPM codes:

• CPT 99453 – Onboarding and education
• CPT 99454 – Device supply/data transmission for 16+ days per month
• CPT 99457 – 20+ minutes of care management
• CPT 99458 – Each additional 20 minutes of management

These codes were designed to support tech-enabled monitoring of chronic and acute conditions.

The Acceleration (2020-2021)

The COVID-19 pandemic served as a major inflection point, dramatically accelerating adoption and acceptance of telehealth and remote services within Medicare. Remote monitoring claims soared by over 500%, and telehealth was broadly expanded even allowing beneficiaries to access care from their homes with minimal restrictions. 

Temporary policy waivers allowed for more flexible billing, availability of additional codes, and relaxed geographic and modality requirements, giving providers critical tools during the public health emergency.

Persistent Challenges

Despite increased usage, providers faced persistent pain points:

• The 16-day data rule for 99454 limited billing if less than 16 days of device data were collected in a 30-day period
• Limited CPT codes restricted reimbursement for less frequent (but clinically valuable) monitoring
• Short-duration monitoring often went uncompensated, despite clinical merit, as earlier codes didn't reflect shorter, meaningful engagement or acute episodes
• Documentation and program complexity left smaller practices at a disadvantage

The 2026 Reform Rationale

The rationale for the 2026 reform is to finally align RPM with real-world clinical workflows and Medicare's broader shift to value-based, outcome-driven care. By recognizing the clinical value of shorter monitoring periods, simplifying billing structures, and expanding access, CMS aims to reward proactive, technology-enabled care especially for small and rural providers while moving closer to its vision for modern, patient-centered health delivery.

Overview: What's New in the 2026 CMS Proposed Rule

The 2026 CMS Proposed Rule introduces several key updates centered around enhancing flexibility and expanding access in Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM).

Major Policy Changes

New CPT Codes

• Introduction of new CPT codes for both RPM (99445, 99470) and RTM (98985, 98979), reflecting expanded service options and reimbursement opportunities

Permanent Virtual Direct Supervision

• Establishes permanent virtual direct supervision, allowing clinicians to supervise services remotely with real-time audio-video technology, improving operational flexibility

Code Streamlining

• Outdated G-codes such as G0511, G0512, and G0136 are removed to streamline the coding system

Behavioral Health Integration

• Enhanced emphasis on Behavioral Health Integration (BHI) within the new Advanced Primary Care Model (APCM), supporting a more holistic approach to patient care that integrates mental and physical health services

Expanded Telehealth Eligibility

• Telehealth eligibility expanded for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs), broadening access for underserved populations

Quality Focus

• CMS maintains continued focus on equity, patient access, and documentation compliance to ensure quality care delivery and address disparities in healthcare

Strategic Vision

These changes collectively underscore CMS's commitment to modernizing Medicare's digital care framework and encouraging wider adoption of remote care technologies as part of value-based care strategies. This sets the stage for providers, administrators, and billing teams to adapt workflows, update billing systems, and prepare for the expanded opportunities for delivering and reimbursing remote care in 2026.

Core Changes: RPM Enhancements in the 2026 Proposed Rule

New RPM Device Supply Code – CPT 99445

What It Is: The 2026 rule introduces a new CPT code 99445 that reimburses device supply and data collection for shorter periods of 2 to 15 days, versus the previous requirement of at least 16 days (CPT 99454).

Key Features

• Allows clinicians to bill for monitoring during short-term scenarios such as post-operative recovery, medication titration, or acute flare-up monitoring
• Payment parity with CPT 99454 – same reimbursement rate applies despite the shorter monitoring window

Benefits This improvement enhances workflow for smaller practices by allowing reimbursement for clinically meaningful short-term monitoring without waiting to reach the 16-day threshold, thus improving return on investment (ROI) in RPM programs.

New Short-Duration Clinical Time Code – CPT 99470

What It Is: CPT 99470 is designed for RPM clinical management involving 10 to 20 minutes of service per month, reimbursed at 50% of the payment for CPT 99457 (20+ minutes).

Key Features

• Supports billing for micro-engagements like brief data review or quick patient follow-ups
• Example: A physician's 12-minute medication adjustment following abnormal vital signs can now be compensated

Benefits This flexibility improves provider efficiency, optimizes compensation for short clinical encounters, and helps reduce burnout by recognizing the value of brief but impactful patient interactions.

Longitudinal RPM and Chronic Care Synergy

The Paradigm Shift CMS's 2026 approach emphasizes a shift from episodic monitoring to continuous, longitudinal care. RPM is increasingly viewed as complementary to Chronic Care Management (CCM) and Transitional Care Management (TCM) programs.

Key Updates

• Clarified guidelines on how RPM clinical time overlaps or can be distinct from CCM time documentation
• Enables hybrid billing opportunities
• Supports integrated patient care, allowing providers to leverage RPM to augment chronic disease management strategies more effectively

Flexibility for Episodic & Preventive Care

Expanded Scope Recognizing diverse clinical needs, CMS explicitly supports episodic RPM models for short-term or event-driven monitoring such as:

• Acute illness follow-ups
• Preventive health programs

Broadened Eligibility The 2026 rule broadens patient eligibility beyond just chronic conditions, including wellness monitoring and preventive care scenarios. This creates new pathways to incorporate RPM into broader care plans, enhancing health outcomes and enabling proactive interventions.

Remote Therapeutic Monitoring (RTM) Updates

RTM Short-Duration Codes

CMS's 2026 Proposed Rule introduces two new RTM CPT codes to increase flexibility similar to the RPM enhancements:

CMS's 2026 Proposed Rule introduces two new RTM CPT codes to increase flexibility similar to the RPM enhancements: 

CPT 98985 

Covers device supply and data monitoring for 2 to 15 days of non-physiologic therapeutic data collection May include parameters such as patient adherence to therapy, musculoskeletal recovery metrics, or pain levels 

CPT 98979 

Reimburses 10 to 20 minutes of related clinical management time Allows billing for shorter, focused therapeutic monitoring engagements

Use Cases These new codes address common scenarios such as:

• Monitoring patient compliance during physiotherapy
• Tracking post-surgery rehabilitation progress

This flexibility aligns RTM more closely with the evolving needs of therapy-based remote care, enabling more timely and relevant reimbursement for episodic or short-term therapeutic monitoring activities.

Integration of RTM with RPM

Unified Approach The 2026 rule promotes unified documentation and streamlined clinical workflows when implementing hybrid RPM and RTM programs.

Benefits

• Providers can leverage the overlap of physiologic and therapeutic data streams to deliver comprehensive remote monitoring services
• Combining RPM and RTM maximizes reimbursement opportunities while providing a more holistic picture of patient health and recovery
• Clear guidance encourages integrating these modalities into coordinated care plans that optimize both clinical outcomes and billing efficiency

Behavioral Health Integration (BHI) in APCM

The New BHI Code

The 2026 CMS Proposed Rule introduces a new Behavioral Health Integration code under the Advanced Primary Care Model (APCM), designated as GPCM3. This addition formalizes support for clinics integrating mental health services with physical health management, recognizing the critical role of behavioral health in comprehensive primary care.

Strategic Importance

This BHI enhancement is especially important for:

• Rural practices
• Primary care providers (PCPs) who frequently manage patients with complex comorbidities involving mental health conditions

By promoting integrated care workflows and reimbursement for behavioral health activities, CMS aims to improve access and outcomes for patients facing mental and physical health challenges concurrently.

Integration with Existing Services

BHI in APCM potentially overlaps with existing Chronic Care Management (CCM) and Remote Patient Monitoring (RPM) services, particularly as mental health conditions can be tracked and managed remotely. This integration enables a cohesive approach to mental health monitoring and intervention within broader chronic care and remote monitoring programs, supporting holistic patient care.

Key Code Deletions and Realignments

The 2026 CMS Proposed Rule includes several important code deletions aimed at simplifying billing and clarifying reimbursement pathways.

Deleted Codes

Social Determinants of Health (SDOH) – G0136

• CMS is shifting toward integrating social and behavioral determinants directly within care management programs like Chronic Care Management (CCM) and the Advanced Primary Care Model (APCM)
• Reflects a more holistic and streamlined approach to addressing these critical factors in patient care

Remote Care G-Codes – G0511 and G0512

• Historically used for certain services in Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)
• Replaced with the newer APCM codes
• Reduces duplication and provides clearer billing frameworks especially for RHC/FQHC settings

CMS's Intent

CMS's intent with these realignments is to:

• Simplify reimbursement processes
• Reduce confusion from overlapping billing rules
• Promote integrated, efficient care management that aligns with evolving digital care models like RPM and Primary Care Management (PCM)

Care Management vs. Care Coordination: CMS Clarifies the Distinction

Definitions and Documentation Standards

CMS in the 2026 Proposed Rule clearly distinguishes between care management and care coordination activities to improve clarity and reduce billing errors.

Care Management

• Refers to the direct clinical management of patients' chronic or complex conditions
• Includes assessment, treatment planning, monitoring (e.g., RPM/RTM), and therapeutic interventions
• Involves clinical decision-making and ongoing patient management

Care Coordination

• Involves activities that ensure patients receive the appropriate services and resources
• Includes connecting patients to specialists, arranging referrals, and facilitating communication among providers and caregivers
• Supports the clinical care plan but is not itself clinical management

Documentation Requirements Documentation requirements emphasize detailed records of clinical encounters, time spent, and specific clinical tasks performed, particularly for care management codes like CCM, RPM, and BHI.

Billing When Activities Overlap

CMS acknowledges that RPM, CCM (Chronic Care Management), and BHI (Behavioral Health Integration) often have overlapping activities but provides guidance to avoid double billing:

Separation Guidelines

• Clinical time spent on RPM or RTM management should be distinctly documented and billed using RPM/RTM-specific codes
• Time allocated to broader chronic condition management outside of direct remote monitoring can be billed under CCM
• Behavioral health services can be billed under the BHI codes when addressing mental health components, with clear separation from physical health management

Compliance Requirement Providers should carefully document and differentiate services, ensuring no single minute of clinical time is counted toward more than one reimbursable service to comply with CMS rules.

Financial & Operational Implications for Providers

Financial Benefits

The 2026 CMS rule offers tangible financial advantages for providers through expanded reimbursement opportunities:

Revenue Capture from Shorter Interactions

• New codes for shorter device data collection (2–15 days) and brief clinical time (10–20 minutes) enable billing for engagements previously uncompensated
• Unlocks revenue from micro-interactions

Expanded Patient Eligibility

• The broadening of patient criteria beyond chronic conditions significantly increases the pool of eligible patients
• Expands the revenue base for RPM and RTM services

Shorter ROI Cycle

• The allowance for shorter monitoring periods accelerates the return on investment
• Enables practices to realize financial benefits more quickly compared to the prior ≥16-day requirement

Case Study Comparison Providers adopting the 2026 model can generate higher monthly reimbursement per patient with flexible service options compared to 2025 models that limited billing to longer monitoring periods and fewer codes, improving cash flow and program sustainability.

Operational Benefits

Operationally, the changes promote more efficient and manageable workflows:

Reduced Burnout

• By allowing billing for shorter, more frequent interactions, clinicians can spread workload more evenly
• Reduces the intensity and stress of longer sessions

Flexible Workflows

• Virtual direct supervision and simplified documentation requirements facilitate hybrid in-person/remote workflows
• Adapts to provider preferences and patient needs

Easier Adoption for Small/Rural Practices

• The shorter monitoring thresholds and flexible coding encourage uptake among smaller, resource-constrained practices
• Addresses struggles with previous RPM time and data requirements

Improved Patient Engagement

• Shorter, attainable care cycles encourage continuous patient involvement and adherence
• Enhances care quality and outcomes

These financial and operational impacts position providers to deliver modern, value-based digital care with greater sustainability, efficiency, and patient-centeredness under the 2026 CMS framework.

Compliance & Documentation Considerations

CMS Scrutiny and Documentation Standards

Despite the 2026 rule's flexibility enhancements, CMS maintains rigorous oversight on documentation. Providers must keep precise, auditable records of:

• Clinical time spent
• Services delivered for RPM codes (including new CPT 99445 and 99470)

Documentation Requirements Documentation should clearly delineate:

• Patient interactions
• Time spent on monitoring and management
• Clinical decision-making processes to support claims

Avoiding Overbilling or Micro-Fragmentation

CMS Caution CMS cautions against "micro-fragmentation"   breaking clinical time into multiple short increments to maximize reimbursement improperly.

Compliance Requirements

• Providers must ensure that time billed reflects actual continuous clinical engagement
• Avoid overlapping claims for the same minutes of service across RPM, CCM, or other codes
• Proper aggregation of clinical time and events is essential for compliance

Sample Compliance Checklist for CPT 99445/99470 Documentation

✓ Detailed logs of RPM device data collection dates and duration (for 2–15 days under 99445) 

✓ Time-stamped clinical notes documenting specific clinical actions or patient communications corresponding to billed minutes (10–20 minutes for 99470) 

✓ Evidence of patient consent and education related to RPM services 

✓ Clear distinction from other care management or coordination activities billed concurrently

 ✓ Consistent updating of patient records with RPM findings and care plans

Integration into EHR and Billing Systems

To facilitate documentation compliance and streamline billing, practices should integrate new RPM codes into their Electronic Health Records (EHR) and billing platforms. This includes:

• Workflow prompts for time tracking
• Audit trails
• Flags for overlapping billing risks

Automation Benefits Automation aids such as RPM-specific templates, alerts for documentation completeness, and built-in compliance checks reduce administrative burden and risk exposure.

Provider Preparation Checklist for 2026

Step 1: Audit Patient Base

Identify patients who could benefit from short-term RPM monitoring (2–15 day cycles) such as:

• Post-op recovery
• Acute flare-ups
• Medication titration cases
• Cases beyond traditional chronic monitoring

Step 2: Train Care Teams

Educate clinical and administrative staff on:

• New CPT codes 99445 (device supply, short duration) and 99470 (short clinical time)
• Accurate documentation standards and coding rules to ensure compliance

Step 3: Update Clinical Protocols

• Revise RPM monitoring protocols to incorporate shorter monitoring and management cycles
• Adjust workflows to integrate episodic and preventive RPM use cases

Step 4: Configure Billing Systems

• Work with billing and EHR vendors to integrate new RPM codes into coding and billing software
• Ensure time tracking and documentation prompts align with the 2026 compliance checklist

Step 5: Review Vendor Partnerships

Assess RPM platform and device provider contracts and capabilities to support:

• Shorter monitoring durations
• Enhanced data reporting as required by CMS

Step 6: Educate Patients

Communicate the expanded and more flexible RPM service options to patients, highlighting how short-term remote monitoring can support:

• Recovery
• Wellness
• Acute care needs more responsively

Broader Policy and Market Implications

Alignment with Value-Based Care

CMS's 2026 updates clearly intend to reinforce value-based care principles by rewarding proactive, preventive, and personalized care management approaches. The introduction of flexible RPM and RTM codes aligns well with Alternative Payment Models (APMs) that emphasize outcomes and continuous patient engagement over episodic services.

By enabling shorter, tailored monitoring episodes and integrating behavioral health, CMS fosters a more holistic, patient-centered care paradigm that supports better health outcomes at controlled costs.

Impact on Digital Health Vendors

Market Opportunity The market opportunity for digital health vendors is significant with these regulatory shifts. Demand is rising for:

• AI-enhanced, interoperable, plug-and-play RPM solutions
• Simplified data collection, analytics, and real-time clinician decision support

Vendor Opportunities Vendors can expand offerings in:

• Training programs
• User-friendly analytics dashboards
• Workflow automation
• Compliance management tools

The rule signals growth potential for vendors willing to innovate in seamless care integration and provider enablement.

The Case for "Physical Activity as a Vital Sign"

An emerging industry conversation, supported by CMS's recent Request for Information (RFI), explores incorporating physical activity as a standard vital sign tracked via RPM. This highlights expanding RPM parameters beyond traditional physiologic metrics to include lifestyle and behavioral indicators.

Implications Such developments have strong implications for:

• Wearable and consumer-grade device integration
• Closer alignment of clinical care with everyday patient health behaviors

This evolution could transform remote monitoring into a more comprehensive health management tool.

Future Outlook: Where CMS Is Headed Post-2026

Expansion of Flexibility

Building on the 2026 reforms, CMS is expected to further expand flexibility in reimbursement across:

• Remote Therapeutic Monitoring (RTM)
• Chronic Care Management (CCM)
• Primary Care Management (PCM)

This includes more nuanced coding options reflecting varied patient needs and care modalities, allowing providers to capture value from a broad spectrum of remote and longitudinal care activities.

Integration of Consumer-Grade Wearables

CMS is likely to increase acceptance and integration of consumer-grade wearables and health tracking devices into reimbursable care programs. As CMS explores "physical activity as a vital sign" and other non-traditional metrics, wearable data could become a reimbursable element within remote monitoring frameworks, supporting continuous, real-world patient health insights.

Collaborative Ecosystem Development

Greater collaboration between primary care providers and digital health vendors will be essential, with CMS encouraging interoperable, user-friendly platforms that support:

• Clinical decision-making
• Data analytics
• Compliance
• Patient engagement

Vendors that can seamlessly integrate into primary care workflows and demonstrate value in improving outcomes will be preferred partners.

Long-Term Strategy: Outcome-Based and Hybrid Care Models

Ultimately, CMS's long-term strategy aims at driving outcome-based reimbursement models that reward quality and efficiency over volume. Hybrid care models, blending in-person and virtual services enabled by advanced remote monitoring, will become the standard. This patient-centric approach balances accessibility, personalization, and cost-effectiveness aligned with evolving Medicare goals.

Timeline of RPM Under Medicare

Conclusion: CMS 2026 – Simplifying Remote Care for the Next Decade

Summary of Transformative Changes

The CMS 2026 rule represents a transformative evolution in remote care delivery by introducing a flexible, inclusive, and value-driven RPM framework. Key changes include:

New CPT Codes

• Shorter data collection periods (2–15 days)
• Reduced clinical time requirements (10–20 minutes)
• Makes remote monitoring more accessible and financially viable for providers, especially small and rural practices

Broadened Eligibility These updates broaden patient eligibility beyond traditional chronic conditions, fostering earlier, preventive, and acute care interventions.

Impact Across Stakeholders

For Patients The changes improve access to care that is timely and personalized, supporting better engagement and health outcomes.

For Providers Providers benefit from:

• Enhanced revenue capture
• Streamlined workflows
• Reduced burnout risks due to more flexible service models

For CMS These reforms promise better cost efficiency by incentivizing outcome-focused care and reducing duplicative or fragmented billing.

The Blueprint for the Future

In summary, the 2026 CMS rule is not merely a payment update it is a blueprint for the next decade of remote, connected healthcare. It aligns with broader trends toward:

• Value-based care
• Digital health innovation
• Integrated patient management

This sets the stage for continuous advancement in how healthcare is delivered and reimbursed in the Medicare program.

Frequently Asked Questions (FAQs)

1. What is the CMS 2026 Proposed Rule?

The CMS 2026 Proposed Rule is the annual Medicare Physician Fee Schedule (PFS) update that outlines payment policies, coding changes, and regulatory updates for 2026. It simplifies reimbursement for digital health services, including Remote Patient Monitoring (RPM), Remote Therapeutic Monitoring (RTM), and Behavioral Health Integration (BHI).

2. How does the 2026 CMS Rule change RPM billing?

The 2026 CMS Rule introduces two new CPT codes (99445 and 99470) allowing billing for shorter data collection (2–15 days) and clinical time (10–20 minutes). This eliminates the strict 16-day data rule and provides more flexible reimbursement options for brief or episodic monitoring.

3. What are the new RPM CPT codes introduced for 2026?

CPT 99445: Device supply and data collection for 2–15 days

CPT 99470: Clinical management time of 10–20 minutes

These codes supplement existing RPM codes (99453–99458) and make short-duration monitoring billable.

 

4. How does the new rule affect RTM (Remote Therapeutic Monitoring)?

The 2026 CMS update introduces RTM CPT codes 98985 and 98979 for shorter-duration device use and clinical management. These updates expand flexibility for therapy-based monitoring like musculoskeletal rehab, medication adherence, and behavioral therapy programs.

5. What is “virtual direct supervision,” and why is it important?

Virtual direct supervision, now made permanent under the 2026 rule, allows supervising clinicians to oversee care teams remotely via real-time audio-video technology. This supports hybrid and remote care delivery models, improving accessibility for smaller and rural practices.

6. Can RPM now be used for short-term or preventive care?

Yes. CMS 2026 broadens RPM eligibility beyond chronic conditions. Providers can now bill RPM for acute conditions, post-operative monitoring, or preventive wellness programs — supporting a proactive approach to patient health.

7. What codes were deleted or replaced in the 2026 CMS update?

CMS removed several outdated or overlapping codes, including:

• G0136 (Social Determinants of Health Assessment)
  
   
• G0511, G0512 (RHC/FQHC Remote Care Codes)
  These were replaced by simplified APCM and care management codes to reduce billing confusion and streamline reimbursement.
  
   

8. How should providers prepare for the 2026 RPM rule changes?

Providers should:

1.  Providers should: Train teams on new CPT codes (99445, 99470, 98985, 98979)
   
    
2. Update EHR and billing systems
   
    
3. Revise RPM protocols for shorter monitoring cycles
   
    
4. Audit current patient populations to identify new RPM use cases
   
    
5. Educate patients on expanded RPM and RTM service options