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

Written by Mark Dose | Jan 7, 2026 7:41:45 PM

Remote Patient Monitoring has always made clinical sense, but the reimbursement structure has been onerous. Especially when real patients behave like real people.

CMS took a meaningful step in the 2026 Physician Fee Schedule (PFS) final rule by adding flexibility where programs have historically broken down: months where patients transmitted fewer than 16 days of data, and months where care teams did valuable work but did not quite reach 20 minutes of documented treatment management time.

This guide walks through what changed, what stayed the same, and what practices should do now so billing, operations, and clinical workflows can adjust to the new rules. 

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

What Changed in 2026

CMS finalized two new CPT codes that create a tiered structure for RPM. One fills the “2 to 15 days of data” gap, and one fills the “10 to 19 minutes of time” gap. 

New CPT 99445: Device supply and data transmission for 2 to 15 days

CPT 99445 covers the RPM device supply and the collection, transmission, and monitoring of physiologic data when the patient transmits readings for 2 to 15 days during a 30-day period. 

This is the big shift for programs that previously saw “partial month” engagement turn into “non-billable month,” even when monitoring was clinically appropriate and useful. 

New CPT 99470: RPM treatment management for 10 to 19 minutes, with an interactive communication requirement

CPT 99470 covers RPM treatment management when the care team documents 10 to 19 minutes of time in a calendar month, and there is at least one interactive communication with the patient or caregiver during that month. 

The practical implication is simple: brief, high-value touchpoints that used to fall short of the 20-minute threshold can now be reimbursed when documented correctly. 

What Stayed the Same

The core RPM code set remains intact. Practices that already have RPM running do not need to rebuild their programs from scratch, but they do need to understand how the new options layer in.

CPT 99453: Initial setup and patient education

99453 remains the code for initial device setup and patient education.

CPT 99454: Device supply and data transmission for 16 to 30 days

99454 still applies when the patient transmits readings on 16 or more days in a 30-day period. 

CPT 99457 and 99458: RPM treatment management at 20 minutes and beyond

99457 remains the first 20 minutes of RPM treatment management in a calendar month, and 99458 remains the add-on code for additional 20-minute increments. Previously, clinics could bill up to three 99458 codes per month.  The new rule does not have a limit on the number of 99458 codes that can be billed. 

These time-based codes continue to require interactive communication with the patient or caregiver during the month, so teams should continue treating that as a core compliance and documentation requirement. 

The Key Rule: You Choose One Code Per Category Each Month

The most important operational concept for billing teams is that the “device supply” codes and “treatment management time” codes are mutually exclusive within their categories. In plain language, you pick the correct code based on what actually happened that month.

Here is a practical quick reference:

Category

Lower tier (new)

Higher tier (existing)

How to choose

Device supply + data transmission

99445 (2–15 days)

99454 (16–30 days)

Choose based on number of days with transmitted data in the 30-day period 

Treatment management time

99470 (10–19 minutes + interactive communication)

99457 (20+ minutes + interactive communication) and 99458 (each additional 20 minutes)

Choose based on total documented time in the calendar month 

What Practices Should Do Next

The 2026 changes create opportunity, but they also expose weak spots that many RPM programs have lived with quietly. The goal now is to make sure your systems, workflows, and documentation can support the tiering cleanly, month after month.

1) Confirm your tracking for “days of data” is audit-ready

Start by validating how your RPM platform determines “days of data transmission.” Billing accuracy depends on this number, and it now determines which device supply code applies in a given month. 

If you have had recurring questions like “does this count as a day,” or “what about multiple readings in one day,” this is the moment to get those answers documented internally.

2) Make interactive communication a routine habit, not a scramble

For time-based RPM treatment management, interactive communication is not an afterthought. It is a requirement that should be operationalized. 

This does not mean every patient needs long calls. It means your team needs a reliable workflow for capturing at least one compliant interaction in the month when billing the time-based codes. In practice, this is often where teams get tripped up because the clinical work happens, but the documentation does not tell the story clearly.

3) Tighten the link between clinical work and documentation

The fastest way to lose the upside of 2026 is to deliver appropriate care but document it inconsistently. Time-based codes live and die on documentation discipline. 

Two practical moves help immediately:

  • Make sure staff know what counts toward RPM treatment management time within your organization’s compliance approach.
  • Make time logging simple enough that it actually happens, especially for the 10 to 19 minute months that previously would have been ignored.

4) Train billing teams on the “tier choice” logic

The new structure is straightforward, but only if everyone is using the same mental model. Your billing team should be able to answer, without hesitation:

  • Which device supply code applies this month, based on days of data
  • Which time-based code applies this month, based on total minutes and the presence of interactive communication
  • When add-on time with 99458 is appropriate 

5) Review payer-specific guidance

CMS policy sets the direction, but payer policies can vary in how they interpret and implement reimbursement details.

Also, there may be differences in some commercial plans as to how RPM is reimbursed; a short payer review now can prevent avoidable denials later.  

Why This Matters Beyond Billing

The point of these changes is not just improved reimbursement. It is improved alignment.

The 2026 updates acknowledge something care teams have known for years: RPM often delivers its value in bursts. It is episodic for some patients, variable for many, and clinically meaningful even when it does not neatly hit the same monthly benchmark every time. 

The practices that benefit most from 2026 will be the ones that treat RPM as a care model first and a billing model second. When workflows, patient engagement, and documentation are built around real-world behavior, the reimbursement finally has a better chance of matching the work.

Disclaimer: This article is for informational purposes only and does not constitute legal, coding, or reimbursement advice. Practices should consult their billing specialists, legal counsel, and payer guidance for final coding and compliance decisions.