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 new 2–15 day RPM codes (e.g., CPT 99445) and corresponding RTM codes (e.g., 98984–98986) to supplement existing 16–30 day codes. These codes cannot be billed concurrently 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 10-minute treatment management codes (99470 for RPM and 98979 for RTM) valued at 0.31 work RVUs—half the value of existing 20-minute codes—to reflect proportionally shorter engagement time.

CMS also reaffirmed that “live, interactive communication” under these codes can include audio-only, video, or secure messaging interactions if they meet CPT criteria.

“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.