The Centers for Medicare & Medicaid Services (CMS) has proposed major changes to how Remote Patient Monitoring (RPM) is reimbursed, the most significant shift since the CPT code updates in 2019.
Buried in the proposed 2026 Physician Fee Schedule is a series of updates that could reshape how remote care is delivered, billed, and valued.
These changes reflect what many providers already know: real care doesn’t always happen in 20-minute chunks or after 16 straight days of device data. Sometimes, a single trend or quick check-in is all it takes.
What’s New in the CMS Proposal
CMS has proposed several changes that bring remote care closer to how it actually works:
- New device supply code (99XX4)
Allows billing for 2–15 days of transmitted data — a major shift from the current 16-day requirement under 99454. - New management time code (99XX5)
Enables billing for 10–19 minutes of RPM care, instead of requiring 20+ minutes (99457) or 40+ (99458). - A clear stance: RPM is a long-term service
CMS confirms that RPM is meant for chronic conditions, not just short episodes of care.
If finalized, these updates will make RPM more flexible, more accessible, and more aligned with how clinicians actually support patients.
Why This Matters for Chronic Care
Anyone managing patients with heart failure, diabetes, or hypertension knows that important changes don’t wait for office visits. One unexpected reading or early symptom can signal the need for action.
This proposal acknowledges that. It shifts the focus from rigid thresholds to meaningful interventions — even when those interventions are brief.
For providers, that means more patients may qualify. For patients, it means they get help sooner. For everyone, it means remote care starts to look more like real care.
“CMS is listening to stakeholder feedback,” said Kyle Zebley, Executive Director of ATA Action. “We’re encouraged to see positive steps forward for virtual care, including new billing codes for 2–15 days of RPM and RTM.”
What Still Needs Attention
This is progress. But there are still gaps to address before the final rule:
- New time codes add complexity
CMS proposes a new 10–minute code (99XX5) — but existing codes (99457/99458) still require 20+ and 40+ minutes. That means more granular documentation, and new decisions about how to bill. - Device reimbursement could drop
CMS may shift the reimbursement method for device supply (99454) to hospital outpatient cost data. That could mean lower payments — and more financial pressure, especially for small or independent groups. - Still no credit for preventive signals
Early indicators like changes in physical activity or behavior still aren’t billable, despite their clinical relevance. The system still values response over prevention.
A Step Toward Better Care Between Visits
This proposal isn’t perfect. But it reflects a growing understanding: the most important care often happens between visits, in small moments, unexpected patterns, or fast decisions.
These updates echo what clinical leaders and organizations like the American Telemedicine Association have long advocated: a more flexible, patient-centered approach to remote care.
“This is a big step in the right direction. CMS is finally starting to match reimbursement with the reality of modern chronic care.”
-Ryan Clark, Nom Care CEO
Remote care is no longer an experiment. It’s essential infrastructure. These updates help build a stronger foundation for delivering it at scale, with fewer tradeoffs and more impact.
To learn more about Nom Care, you can watch our CEO talk about Nom Care here, or simply click here to set up a time to connect.
Note: Providers and healthcare organizations can submit feedback on the 2026 Proposed Medicare Physician Fee Schedule (CMS–1832–P) through the official federal comment portal. CMS is accepting comments until 11:59 p.m. ET on September 12, 2025.
To share your perspective on the proposed RPM and CCM updates, visit:
🔗 https://www.regulations.gov/commenton/CMS-2025-0107-0001
Federal Register Reference:
CY 2026 Payment Policies Under the Physician Fee Schedule (CMS–1832–P)
Published July 16, 2025 – Vol. 90, No. 134
📄 Read the full proposed rule