Stay current with Medicare's most recent changes and register for our educational webinar "Understanding Medicare's 2026 Changes to Remote Care Management," on November 20, 2025, at 2:00 PM ET / 11:00 AM PT.
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We recently hosted a webinar exploring key changes in the 2026 Medicare Physician Fee Schedule proposed rule that could impact remote care management. The session was designed to help attendees understand how the proposed updates may 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 watch the on-demand recording of "Understanding Medicare's 2026 Proposed 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 proposed rule and its potential implications, we have provided answers to many of those questions below.
Q: Will there be a reduction in reimbursement for current RPM CPT codes, specifically 99454?
A: There is no proposed reduction in the rates for the current RPM codes, including 99454. The rates are expected to go up slightly next year, with an increased conversion factor rate for 2026.
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: How will RPM reimbursement change in 2026 based on the number of patient readings per month?
A: As proposed, the 2–15 readings code (99XX4) and the 16-plus readings code (99454) would be reimbursed at the same rate in 2026. This means you would receive the same reimbursement whether a patient takes 2 readings or 30 readings in a month.
Q: Would the new proposed code for 10-20 minutes (CPT 99XX5) require interactive communication? Also, what are the chances these proposals are accepted wholesale and active in January 2026?
A: Yes, the 10–20 minute code will still require interactive communication. While there is always a possibility that changes will be made to these proposals before the end of the year, we are optimistic that the overarching provisions will be finalized, even if some of the nuanced details are revised.
Q: Does virtual direct supervision apply to RNs (registered nurses) 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: Are there implications in the information you are reporting for the care of dementia patients, with or without comorbidities?
A: Yes, there could be 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 (chronic care management)? 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: 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.
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 FQHCs (federally qualified health centers) begin billing for RPM services?
A: FQHCs could begin billing for RPM using code G0511 starting Jan. 1, 2025. However, HCPCS G0511 is expected to be unbundled as of Oct. 1, 2025. After that date, FQHCs can still provide RPM services, but they just need to use the relevant CPT codes instead of the G-code.
Did You Miss Our PFS Proposed Rule Webinar? Don't Worry!
Understanding how the 2026 Medicare Physician Fee Schedule final rule could impact your remote care programs is essential for staying ahead. Our upcoming webinar "Understanding Medicare's 2026 Changes to Remote Care Management" on November 20, 2025, at 2:00 PM ET / 11:00 AM PT, is designed to give you the insights you need to prepare. Register here.
If you would like to schedule a free consultation to discuss how these changes could affect your current remote care strategy, 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.