Remote Care Management: Key FAQs From the 2026 Medicare PFS Final Rule

We recently hosted a webinar exploring key changes in the 2026 Medicare Physician Fee Schedule final rule that impact remote care management. The session was designed to help attendees understand how the updates affect remote patient monitoring (RPM), advanced primary care management (APCM), preventive services, and more.  

If you missed the webinar, do not worry as you can now watch the on-demand recording of "Understanding Medicare's 2026 Changes to Remote Care Management."  

The webinar was very well attended, and participants asked many insightful questions, some of which we did not have time to address during the live session. To further support your understanding of the final rule and its implications for 2026 and beyond, we have provided answers to many of those questions below.   

Billing Rules, Code Interactions, and Program Eligibility 

Q: Can you bill remote therapeutic monitoring (RTM) and chronic care management (CCM) together? If so, what are the requirements? Do you need to bill CPT 99454 to bill CPT 99457? Can RPM and CCM be billed together? 

A: RTM and CCM can be billed together under the same rules that apply to RPM and CCM. The patient must meet the requirements for both services, and time and documentation must be kept separate and distinct.  

CPT 99454 and 99457 are independent and do not require each other.  

Yes, CCM and RPM can be billed together if the time and documentation are discrete and the patient meets requirements for both. 

Q: Can you bill CPT 99458 if you bill CPT 99445? 

A: Yes. The measurement-transmission codes and care-management time codes are distinct. Billing 99445 (2–15 days of measurement) does not affect billing 99458 (additional 20 minutes of care-management time). 

Q: Can CPT code 99091 be billed along with the new "2 readings" code (CPT 99445)? 

A: Yes. 

Q: Consider an episode of care that begins when the patient is enrolled in RPM and ends when the patient's treatment goals are met. If the patient meets their goals, is discharged from RPM, and later re-enrolled into RPM, can you bill 99453 for this patient's new episode of care? Would this then require a new consent form for the new episode of care?  

A: There is a bit of nuance here. The 99453 code is typically used once in the lifetime of the patient unless they are enrolled in a new program, so reasonably, this could be used again if it is a truly new and distinct episode of care (e.g., new provider, clinic, diagnosis, device). We would always recommend reconsenting the patient into the program once they have been unenrolled, whether it is for a new episode of care or a continuation of the program after a break that included unenrollment.  

Q: We need information on rural health clinic bundled payments for APCM. Can a patient be enrolled in APCM if they are already enrolled in CCM?  

A: APCM and CCM cannot be billed in the same month for the same patient. A patient may only be enrolled in one of these programs at a time. However, a patient can be enrolled in both RPM and APCM simultaneously.  

Device Transmission, Measurement Requirements, and Time-Based Rules 

Q: What is the maximum level of RPM time codes that can be billed in a rolling 30-day period? 

A: We typically advise three, or up to 60 minutes. That's one use of CPT 99457 and two uses of CPT 99458. 

Q: If a patient sends only two readings in a month but we spend 45 minutes on RPM activities, can this be billed for 2026? 

A: Yes. In this case you would bill one unit of CPT 99445 for the device readings, one unit of CPT 99457 (first 20 minutes), and one unit of CPT 99458 (second 20 minutes). 

Q: Are the 2026 time-based codes still billed by calendar month, or are they also on a 30-day cycle like measurement codes? 

A: Time-based care-management (99470, 99457, and 99458) codes remain calendar month codes. 

Q: Will we still be able to bill 20-plus minutes of time for RPM patients who only receive 2–16 readings, or does "2–16 readings" limit time to 10–20 minutes? 

A: Time codes and measurement codes are distinct. They can be mixed and matched based on patient needs. 

Q: Do vitals have to be taken at the same time to count as a "reading"? For example, if blood pressure (BP) is taken on the first of the month and weight on the second, does that count as one reading day for a CCM patient with hypertension and obesity? 

A: For CPT 99454 and 99445, measurement days are counted regardless of device. If a patient takes BP on Monday and weight on Tuesday, that counts as two days. If both BP and weight are taken on the same day, that counts as one measurement day. 

Q: Can an unstable patient be checked more often than every 30 days? 

A: Yes. Patients may send measurements as often as clinically necessary. Readings are counted by measurement day, not by the number of measurements. It’s important to note that RPM device readings are reimbursable only if a patient transmits 2 or more readings in a 30-day period. 

Q: Does spirometry data need to be captured automatically, or can it be entered manually for RPM? 

A: For RPM, all device measurements must be digitally transmitted. Manual entries are not compliant. 

Reimbursement, Copays, and Payer Policies 

Q: How does RPM reimbursement change in 2026 based on the number of patient readings per month?  

A: The 2–15 readings code (99445) and the 16-plus readings code (99454) will be reimbursed at the same rate in 2026. This means you will receive the same reimbursement whether a patient takes two readings or 30 readings in a month.  

Q: Is the cost of the RPM device included in reimbursement? Or is it covered as durable medical equipment (DME)? 

A: Providers must supply the devices. Reimbursement typically offsets the cost within one or two months. RPM devices are not covered under DME. 

Q: Is there a source listing RPM codes covered by Medicaid plans by state? 

A: The Center for Connected Health Policy (CCHP) is the best available resource. It links to state Medicaid policy/legal documents where specific code information is often buried. 

Q: Is there a copay for Medicare patients receiving RPM? 

A: Yes, unless the patient has secondary insurance that covers the copay. 

Q: Are the 2026 RPM CPT code changes and reimbursement amounts confirmed? 

A: For RPM, existing code definitions have not changed. Two new codes have been confirmed and added: CPT 99445, reimbursed at a national average of $47, and CPT 99470, reimbursed at a national average of $26. Note that actual reimbursement rates vary slightly based on locality. 

Q: Where can you find CPT code reimbursement rates for a specific city? 

A: Use the Physician Fee Schedule lookup tool available on the CMS website. 

Q: If copays are eventually eliminated for CCM/RPM, will CMS pay 100%, or will patients/secondary insurance simply not be required to pay? 

A: It depends on how the various congressional bills currently under consideration on these topics shake out. One CCM bill proposes permanent copay elimination. Another RPM proposes a two-year elimination. As with any bill, specifics are subject to change until final passage. 

Q: What should be communicated to Medicare patients about out-of-pocket costs before they enroll? 

A: Medicare patients owe 20% coinsurance unless they have secondary or supplemental coverage, which often covers the remainder. 

Q: Is there a reduction in reimbursement for current RPM CPT codes, specifically 99454?  

A: There is no reduction in the rates for the current RPM codes, including 99454. The rates are going up slightly next year, with an increased conversion factor rate for 2026.  

Supervision, Compliance, and Operational Guidance 

Q: What does PC/TC mean? 

A: PC/TC refers to the professional component/technical component billing indicators used by the Centers for Medicare & Medicaid Service (CMS). 

Q: Does the direct-transmission requirement apply to CCM? 

A: No. CCM does not require device transmission unless the patient is also enrolled in RPM. 

Q: Does direct supervision have to involve a clinical staff member (e.g., nurse), or can it be an unlicensed team member? 

A: It may be any “clinical staff” member trained and vetted by the supervising physician; no specific license is required. 

Q: Will CMS allow live artificial intelligence (AI) conversations to satisfy the synchronous-interaction requirement for CPTs 99457, 99458, etc.? 

A: CMS has stated that human interaction is required. No indication has been given that this will change soon. 

Q: Does the new code for 10-20 minutes of RPM treatment management services (CPT 99470) require interactive communication?  

A: Yes, the 10–20 minute code requires interactive communication.  

Q: Does virtual direct supervision apply to registered nurses (RN) working for RPM companies that partner with PCPs (billing incident to), or does the RN need to be employed by the same company as the physician?  

A: Yes, virtual direct supervision applies to anyone working incident to the physician, whether they are employed directly by the practice or functioning as an extension of the practice through a collaborative practice agreement.  

Q: Does the 2026 PFS final rule have implications for the care of dementia patients, with or without comorbidities?  

A: Yes, there are implications for dementia patients if they are enrolled in remote care management services like remote patient monitoring, which they can be.  

Q: Do you see similarities between the new set-fee-per-patient-per-month approach for APCM and the broader goal of fully transitioning to value-based care by 2030?  

A: Yes, we see this as part of a broader push toward shifting value to preventive services and advancing value-based care.  

Q: For compliance purposes, does leaving a voicemail for a patient about appointment reminders count as non–face-to-face time when reporting for the likes of RPM, APCM, and CCM? Similarly, does a clinically focused voicemail (e.g., discussing prescriptions or lab results) count as non-face-to-face time for these services?  

A: Leaving a voicemail can count toward care management time. However, it does not fulfill the interactive communication requirement for programs like RPM.  

Q: Where can I watch your previous webinar about the APCM program?  

A: It is accessible here.   

Q: What are some common audit pitfalls or red flags when billing for RPM? 

A: One of the biggest pitfalls is frequency denials. The 99454 code follows a rolling 30-day billing cycle, while the care management time codes follow a calendar month. Keeping those timelines straight can be challenging. We often recommend syncing the two billing cycles to help maintain consistency and reduce errors. Just be mindful in months like February, where you may need to borrow a day from the surrounding months to meet the 30-day requirement.  

Q: What is the supervision requirement for a CCM program? Does the physician need to be present in the same building?  

A: CCM requires general supervision. The supervising physician must be available virtually in case of an emergency but does not need to be physically present in the same building.  

Q: When can federally qualified health centers (FQHCs) begin billing for RPM services?  

A: FQHCs could begin billing for RPM using code G0511 starting Jan. 1, 2025. However, G0511 was sunset on Oct. 1, 2025. FQHCs can still provide RPM services, but they must use the relevant — and now expanded — CPT codes instead of the G-code. 

UnitedHealthcare (UHC) Coverage and Market Implications 

Q: Is UnitedHealthcare the only payer cutting RPM program coverage? 

A: At this time, yes. Coverage is generally expanding across Medicare, non-UHC Medicare Advantage (MA) plans, commercial plans, and Medicaid. UHC is the outlier. 

Q: Do Medicare Advantage plans have to match Medicare's RPM coverage? 

A: Yes. Per the 2024 PFS final rule, MA plans must provide at least the same level of coverage as traditional Medicare. UHC has used a loophole to justify reducing coverage, but this will likely face legal challenges and is not expected to be emulated by other payers. 

Q: How can the RPM community push back against UHC to prevent similar actions by other insurers? 

A: Providers can continue submitting claims and appealing denials. Advocacy efforts include media outreach and communication with CMS and elected officials. 

Did You Miss Our PFS Final Rule Webinar? Watch It Now!  

Understanding how the 2026 Medicare Physician Fee Schedule final rule will impact your remote care programs is essential for staying ahead. That's why you should view our on-demand webinar : "Understanding Medicare's 2026 Changes to Remote Care Management." 

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.