Distant Affected person Monitoring (RPM) and Distant Therapeutic Monitoring (RTM): What You Must Know About CMS’ Proposed Modifications

On July 14, 2025, the Facilities for Medicare and Medicaid Companies (CMS) proposed key adjustments to distant affected person monitoring (RPM) and distant therapeutic monitoring (RTM) companies reimbursed below the Medicare program. The adjustments, a part of the proposed 2026 Medicare Doctor Charge Schedule rule (the Proposed Rule), have been anticipated by digital well being suppliers and stakeholders hoping to see extra flexibility for RPM and RTM companies. 

This text discusses the brand new adjustments and proposed codes and explains the best way to submit public feedback on the Proposed Rule. 

1. Proposed RPM & RTM Billing for 2-15 Days of Information Transmissions

Traditionally, system provide codes for each RPM and RTM required no less than 16 days of knowledge transmission per 30-day interval to be eligible for reimbursement by Medicare. In different phrases, if information transmission happens 15 days in a 30-day interval, no reimbursement might be claimed. Particularly, this requirement applies to CPT codes 99454 (RPM), 98976 (RTM-respiratory), 98977 (RTM-musculoskeletal), and 98978 (RTM-cognitive behavioral remedy). 

CMS now proposes so as to add new system provide codes for each RPM and RTM that may also permit for information transmission over a interval of 2-15 days per 30-day interval. The desk beneath lists the proposed new system provide codes for 2026.

This transformation comes after a number of years of stakeholder suggestions that the 16-day billing threshold was not vital or applicable in sure medical use instances. The brand new codes would offer a brand new pathway for billing in situations the place sufferers don’t meet the 16-day requirement however are offered shorter monitoring intervals which might be clinically significant.

It’s notable that CPT Codes 99453 (RPM) and 98975 (RTM) overlaying the preliminary set-up and affected person schooling companies would nonetheless require 16 days of knowledge transmission through the 30-day interval to be eligible for reimbursement.

If this rule is finalized as proposed, RPM and RTM suppliers would want to implement programs and processes to trace which sufferers meet which information transmission threshold within the relevant 30-day interval and guarantee therapy plans proceed to fulfill Medicare’s “cheap and vital” normal and are supported by strong documentation.

2. Uncertainty Round Reimbursement Quantity for System Provide Codes 

CMS is proposing the identical reimbursement fee for the brand new codes overlaying 2–15 days of knowledge as the prevailing codes that cowl 16 days of knowledge. This implies fee could be the identical no matter whether or not information is transmitted for 2 days or for 16+ days inside any 30-day interval.

Nevertheless, CMS rejected the American Medical Affiliation’s (AMA) Relative Worth Scale Replace Committee (RUC) suggestions for valuing the brand new and present system provide codes, citing inadequate survey information from the RUC to appropriately worth the codes. As a substitute, CMS proposes utilizing Hospital Outpatient Potential Cost System (OPPS) value information to worth these companies. The proposal marks a possible shift in how distant care companies are evaluated and valued. This implies, though the proposed adjustments symbolize a transparent enlargement of protection, future changes are probably as extra information is collected and reviewed, so suppliers ought to count on continued flux within the reimbursement charges.

It is also notable that CMS is proposing to use contractor pricing for the RTM system provide codes related to respiratory system monitoring (CPT codes 98XX4 and 98976) and with cognitive behavioral remedy (CPT codes 98XX6 and 98978). Contractor priced standing means the worth and fee for these RTM codes shall be established on the discretion of every native Medicare Administrative Contractor (MAC) and should end in variability in reimbursement charges throughout jurisdictions. CMS at present units a nationwide fee for CPT code 98976, so RTM stakeholders could view this proposal as a step backward. If the proposal turns into ultimate, practitioners might want to seek advice from their native MACs for particular protection and billing tips of CPT codes 98XX4, 98976, 98XX6, and 98978.

3. Proposed RPM & RTM Billing for 10-19 Minutes of Monitoring.

Presently, the RPM and RTM therapy administration companies codes (CPT 99457 and 98980) can solely be billed after no less than 20 minutes are spent in a calendar month on actions corresponding to monitoring, information overview, and affected person teaching actions. In different phrases, if 19 minutes are spent on such monitoring actions, no reimbursement might be claimed.

CMS is proposing to create new therapy administration codes for each RPM and RTM to cowl 10–19 minutes of administration time in a calendar month. Each codes would nonetheless require no less than one real-time, interactive communication with the affected person or caregiver through the calendar month. The desk beneath lists the proposed new therapy administration companies codes for 2026.

The addition of those codes successfully would permit for 3 separate tiers of monitoring time: (1) the primary 10-19 minutes; (2) a complete of 20-39 minutes; and (3) every further 20 minutes spent above the primary 20 minutes. CMS proposes the reimbursement for CPT codes 99XX5 and 98XX7 to be at roughly half the speed of the prevailing 20-minutes codes (99457 and 98980).

CMS is also rejecting a suggestion from the RUC to chop the reimbursement worth for the prevailing 20-minute codes (99457, 99458, 98980. 98981) and as a substitute proposes to keep up their present valuation.

4. Make Your Voice Heard

Suppliers, know-how firms, and digital care entrepreneurs keen on distant monitoring ought to take into account offering feedback to the Proposed Rule. Feedback could tackle not solely CMS’ proposals or clarifications however may also request responses on points CMS didn’t tackle. CMS is soliciting feedback on the Proposed Rule till 11:59 p.m. EDT on September 12, 2025. Anybody could submit feedback (anonymously or in any other case) through digital submission at https://www.laws.gov/doc/CMS-2025-0304-0009. Alternatively, commenters could submit feedback by mail to:

• Common Mail: Facilities for Medicare & Medicaid Companies, Division of Well being and Human Companies, Consideration: CMS-1832-P, P.O. Field 8016, Baltimore, MD 21244-8016.
• Categorical In a single day Mail: Facilities for Medicare & Medicaid Companies, Division of Well being and Human Companies, Consideration: CMS-1832-P, Mail Cease C4-26-05, 7500 Safety Boulevard, Baltimore, MD 21244-1850.

If submitting through mail, please you’ll want to permit time for feedback to be obtained earlier than the deadline.

5. Conclusion

The Proposed Rule advances the power of clinicians to leverage distant monitoring applied sciences to enhance the affected person care expertise and receives a commission for doing so by providing higher flexibility and enabling shorter-term monitoring and affected person engagement. Notably, the introduction of recent 10-minute codes for RPM and RTM companies higher aligns with medical workflows, as many duties, corresponding to responding to alerts or conducting affected person outreach, are sometimes accomplished in below 20 minutes. Nevertheless, regulators have warned that these adjustments could also be weak to abuse (e.g., billing with minimal information), and elevated auditing and enforcement exercise associated to RPM and RTM must be anticipated. Thus, cautious program administration of those companies shall be essential. Suppliers utilizing these codes ought to keep strong documentation supporting medical necessity, keep detailed time logs that clearly present medical engagement, and guarantee compliance with all billing necessities.

We’ll proceed to watch CMS and steerage for developments that impression the use, reimbursement, and compliance panorama for RPM and RTM companies.

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For extra data on telemedicine, telehealth, digital care, distant affected person monitoring, digital well being, and different well being improvements, together with the group, publications, and consultant expertise, go to Foley’s Telemedicine & Digital Well being Trade Staff.

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