CMS recently unveiled its proposed 2026 Physician Fee Schedule Rule, bringing significant updates for Remote Patient Monitoring (“RPM”) billing. These changes aim to enhance flexibility for providers and expand access to remote care.

Key Takeaways for Your Practice:

New Shorter Duration Device Billing: A new CPT code (99XX4) is proposed to allow billing for RPM device supply when patients are monitored for 2 to 15 days within a month. This offers the same reimbursement as the existing code (99454), which will now cover 16-30 days of monitoring. This means more flexibility for patients who don't require continuous daily data transmission.

New Shorter Management Time Billing: CMS proposes a new CPT code (99XX5) for RPM treatment management services lasting 10 to 19 minutes per month. This provides a new billing option for shorter clinical interactions, complementing the existing 20+ minute code (99457).

Expanded Patient Eligibility: These updates are designed to make RPM services accessible to a wider range of patients and allow providers to be reimbursed for care previously uncompensated.

Increased Scrutiny: While offering new opportunities, CMS is expected to increase oversight into billing accuracy and documentation for RPM services. As such, it is crucial that providers and practice owners build out sound compliance strategies prior to engaging in these new billing flexibilities.

These proposed changes, if finalized, will significantly impact how your practice utilizes and bills for RPM. It is encouraged that stakeholders submit comments to CMS regarding this proposed rule by September 12, 2025.

We will continue to monitor developments and provide updates as they unfold. In the meantime, if you have questions about the potential implications of this proposed rule or how to strategically position your practice for these changes, please reach out to our knowledgeable and experienced healthcare attorneys at (212) 668-0200 or via email at info@mdrxlaw.com.