Decoding the 2026 Medicare Fee Schedule for RPM and RTM

The Centers for Medicare & Medicaid Services (CMS) has released its proposed rule for the 2026 Medicare Physician Fee Schedule, signaling significant advancements for Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM). These proposed changes are designed to expand patient access, streamline billing processes, and enhance revenue opportunities for healthcare providers. For organizations committed to delivering exceptional remote care, understanding these updates is critical for strategic planning and operational readiness.

This article provides an in-depth analysis of the proposed 2026 Medicare Fee Schedule for RPM and RTM. We will explore the key changes, their direct impact on clinical workflows and reimbursement, and how your practice can prepare to leverage these new opportunities for growth and improved patient outcomes.

Key Proposed Changes for RPM & RTM in 2026

The proposed rule introduces a more flexible and realistic framework for remote care reimbursement. It acknowledges that patient needs and engagement levels vary, moving away from a rigid, one-size-fits-all model. Here are the most impactful updates.

Flexible Device Data Collection Periods

A major shift is the proposal to allow billing for shorter monitoring periods. Instead of the previous 16-day minimum, CMS is introducing new codes that cover a data transmission period of just 2 to 15 days within a 30-day window.

• Previous Requirement: At least 16 days of data transmissions were needed to bill for device supply (CPT 99454).
• Proposed Change: New codes will allow billing for shorter, more flexible periods, making it possible to get reimbursed for patients who require short-term monitoring or who are less consistent with device usage.
• Impact: This permanently removes the "all-or-nothing" barrier, enabling providers to enroll a wider range of patients, such as post-operative individuals or those with episodic conditions.

Shorter Billable Time for Care Management

Recognizing that not every patient interaction requires 20 minutes, CMS has proposed new codes for shorter clinical encounters.

• Previous Requirement: A minimum of 20 minutes of care management time was required to bill CPT codes 99457 (RPM) and 98980 (RTM).
• Proposed Change: New codes will permit billing for 10 to 19 minutes of care management, typically at a reduced reimbursement rate.
• Impact: This change allows practices to bill for the brief, yet clinically significant, check-ins that are common in remote care. It aligns reimbursement with the true clinical effort involved in proactive patient management.

RTM Achieves Greater Parity with RPM

Remote Therapeutic Monitoring is set to receive updates that bring its billing structure more in line with RPM. The new framework will apply to respiratory, musculoskeletal, and cognitive behavioral therapy monitoring, creating consistency across remote care services. This includes adopting the same flexible 2–15 day and standard 16–30 day data collection structures.

Analyzing the Proposed 2026 Medicare Fee Schedule for RPM and RTM

These proposed updates from CMS are more than just administrative changes; they represent a strategic shift toward integrating remote care as a standard component of modern healthcare. Here’s what this evolution means for healthcare organizations.

1. Broader Patient Access and Health Equity

The introduction of a 2-15 day monitoring window is a significant step toward more equitable care. It allows providers to serve patients who were previously excluded from RPM and RTM programs. This includes:

• Patients recovering from surgery who only need short-term monitoring.
• Individuals in rural areas with inconsistent internet connectivity.
• Patients with chronic conditions who may struggle to meet a 16-day minimum each month.

By accommodating these populations, practices can expand their reach and deliver proactive care to more people in their communities.

2. Financial Models Aligned with Clinical Reality

The ability to bill for 10-19 minute interactions provides new financial flexibility. It ensures that providers are compensated for the valuable, shorter check-ins that can prevent minor issues from escalating. This change supports financial models that blend fee-for-service billing with value-based care objectives, incentivizing proactive outreach that keeps patients healthy and reduces hospital readmissions.

3. A Foundation for Long-Term Digital Health Strategy

CMS's continued refinement of RPM and RTM codes solidifies remote monitoring as an essential element of healthcare delivery. These proposals encourage organizations to make long-term investments in their digital health infrastructure. As you evaluate technology partners, consider solutions that are not only compliant with today's rules but are also scalable and adaptable for future initiatives like Hospital-at-Home programs and fully integrated care models.

4. The Growing Importance of Compliance and Documentation

With increased billing flexibility comes a greater need for meticulous compliance. The new codes introduce additional operational and documentation requirements. To mitigate audit risks, it is essential to have a robust system for tracking data transmissions and clinical time. Investing in an advanced remote care platform with automated data capture and comprehensive audit trails will be crucial. This allows your clinical staff to focus on patient care, not paperwork.

2025 vs. 2026 RPM & RTM Billing Codes Comparison

Rates and codes are subject to CMS finalization; see the CMS Fact Sheet, NatLawReview summary, ChartSpan analysis, Prevounce blog, CareSimple executive summary

Preparing Your Practice for 2026

The proposed 2026 Medicare Fee Schedule for RPM and RTM offers a clear path toward a more flexible and inclusive future for remote care. While these rules are not yet final, proactive organizations can begin preparing now.

• Review Your Patient Population: Identify patient groups who could benefit from the new, shorter monitoring periods.
• Educate Your Clinical Team: Ensure your staff understands the new time-tracking and documentation requirements for the proposed 10-19 minute billing codes.
• Evaluate Your Technology: Assess whether your current RPM/RTM platform can support the new coding structure and provide the necessary compliance and audit documentation.
• Partner for Success: Consider partnering with a dedicated remote care provider who can manage the complexities of billing, device logistics, and clinical monitoring, allowing you to focus on delivering excellent care.

By thoughtfully preparing for these changes, your practice can effectively serve more patients, enhance operational efficiency, and strengthen its financial position in an evolving healthcare landscape.

Frequently Asked Questions (FAQ)

What is the most significant change in the proposed 2026 Medicare Fee Schedule for RPM and RTM?
The most significant change is the introduction of new billing codes that allow for shorter data collection periods of 2-15 days, in addition to the existing 16-day requirement. This makes it possible to bill for patients who require short-term or intermittent monitoring, expanding access to care.

Will the existing RPM and RTM codes change?
No, the existing CPT codes for 16+ days of monitoring and 20+ minutes of care management are expected to remain. The proposed rule adds new codes for shorter durations, providing more flexibility rather than replacing the current structure.

How does the new 10-19 minute billing code for care management work?
CMS has proposed new codes (e.g., 99XX5 for RPM) that allow providers to bill for care management activities lasting between 10 and 19 minutes. The reimbursement rate will be lower than the code for 20+ minutes (CPT 99457), but it ensures compensation for briefer, yet clinically important, patient interactions.

Why is CMS making these changes to the Medicare Physician Fee Schedule?
CMS is aiming to make remote care services more accessible and align reimbursement with real-world clinical practice. The changes in the proposed 2026 Medicare Fee Schedule for RPM and RTM are designed to remove barriers to entry for both patients and providers, encouraging wider adoption of these valuable services.

How can my practice prepare for the 2026 RPM and RTM updates?
To prepare, your practice should educate staff on the new billing and documentation requirements, identify patients who would qualify under the flexible monitoring periods, and evaluate your technology to ensure it can support the new codes and compliance needs. Partnering with a specialized remote care management service can also help streamline this transition.