CMS Confirms CPT 99445 Is Covered for FQHCs and RHCs in 2026 RPM Programs

The 2026 Medicare Physician Fee Schedule (PFS) introduced new remote patient monitoring (RPM) CPT codes aimed at expanding flexibility and access to RPM services. Shortly after the final rule was released, questions arose around whether federally qualified health centers (FQHCs) and rural health clinics (RHCs) would be eligible to bill for one of the new codes, CPT 99445.

After identifying the discrepancy, Prevounce reached out to CMS directly to request clarification. CMS has since confirmed that the exclusion of CPT 99445 was accidental and that the code will be added to the list of RPM services payable to FQHCs and RHCs, retroactive to January 1, 2026.

Let's take a look at what RPM coding looks like for FQHCs and RHCs in 2026.

New 2026 RPM CPT Codes: 99445 and 99470

CMS finalized two new RPM CPT codes for 2026 that reflect how RPM is increasingly used in real-world clinical settings.

CPT 99445

CPT 99445 allows providers to enroll and monitor patients who benefit from less frequent, but still clinically meaningful, remote patient monitoring. This code is designed for patients who may not require daily device readings but still benefit from ongoing monitoring, clinical oversight, and early intervention.

Unlike CPT 99454, which requires 16 or more days of device data collection per month, CPT 99445 covers 2–15 days of physiologic data collection per month. This expanded eligibility allows providers like FQHCs and RHCs to tailor RPM intensity based on patient risk and clinical need, rather than meeting a one-size-fits-all utilization threshold.

For many FQHCs and RHCs, CPT 99445 supports RPM use cases such as:

• Stable chronic condition management

• Step-down monitoring after acute episodes

• Preventive care and early risk detection

CPT 99470

CPT 99470 complements CPT 99445 by reducing the RPM care management time requirement to 10 minutes or more, expanding access to reimbursement for lower-intensity RPM services. This change reflects CMS's recognition that meaningful clinical oversight does not always require higher monthly time thresholds.

Together, these codes modernize RPM reimbursement and better align payment with clinical judgment.

Why CPT 99445 Was Missing for FQHCs and RHCs

When CMS published the final CY 2026 PFS, CPT 99445 was not included on the list of RPM services eligible for payment to FQHCs and RHCs (see: “RHC/FQHC CY 2026 Non-Facility Payment Rates"). On the other hand, the new CPT 99470 was included in the list of approved codes. This created confusion across the industry, including among providers, billing teams, and RPM partners like Prevounce.

The omission led to:

• Uncertainty around RPM reimbursement for FQHCs and RHCs

• Questions about whether RPM expansion applied equally to RHCs and FQHCs

• Delays in RPM program planning for 2026

Following Prevounce's outreach, CMS confirmed the exclusion was unintentional and not reflective of policy.

CMS Confirms a Retroactive Fix for CPT 99445

In its email response to Prevounce, a CMS spokesperson from the Atlanta Regional Office stated that CPT 99445 was inadvertently omitted and will be added to the list of covered RPM services for FQHCs and RHCs:

CMS has reviewed your inquiry regarding CPT code 99445. After further internal review, CMS identified that CPT 99445 was inadvertently omitted from the list of RPM services eligible for payment to FQHCs and RHCs in CY 2026. CMS intends to add CPT 99445 to the list of covered RPM services for FQHCs and RHCs, retroactive to January 1, 2026.

 

Currently, CMS is coordinating with claims processing partners to implement this update. While we do not yet have a specific timeframe for when the updated billing guidance and payment rate materials will be posted, CMS is actively working to ensure the correction is reflected in applicable systems and public-facing resources."

So, according to CMS:

• CPT 99445 will be covered for FQHCs and RHCs, alongside CPT 99470

• Coverage will be retroactive to January 1, 2026

• CMS is coordinating with claims processing partners to implement the correction

• Updated billing guidance and payment rate materials will be released once system updates are complete

While CMS has not yet published a specific timeline, the agency confirmed the correction is actively underway.

We appreciate CMS for promptly reviewing this issue and providing clear guidance. Its response and coordination with claims processing partners help reduce uncertainty for FQHCs and RHCs and support continued access to flexible, compliant RPM programs.

Why This Matters for FQHC and RHC RPM Programs

This clarification is positive news for FQHCs and RHCs planning RPM programs in 2026 and the patients they serve.

With both CPT 99445 and CPT 99470:

• Clinics can extend RPM to patients who need lower-intensity monitoring

• RPM programs can be tailored to patient risk and clinical need

• Providers gain greater flexibility without sacrificing reimbursement

• RPM can be used more strategically across chronic and preventive care

Most importantly, CMS’s response confirms that RPM remains a supported and evolving care model for FQHCs and RHCs.

What FQHCs and RHCs Should Do Next

FQHCs and RHCs should:

• Continue planning RPM programs that include both new RPM CPT codes for 2026

• Monitor CMS communications for updated billing guidance

• Confirm billing workflows and vendor readiness once claims updates are implemented

As CMS finalizes system changes, providers can move forward with greater confidence that RPM expansion applies fully to FQHCs and RHCs.

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Prevounce works closely with FQHCs and RHCs to stay ahead of CMS policy changes and ensure RPM programs remain compliant, scalable, and sustainable. For the latest updates on RPM, subscribe to the Prevounce newsletter and follow us on LinkedIn.