CMS Finalizes 2026 Remote Monitoring Reimbursement Updates: What Changed for RPM and RTM
A Turning Point for Digital Health Companies Offering RPM and RTM
The Final CY 2026 Medicare Physician Fee Schedule (MPFS) marks one of the most consequential rulemaking cycles for remote monitoring since the creation of the original RPM (Remote Physiologic Monitoring) codes. For the first time, CMS finalized new CPT codes supporting shorter-duration monitoring, taking a major step toward more flexible reimbursement pathways for both RPM and RTM (Remote Therapeutic Monitoring) services.
Below, we summarize what digital health companies, clinicians, and investors need to know about how these changes may reshape virtual care delivery models going forward.
New Codes for Shorter Monitoring Periods and Simplified Treatment Management
CMS finalized a new RPM supply of device code (CPT 99445) billable when between 2 and 15 days of data have been transmitted in a 30-day period. This supply of device code will be paid at the same rate as CPT code 99454, which is billable when 16 or more days of data have been transmitted in a 30-day period. The same is true for the new corresponding RTM codes (98984–98986) for 2 to 15 days of data transmitted in a 30-day period. These new codes cannot be billed concurrently with the existing supply of device codes within a 30-day period, but they create new flexibility for episodic, acute, or transitional care monitoring models such as post-discharge recovery, weight management, or behavioral interventions.
In parallel, CMS adopted new treatment management codes (99470 for RPM and 98979 for RTM) for 10 to 19 minutes of services in a calendar month. These two new codes are valued at 0.31 work RVUs—half the value of existing 20 minute treatment management codes—to reflect proportionally shorter engagement time.
CMS included a surprising response to a commenter around the “live interactive communication” requirement for RPM and RTM. The exact exchange from the Final Rule is here:
Comment: Several commenters requested clarification on whether time spent providing audio-
only communication with the patient/caregiver (for example, telephone calls) could count towards the
time counted for the interactive communication portion of CPT codes 98979, 98980, 98981, 99470,
99457, and 99458. Commenters also requested that we clarify that technological communications, such as
secure messaging, asynchronous chat, automated bi-directional messaging, and AI prompts, count
towards time for the interactive communication portion of CPT codes 98979, 98980, 98981, 99470,
99457, and 99458. Commenters requested that documented in-clinic discussions meet the interactive
communication requirement.
Response: We are clarifying that we are adopting the CPT language around this requirement. The
CPT code book states that CPT Codes 98979, 98980, 98981, 99470, 99457, and 99458 “require a live,
interactive communication with the patient/caregiver. The interactive communication contributes to the
total time, but it does not need to represent the entire cumulative reported time of the treatment
management service.” We are 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. For in-clinic discussions,
no time or effort should be counted more than once toward the required time for any servicesAt first glance, this language seems to contradict CMS policy in the 2021 Final MPFS. In that Rule, CMS stated “interactive communication for purposes of CPT codes 99457 and 99458 involves, at a minimum, real-time synchronous, two-way audio interaction that is capable of being enhanced with video or other kinds of data transmission.” This clearly eliminates text messaging as a form of “interactive communication” for purposes of these codes. A closer reading of the exchange above may suggest that CMS intends to adopt any language that the 2026 CPT Manual may include about “interactive communications.” For example, if the CPT Manual defines text messaging as “interactive communication,” then CMS will adopt that definition.
Also surprising is the language that could be read to include in-clinic discussions as time counted toward RPM or RTM services. Both CMS and the CPT Manual have explicitly prohibited in-clinic discussion time as attributable to time requirements for RPM or RTM.
“Sometimes Therapy” Designation for RTM
CMS adopted the full 2026 CPT code descriptors and clarified how the new RTM codes will be treated:
CPT 98979, 98984, and 98985 are now designated as “sometimes therapy” services.
CQ/CO modifiers apply when furnished by therapy assistants, but not for device supply codes.
CMS again declined to expand provider eligibility (e.g., to pharmacists or dietitians) due to statutory constraints.
No policy changes were made around concurrent RPM/RTM billing, multi-device use, or global period overlap, though CMS signaled openness to revisit these in future rulemaking.
Key Valuation Decisions: CMS Leans on OPPS Data
For both RPM and RTM device supply codes, CMS finalized valuations based on Outpatient Prospective Payment System (OPPS) Geometric Mean Cost (GMC) data rather than practice-based invoices. Valuations will be calculated by dividing each code’s CY 2026 GMC by the CY 2026 PFS Conversion Factor.
Why it matters:
CMS views OPPS data as auditable, standardized, and regularly updated, offering a more consistent valuation baseline.
Critics argue OPPS cost structures differ significantly from physician offices, but CMS maintained that device costs are largely comparable across care settings.
This shift toward OPPS-based valuation reflects a broader modernization of CMS’s Practice Expense (PE) methodology, which increasingly aims to capture software-as-a-service (SaaS) costs, cloud storage, and cybersecurity expenses as critical components of digital care infrastructure.
RPM Valuations at a Glance
99445 (new, <16 days): Valued using OPPS GMC ÷ PFS Conversion Factor.
99454 (16–30 days): Maintains existing structure and value parity.
99470 (10-minute management): Finalized at 0.31 RVUs, half of 99457’s 0.61.
99457 and 99458: Retain current values.]
99091 (data analysis): Maintained at 1.10 RVUs despite RUC’s lower recommendation.
Setup and education code 99453 now requires at least 2 days of monitoring to qualify for reimbursement.
RTM Valuations and Crosswalks
98979 (10 minutes): 0.31 RVUs
98980 (20 minutes): 0.62 RVUs
98981 (add’l 20 minutes): 0.61 RVUs
98985 and 98977: Valued using OPPS GMC data
98978 and 98986: Retain contractor pricing (MAC discretion) due to technology variability
CMS crosswalked 98984 to 99454 to ensure alignment between physiologic and therapeutic monitoring reimbursement.
Maintaining Parity Between RPM and RTM
CMS reaffirmed its intent to preserve relativity between RPM and RTM valuations in recognition of the parallel structure of the services. Stakeholders remained divided in their comments; some advocated parity to support adoption and workflow integration, while others argued that therapeutic monitoring requires distinct staffing and technology.
For now, CMS will monitor utilization and revisit the issue as data accumulates, particularly with RTM still on the New Technology list for three years.
Broader Implications for Digital Health and Virtual Care
Validation of short-duration codes – Enables reimbursement for acute and episodic use cases—key for hybrid care models.
RPM–RTM parity – Promotes consistent business modeling across physiologic and therapeutic programs.
Reliance on OPPS data – Sets precedent for valuing SaaS and subscription-based models under PFS.
Provider eligibility limits – Reinforces physician/NPP oversight requirement, constraining expansion to pharmacists.
Future reassessment – Expect continued evolution as CMS refines valuation methods and data sources.
How Nixon Law Group Can Help
Nixon Law Group has been deeply engaged in remote monitoring reimbursement policy since the inception of the RPM and RTM codes. Our attorneys work closely with digital health companies, device manufacturers, and providers to ensure compliant implementation, optimize reimbursement workflows, and anticipate evolving CMS valuation methodologies.
To learn more or schedule a consult, contact us.