If you know me, you know that the MPFS Proposed Rule Comment Period each summer is my favorite time of year for digital health. And after a few years of little-to-no excitement in the remote monitoring reimbursement environment, CMS is proposing big changes for 2026.
Those of us who have been following the American MedicalAssociation’s CPT Editorial Panel meetings in the last year expected CMS to adopt new codes that will reduce arbitrary boundaries to reimbursement for bothRPM and RTM. But there are a few details that we did NOT see coming.
The good news? You can skip the tedious process of combing through 910 pages of regulatory text to find what’s relevant to your remote monitoring business. I’m breaking down what you need to know right here.
New Proposed RPM and RTM CPT Codes
The full list of proposed new codes and their respective proposed reimbursement rates for 2026 is:
Proposed Code: 99XX4
Proposed Descriptor: Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial: device(s) supply with a daily recording(s) or programmed alert(s) transmission, 2-15 days in a 30-day period
Proposed Non-Facility Reimbursement for 2026: $47.70
Proposed Code: 99XX5
Proposed Descriptor: Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring 1 real-time interactive communication with the patient/caregiver during the calendar month; first 10 minutes
Proposed Non-Facility Reimbursement for 2026: $25.53
Proposed Code: 98XX4
Proposed Descriptor: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of respiratory system, 2-15 days in a 30-day period
Proposed Non-Facility Reimbursement for 2026: Contractor priced
Proposed Code: 98XX5
Proposed Descriptor: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of musculoskeletal system, 2-15 days in a 30-day period
Proposed Non-Facility Reimbursement for 2026: $39.97
Proposed Code: 98XX6
Proposed Descriptor: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of cognitive behavioral therapy, 2-15 days in a 30-day period
Proposed Non-Facility Reimbursement for 2026: Contractor priced
Proposed Code: 98XX7
Proposed Descriptor: Remote therapeutic monitoring treatment management services, physician or other qualified health care professional time in a calendar month requiring at least 1 real-time interactive communication with the patient/caregiver during the calendar month; first 10 minutes
Proposed Non-Facility Reimbursement for 2026: $26.20
Zooming in on what matters
Several provisions in the proposed rule could carry outsized implications for remote monitoring stakeholders, providing important topics to comment on during the public comment period.
1. Contractor Pricing for Certain RTM DeviceSupply Codes
Based on are commendation from the AMA’s RVS Update Committee (RUC), CMS is proposing to contractor price CPT codes 98XX4 and 98976, both of which are Practice Expense-only codes tied to respiratory RTM device supply. This means Medicare AdministrativeContractors (MACs) will have the discretion to determine payment amounts locally rather than relying on a national RVU-based valuation.
This is a notable shift – in 2025, CMS established a Non-Facility Practice Expense RVU for 98976of 1.32, which in turn provided important predictability for vendor pricing. For vendors and providers alike, this new proposal introduces uncertainty—if this proposal is finalized, expect volatility in reimbursement until CMS finalizes a more uniform valuation methodology.
2. Misalignment Between "30-Day"vs. "Calendar Month" Billing Periods Still Unaddressed
Despite multiple cycles of stakeholder feedback throughout the last several years, neither CMS nor the AMA appears to have resolved a long-standing concern: the mismatch between the 30-day periods used for device supply codes (like 99454 and 98977)and the calendar-month basis used for time-based treatment management codes (including99457 and 98980).
This disconnect leads to administrative complexity for billing teams and can distort billing data, which may have contributed to OIG’s report last year highlighting concerns about periods in which providers billed only the device supply code or only the treatment management code. It also increases the risk of denials or audits if payers question overlaps or gaps between services. Stakeholders may want tore-engage with CMS during the comment period to push for alignment or additional billing guidance.
3. New Discrepancy Emerges in Valuation ofRPM vs. RTM Device Supply
Historically, CMS has maintained payment parity between RPM and RTM device supply codes, with equivalent PE RVUs reflecting the similar resource costs of delivering remote monitoring across both modalities. However, the proposed rule introduces a new divergence: RPM device supply codes (99454 and 99XX4) are proposed at a PE RVU of 1.41, while RTM musculoskeletal device supply codes (98977 and 98XX5) are proposed at just 1.18. This results in approximate reimbursement of $47 for RPM device supply and just $40 for RTM musculoskeletal device supply.
This new split creates a reimbursement imbalance that could disincentivize RTM adoption—despite the clinical need and policy emphasis on supporting therapeutic use cases. Providers and digital health platforms offering RTM services should consider submitting comments to urge CMS to maintain payment alignment across remote monitoring categories.
Final Thoughts for Remote Monitoring Companies
These updates prove a clear trajectory many of us have long been pushing for: remote monitoring is no longer experimental—it's being normalized. Moregranular codes for shorter-duration services reflects the years-long efforts of remote monitoring providers and vendors alike in persuading the AMA and CMS to adopt coding and reimbursement policy that accurately reflects practical implementation. For vendors, the proposals also signal a growing legitimacy which may also result in even greater scrutiny of billing documentation and practices.
Greater scrutiny is also implied in CMS’ cautious approach to proposed valuations of new and existing remote monitoring codes for 2026. Stakeholders will need to present persuasive data to back up their comments this year, but if you plan to comment on valuation, consider leveraging data from reputable third-party sources. CMS reminds stakeholders in the 2026 Proposed Rule that they “do not believe that very small numbers of voluntarily submitted invoices are likely to reflect typical resource costs and create the potential for overestimation of supply and equipment costs.”