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CMS’s 2026 RPM Rule Changes Reflect How Care Actually Happens

Written by Mark Dose | Jan 7, 2026 8:02:06 PM

For the past few years, Remote Patient Monitoring has held a strange position in healthcare. Clinically, it makes intuitive sense. Operationally and financially, it has often felt harder than it needed to be.

At Quokka Care, we see this tension up close. We work with care teams that believe deeply in monitoring patients between visits, but who have had to design their programs around rigid billing thresholds rather than around how patients actually behave at home. The result has often been RPM programs that work well for a narrow slice of patients and feel frustratingly fragile for everyone else.

The CMS rule changes for 2026 suggest that this tension has finally been acknowledged.

They read less like a policy tweak and more like CMS paying attention to what has been happening in real RPM programs for years.

Also read: The 2026 RPM Rule Changes Explained: New CPT Codes, Same Core Requirements

Where RPM Has Felt Constrained

Until now, RPM reimbursement has required providers to hit specific monthly benchmarks. Patients needed to transmit data on at least sixteen days within a thirty-day period. Clinical teams needed to document at least twenty minutes of treatment management time to bill for RPM oversight.

When those boxes were checked, RPM worked cleanly. When they were not, even by a small margin, entire months could suddenly become non-billable.

We have seen this play out repeatedly. A patient engages consistently for the first half of the month, then travels, gets sick, or simply disengages for a stretch. A care team spends meaningful time reviewing trends, reaching out, and documenting next steps, but the clock stops at eighteen minutes instead of twenty. The clinical value is still there, but the reimbursement is not.

Over time, this has shaped behavior. Some practices have limited RPM enrollment to only the most reliable patients. Others have hesitated to expand programs beyond narrow chronic care use cases because the risk felt too high.

That context makes the 2026 changes especially notable.

What CMS Is Changing in 2026

Beginning in 2026, CMS has moved RPM reimbursement toward a tiered structure that reflects varying levels of patient engagement and clinical intensity.

Instead of a single participation threshold, providers will be able to bill for device supply and data transmission when patients submit readings for as few as two to fifteen days in a month. Clinical treatment management will also allow reimbursement starting at ten minutes of documented time, provided there is at least one interactive communication with the patient during that period.

Higher-intensity monitoring remains fully supported. Patients who transmit data on sixteen to thirty days per month and require more extensive clinical oversight still fall under the existing RPM codes. What changes is that lower-intensity monitoring is no longer treated as an all-or-nothing failure.

This matters because care rarely unfolds in neat, uniform patterns.

Why This Aligns With How RPM Is Actually Used

In practice, RPM already operates on a spectrum.

We see patients who need close monitoring during a specific window, then stabilize. Others engage inconsistently but still benefit from timely intervention when concerning trends appear. Care teams often provide value in short, targeted interactions that prevent escalation, even when those interactions do not add up to large blocks of time.

Under the previous rules, much of this work lived in a gray area. Clinically meaningful, operationally necessary, but financially awkward.

The 2026 framework brings policy closer to reality. It acknowledges that RPM can be valuable even when engagement fluctuates and when care is delivered in smaller, well-timed moments rather than prolonged monthly checklists.

That shift expands who RPM can realistically serve.

Implications for Providers

For providers, the immediate impact is flexibility.

Consider a postpartum patient monitoring blood pressure at home. Engagement is often high early on, then tapers as risk decreases. Under the old structure, that taper could undermine an otherwise successful monitoring period. Under the new rules, care teams can continue supporting the patient without forcing unnecessary intensity just to meet billing requirements.

Or consider patients who struggle with daily device use but still benefit from periodic monitoring and follow-up. These patients have often been excluded from RPM programs entirely. Tiered thresholds make it possible to include them without compromising program sustainability.

Over time, this also changes how programs are designed. RPM no longer has to be reserved only for patients who fit a narrow definition of “ideal.” It can be integrated more naturally into broader care models.

A Clear Signal From CMS

Stepping back, the 2026 changes point to something larger.

CMS appears to be moving away from rigid participation metrics and toward a more pragmatic view of remote care. The emphasis is shifting toward continuity, early detection, and meeting patients where they are. That direction aligns with how care is increasingly delivered outside of clinic walls.

This is particularly relevant as RPM expands beyond traditional chronic disease management. In maternal health, post-procedural care, and other episodic use cases, what matters most is visibility between visits. Early changes caught at home can prevent complications long before they become emergencies.

CMS is increasingly rewarding models that support that kind of proactive care.

What This Means for RPM Programs Going Forward

As RPM becomes more accessible, the operational side becomes even more important.

Expanded eligibility and tiered billing create opportunity, but they also require thoughtful execution. Programs need clear workflows, reliable patient engagement strategies, and consistent documentation practices to ensure that flexibility does not turn into confusion.

The strongest RPM programs will be those that treat monitoring as an ongoing clinical relationship rather than a billing exercise. Technology, coaching, and clinical oversight need to work together so care teams can focus on patients instead of thresholds.

At Quokka Care, the 2026 changes feel less like a surprise and more like confirmation. They reflect the direction RPM has been moving all along, toward care models that are flexible, patient-centered, and grounded in real-world behavior.

CMS has made it easier to build RPM programs that reflect how care actually happens. For providers who have been waiting for the policy environment to catch up, 2026 may finally be the moment when remote patient monitoring can scale without losing its clinical soul.