2026 PFS Final Rule: CMS Finalizes Key Remote Physiologic Monitoring (RPM) Updates

The Centers for Medicare & Medicaid Services (CMS) has issued the Calendar Year (CY) 2026 Physician Fee Schedule (PFS) Final Rule, bringing significant changes to the coding and valuation of Remote Physiologic Monitoring (RPM) services. These updates, driven by new CPT codes created by the CPT Editorial Panel, aim to offer greater flexibility for providers managing patient conditions like weight, blood pressure, and pulse oximetry remotely.

Two New RPM Codes Introduced for CY 2026

The CPT Editorial Panel created two new RPM codes to describe services that involve less data transmission and treatment management times. CMS is finalizing the adoption of these codes:

CPT code 99445: Device Supply for 2-15 Days

• This new code describes the initial device supply and daily recording/transmission when data is collected for 2-15 days in a 30-day period.
• The existing CPT code 99454 will continue to cover the device supply for 16-30 days in a 30-day period.
• This split allows for billing in cases where beneficiaries have acute conditions or are more stable, requiring shorter monitoring periods.

CPT code 99470: Treatment Management (First 10 Minutes)

• This new code covers treatment management services (time spent by clinical staff/physician/other qualified health care professional) for the first 10 minutes in a calendar month. It requires at least one real-time interactive communication with the patient/caregiver.
• The existing CPT code 99457 continues to describe the first 20 minutes of treatment management services.

Key Clarification: New Codes are Not Additive

• CPT code 99445 (Device Supply, 2-15 days) is not additive with CPT code 99454 (Device Supply, 16-30 days). Providers would bill for only one of these codes based on the appropriate number of days of data transmission per 30 days.
• CPT code 99470 (Treatment Management, first 10 minutes) is not additive with CPT code 99457 (Treatment Management, first 20 minutes). You must choose the single most appropriate code for the time spent that calendar month (e.g., if you reached 20 minutes, you would bill 99457, not 99470 and 99457). Additional time will continue to be billed in 20 minute increments using code 99458.

Valuation Update: 99445 and 99454 Proposed to be Reimbursed Equally

CMS proposed the same valuation for both CPT codes 99445 (2-15 days) and 99454 (16-30 days).

• Reasoning: CMS's proposal is based on the belief that the practice expense (PE) costs for these services remain the same, regardless of the number of days of data collected, because the device is supplied to the beneficiary for the full 30-day period.
• Cost Data Source: CMS proposed to utilize Hospital Outpatient Prospective Payment System (OPPS) Geometric Mean Cost (GMC) data to establish the PE valuation for both CPT codes 99445 and 99454. They believe this data is more accurate than the RUC's recommended direct PE inputs, which included components like "per-click vendor fees" that are difficult to verify.
• Commenter Feedback: Commenters who supported this equal valuation stated it would reduce administrative burden and aligns with the reality that actual technology costs are tied to the number of patients receiving the service in a 30-day period, not the number of days of data collected.

Clarifications on Interactive Communication

CMS is finalizing its policy regarding the interactive communication component required for the treatment management codes (99470, 99457, and 99458):

• Live, Interactive Communication is Required: CMS is adopting the CPT language which states that these treatment management codes "require a live, interactive communication with the patient/caregiver".
• Communication Types: CMS is not specifying further exclusions for the types of communications that can be had with the patient/caregiver, so long as they meet the CPT specifications. They clarify that for in-clinic discussions, no time or effort should be counted more than once toward the required time for any services.
• Time Allocation: The interactive communication contributes to the total time but does not need to represent the entire cumulative reported time of the treatment management service.

RPM Coding for FQHCs and RHCs

The publicly available documents from the 2026 Physician Fee Schedule (PFS) Final Rule do not explicitly detail a separate payment methodology for the new RPM codes (99445 and 99470) specifically for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs).

However, the broader context of the rule suggests how these new codes will be incorporated based on existing FQHC/RHC billing policies:

• Previous Policy (2024): FQHCs and RHCs were previously paid for care management services, which include Remote Physiologic Monitoring (RPM), using a consolidated payment mechanism—historically, an all-inclusive rate (AIR) or the special Medicare care management G-codes.
• Current Policy (2025): As of 2025, FQHCs and RHCs were allowed to bill RPM using the individual CPT codes (99453, 99454, 99457, 99458) instead of the former bundled code (G0511). This shift was aimed at aligning reimbursement and improving service tracking.
• Implication for the new RPM Codes (2026): Since FQHCs and RHCs are now billing the specific CPT codes for RPM, the two new CPT codes finalized in the 2026 PFS will likely be used by these facilities to reflect the new monitoring and time thresholds.

Future RPM Valuation Review

CMS is finalizing the maintenance of current work RVUs and direct PE inputs for several existing RPM codes (99091, 99457, and 99458) due to the lack of survey data meeting the minimum RUC requirements.

• All RPM codes are expected to be resurveyed after one year of utilization data is available for this CPT 2026 code structure.
• The entire RPM code set is currently expected to be reviewed at the January 2028 RUC meeting.

If you have any questions about the 2026 Final Rule for RPM, or want to learn how you can build and scale a Remote Patient Monitoring program for your practice, our experts are happy to help! Contact us today by filling out a “Request Demo” form on our website or emailing info@rimidi.com.