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We recently hosted a webinar exploring key strategies for building or scaling a successful remote care management program in 2026. Presented by Prevounce CEO Daniel Tashnek, the session was designed to help attendees understand how recent industry shifts and policy changes affect remote care in areas including remote patient monitoring (RPM), chronic care management (CCM), and advanced primary care management (APCM), and what organizations must do to develop a high-performing remote care program.
If you missed the webinar, you can watch the on-demand recording of "Winning in Remote Care in 2026: What Providers Must Know."
The webinar was very well attended, and participants asked numerous insightful questions, many of which Daniel did not have time to address during the live session. To further support attendees in building or scaling a successful remote care program, we have provided answers to those questions below.
Q: If a patient doesn't reach the required care time for a CCM code, can you bill APCM for just that month?
Yes, you can technically toggle a patient between chronic care management and advanced primary care management month-to-month. To do so, the patient needs to be verbally consented into both programs, and you need to ensure you are not double billing. If you want to offer both programs, it is generally easier to pick a cohort of patients you want to enroll in CCM and a separate cohort to enroll in APCM. Moving patients back and forth can pose operational and compliance challenges.
Q: Has it been clarified if CPT 99453 can also be generated after 2 readings to line up with CPT 99445?
Yes, 99453 can now be billed alongside 99445 (2-15 days of RPM device data). Providers should only be billing 99453 in the first month that a patient meets criteria for either 99445 or 99454 (16+ days of RPM device data). You can learn more about how to properly code and bill for RPM in our 2026 Remote Patient Monitoring Billing Guide.
Q: If I’ve applied to be a part of CMS’ recently announced ACCESS program, can I opt out if reimbursement is not sustainable for my organization?
The lack of details on the payment from the Centers for Medicare & Medicaid Services (CMS) is the major hang up for most considering the program right now. ACCESS adoption will likely depend on whether the financial upside is greater than running a traditional fee-for-service RPM program. Technically, you could register as an ACCESS provider and simply not enroll patients in the program if you don't find it to be financially viable. Just being ACCESS-registered would not preclude you from running an RPM, CCM, and/or APCM program, or billing out under traditional fee-for-service more generally.
Q: Can you bill for CPT 99453 if the patient leaves the program before they are eligible for billing CPT 99454 or CPT 99445?
You can only bill 99453 (device setup and training) in the first month that the patient hits the threshold for 99445 (2-15 days of RPM device data) or 99454 (16+ days of RPM device data). You cannot bill 99453 if the patient never meets billable criteria for 99445 or 99545. With the new 2-15 day RPM code, it becomes a lot easier for patients to hit monthly device reading requirements, and thus easier to bill for device setup and training.
Q: Can I switch my non-compliant CCM patients into APCM?
Yes, you can absolutely transition patients from CCM into APCM. Those patients will need to be formally consented into APCM first and you will need to ensure that the 13 APCM service elements are available to the patient each month.
Q: Does APCM require a monthly call or communication with the patient?
No, APCM does not require a monthly call with the patient. The patient's care manager can determine an appropriate cadence of outreach, depending on the patient's needs. It is still advisable to call APCM-enrolled patients occasionally to ensure compliance with their care plan and to address any questions or issues they may have.
Q: Can CPT 99454 or CPT 99445 be billed in the same 30 days as a traditional office visit?
A patient coming in for a visit does not prevent you from billing 99454 in that month. If you are measuring vitals in-office during the visit, just be aware that those readings just would not count towards RPM billing.
Q: What if RPM patients prefer to text rather than called?
Interactive communication, a requirement for RPM time codes, means a live phone or video call between a care manager and the patient or the patient’s caregiver. Voicemails, emails, or text messages do not count toward this requirement, although time spent on voicemails, emails, and texts can count towards billable time.
Q: What is the main difference between APCM and CCM?
There are some similarities, but also key differences between CCM and APCM. This blog post provides a good summary.
Q: Is a yearly office visit required for RPM services?
A yearly office visit is not a requirement for RPM participation. Patients must be "established" with the provider before RPM enrollment, which means you need to have had an in-person or telehealth evaluation and management (E&M) visit within the previous 12 months. You are not required to "re-establish" the patient annually assuming uninterrupted RPM enrollment.
Q: Are there any topics that must be discussed with patients to bill for RPM care time?
There are no specific requirements on what topics need to be covered in the monthly interactive communication requirement for RPM time codes. Typically, these calls cover things like device usage, medication adherence, diet, exercise, and other issues related to their chronic condition. The interactive communication should be documented in your remote patient monitoring platform or wherever you are managing your program. Most RPM platforms automate the workflow, but there should be a log with the call length and brief notes on topic(s) discussed.
Q: How many patients should a care manager be responsible for? Is there an ideal range for the patients to care manager ratio?
The answer to this question can vary quite a bit based on the needs of your patient population, staffing levels, and other factors. Generally speaking, 150 to 200 patients per care manager seems to work for many organizations. Practices with patients requiring more time and attention may opt to have more 100 to 150 patients per care manager.
Q: Does Medicare Advantage cover remote care programs like RPM, CCM, or APCM?
Medicare Advantage (MA) plans are required to cover everything that traditional Medicare covers, which includes RPM, CCM, and APCM. Specific MA payers and plans can, however, control things like provider authorization and documentation rules. You can always contact the payer directly to learn about any requirements or nuances as compared to traditional Medicare.
Q: Can a practice with both a primary care physician and a nurse practitioner billing under the same TIN and NPI provide and bill for both APCM and CCM?
In this scenario, you could have a population of patients enrolled in CCM and a separate population of patients enrolled in APCM. However, you could not dual-enroll any patient in both CCM and APCM. If you were to provide APCM to a patient, he/she would only be eligible for CCM services offered by another provider with a separate NPI.
Q: For CCM, should at least two chronic conditions be actively addressed on the claim in order to bill properly?
Conditions do not necessarily need to be listed on the claim, though payer requirements may vary. It is essential that you have the conditions documented in your CCM platform, or wherever you are administering your program, in the event of an audit.
Q: What recommendations do you have for outsourcing patient enrollment or patient support, such as billing-related calls, to ensure a positive vendor relationship and confirm the vendor is meeting RPM and CCM requirements? Are there specific components that should not be outsourced?
There are a number of factors to consider when evaluating a potential outsourced care management company. Our 10-Point Checklist to Outsourcing Remote Care Management provides good information to address the specific question asked, as well as other things you might consider when picking a vendor.
Q: For CCM, can a licensed practical nurse serve as the primary business owner and care coordinator by contracting with an outside physician for general supervision, or must the billing provider be an in-house partner?
Yes, CCM services are delivered under the "general supervision" of a billing provider. That provider does not need to be physically or virtually present during service delivery. The services themselves are typically delivered by nurses, medical assistants, clinical social workers, and other clinical staff. The scenario described in the question is a perfectly fine way to structure a program.
Q: What are the most effective strategies for enrolling patients in care management programs and overcoming cost-sharing objections?
A great way to handle patient objections to copays is to explain the cost relative to expensive hospital visits and procedures. Proactive, remote monitoring can identify and address issues before they worsen and lead to costlier care. One hospital bill can easily be more expensive than years of RPM copays.
Q: As an endocrinology clinic, should we implement RPM services, and can RPM be successfully implemented in-house?
Endocrinology practices are excellent candidates for remote patient monitoring programs. Diabetes is one of the most common conditions managed through RPM programs. "Insourcing" your program will work well if your practice has staff who can oversee incoming device readings and ongoing care management work. If staffing is a challenge, you may have an easier time scaling your program with an outsourcing partner.
Q: Can RPM be used for CPAP monitoring?
CPAP readings do not count for standard RPM codes. A prerequisite for RPM is that the device is purchased by the practice or provider and supplied to the patient at no cost. CPAP machines are considered durable medical equipment (DME), which come with a different set of billing rules. Sleep apnea could, however, be considered a chronic condition that you might monitor through CCM or APCM.
Q: As a rural community pharmacist building an RPM program that relies on collaborative practice agreements (CPAs), what strategies can help overcome challenges and gain prescriber buy-in?
First and foremost, these services are going to help keep patients healthier and out of the hospital. Especially in rural areas, patients may only visit their doctor once or twice a year and need to travel long distances in order to do so. Proactive, remote monitoring is going to allow patients to comfortably and effectively manage their conditions from home. If you are sharing the reimbursement revenue from enrolled patients with prescribers, there is a direct financial incentive as well. If not, these programs can still impact prescribers’ bottom line. RPM can lead to things like higher quality scores that can positively impact overall Medicare reimbursement.
Q: For RPM code CPT 99454, is the 16-day device data requirement based on a rolling 30-day period or a calendar month, and how should billing be handled in longer months (for example, billing on the 1st and 31st)?
RPM device codes (99445 and 99454) are billed on a 30 day cycle while RPM time codes (99470, 99457, and 99458) are billed on a monthly calendar cycle. We typically advise aligning the device codes to calendar months for ease of billing. You may lose a bit of money in the margins this way, but not much. The very small loss is generally worth the convenience of all claims going in monthly at the same time.
Did You Miss Our Winning in Remote Care in 2026 Webinar? Watch It Now!
Understanding how recent changes will impact your remote care programs is essential for staying ahead. That's why you should view our on-demand webinar: "Winning in Remote Care in 2026: What Providers Must Know."
If you would like to schedule a free consultation to discuss how these changes are likely to affect your current remote care strategy and plan, book time with one of our experts.
* Disclaimer: The above information is for informational purposes only and does not constitute legal or other professional advice. Billing and coding requirements — especially in the telehealth space — can change and be reinterpreted often. You should always consult an attorney and/or medical billing professional prior to submitting claims for services to ensure that all requirements are met.