Overview
Over the past several years, the Centers for Medicare & Medicaid Services (CMS) has expanded payment for remote monitoring services in an effort to recognize and pay for non-face-to-face services that improve care management for Medicare beneficiaries. In connection with the CY 2026 Medicare Physician Fee Schedule (MPFS) proposed rule (the Proposed Rule), CMS proposes several payment policy changes for remote monitoring services, including recognizing new modifications to the remote physiological monitoring (RPM) and remote therapeutic monitoring (RTM) codes. Most significantly, CMS proposes payment rates for new RPM and RTM codes established by the American Medical Association’s (AMA) CPT Editorial Panel last year that, if finalized, would be effective January 1, 2026.
CMS also requests comments on how to establish pricing for software as a service (SaaS) under the MPFS, which has implications for the proposed reimbursement amounts for certain RPM and RTM codes. Comments on the Proposed Rule are due to CMS by 5:00 pm EDT on September 12, 2025.
In Depth
Background
CMS pays for remote monitoring services, which generally use digital technologies (medical devices, together with software) to collect medical and other forms of health data from a patient in one location and electronically transmit the information to the patient’s healthcare provider in a different location for assessment and care management. The data collected is electronically transmitted to health professionals for review and can be used in ongoing patient management. In some cases, the technologies can either trigger direct patient engagement or facilitate that communication.
RPM services involve monitoring physiological measurements (e.g., weight, blood pressure, blood sugar) through medical devices, which automatically transmit data obtained from patients remotely to healthcare providers for assessment and recommendations. In contrast, RTM services involve the use of medical devices to monitor a patient’s health or response to treatment using non-physiological data. RTM services can monitor medication adherence, response to therapy, musculoskeletal activity, and respiratory activity. Unlike RPM, devices for RTM are not limited to transmitting data automatically obtained from patients but can also transmit data self-reported by patients.
Separately, many healthcare services have begun to include software algorithms and other software-based technologies to support clinical services in recent years. Under the existing MPFS payment methodology, most computer software and associated analysis and licensing fees are considered to be “indirect costs” associated with hardware costs. This creates challenges in appropriately valuing and paying for SaaS that is incorporated into healthcare services payable under the MPFS.
On July 14, 2025, CMS released the CY 2026 Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Medicare Part B Proposed Rule, which includes proposed changes to payment for RPM and RTM services and requests information regarding payment for SaaS devices.
RPM proposals
Coding
The RPM code set currently includes CPT codes 99453, 99454, 99091, 99457, 99458, 99473, and 99474. CMS proposes payment rates for new RPM codes and changes to existing codes accepted by the AMA’s CPT Editorial Panel last year.
For CY 2026, the CPT Editorial Panel created two new RPM codes to describe RPM services that include fewer than 16 days of data transmission per 30-day period and fewer than 20 minutes of interactive communication per month: CPT codes 99XX4 and 99XX5, respectively. In the Proposed Rule, CMS proposes to accept these codes and establish payment rates effective January 1, 2026. The CPT Editorial Panel also made edits to specify the minimum days of data transmission per 30-day period for CPT code 99454, which CMS proposes to adopt. The current, revised, and new RPM code descriptions are summarized in Table 1.
CMS notes that many of the codes (99091, 99474, 99XX5, 99457, and 99458) will have to be resurveyed after one year of utilization data becomes available because the codes did not meet minimum survey requirements for the CPT Editorial Panel’s January 2025 Relative Value Scale Update Committee (RUC) meeting. CMS also notes that all remote monitoring codes are expected to be reviewed at the CPT Editorial Panel’s January 2028 meeting.
Table 1: RPM codes
| Code | Code Category | CY 2025 Long Descriptor | Proposed Code Descriptor Changes for CY 2026 |
|---|---|---|---|
| 99453 | Patient education and device set-up | Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment | No changes for CY 2026 |
| 99XX4 | Data transmission and device supply codes | N/A, new proposed code for CY 2026 | Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, 2 – 15 days in a 30-day period |
| 99454 | Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days | Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, 16 – 30 days in a 30-day period | |
| 99091 | Treatment management services | Collection and interpretation of physiologic data (e.g., ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician and/or other qualified healthcare professional, qualified by education, training, licensure/regulation (when applicable), requiring a minimum of 30 minutes of time each 30 days | No changes for CY 2026 |
| 99XX5 | N/A, new proposed code for CY 2026 | RPM treatment management services, clinical staff/physician/other qualified healthcare professional time in a calendar month requiring real-time interactive communication with the patient/caregiver during the calendar month; first 10 minutes | |
| 99457 | Remote physiologic monitoring treatment management services by clinical staff/physician/other qualified healthcare professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; first 20 minutes | No changes for CY 2026 | |
| 99458 | Remote physiologic monitoring treatment management services by clinical staff/physician/other qualified healthcare professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; each additional 20 minutes (list separately in addition to code for primary procedure) | No changes for CY 2026 | |
| 99473 | Patient education and device set-up | Self-measured blood pressure using a device validated for clinical accuracy; patient education/training and device calibration | No changes for CY 2026 |
| 99474 | Data transmission, device supply, and treatment management services | Self-measured blood pressure using a device validated for clinical accuracy; separate self-measurements of two readings one minute apart twice daily over a 30-day period (minimum of 12 readings), collection of data reported by the patient and/or caregiver to the physician or other qualified healthcare professional with report of average systolic and diastolic pressures and subsequent communication of a treatment plan to the patient | No changes for CY 2026 |
Payment valuations
In the Proposed Rule, CMS uses three different approaches to payment valuation for the RPM codes. For most existing codes (99453, 99457 – 99458, and 99473 – 99474), CMS proposes no changes in the work or practice expense (PE) relative value unit (RVU), in part because the codes did not meet the minimum survey requirements established by the RUC.
For 99454 and 99XX4, CMS acknowledges that the RUC recommended a new PE input: “digital remote physiologic monitoring device app.” This proposed form of direct PE is a per-click vendor fee. However, CMS did not accept this new input, expressing concerns about establishing a price for a PE input in a field that has evolving technology and is based on a limited number of inputs (i.e., substantive invoices and other supportive data to establish the pricing for the input).
Based on these concerns, CMS proposes a new approach to valuation that is a variation on the crosswalk approach that CMS has used in prior rulemaking cycles. For CY 2026, CMS proposes to use hospital claims data for 99454 (specifically the total geometric mean cost that CMS calculates from the submitted cost data) to set the PE RVU for 99454. CMS proposes this approach based on the stated rationale that the data submitted via hospital claims more accurately reflects the cost of the service and, because this code is a PE-only code, the costs should be consistent across the different settings. Based on the RVU values posted in Addendum B, CMS uses the total geometric mean cost published in the CY 2025 Outpatient Prospective Payment System (OPPS) final rule and divides that value by the CY 2026 PFS conversion factor. CMS proposes to use the same approach and same PE RVU for 99XX4. For CY 2026, this approach leads to a proposed increase in the payment rate for 99454 ($47.06, up from $43.02).
CMS did not accept the RUC recommendations for 99XX5 and proposes to establish a linear relationship between 99XX5 and 99457. As the work and intensity of work are similar and the primary difference is the time associated with the codes, CMS proposes to set the work RVU for 99XX5 at 50% of that for 99457, because the time required (10 minutes) is 50% of that for 99457 (20 minutes).
RTM proposals
Coding
The RTM code set currently includes CPT codes 98975, 98976, 98977, 98978, 98980, and 98981. Like the RPM proposals above, CMS proposes payment rates for the new codes and changes to existing RTM codes consistent with the changes made by the CPT Editorial Panel.
For CY 2026, the CPT Editorial Panel created four new RTM codes to describe RTM services that include fewer than 16 days of data transmission per 30-day period and fewer than 20 minutes of interactive communication per month: CPT codes 98XX4, 98XX5, 98XX6, and 98XX7. CMS proposes to adopt these codes. The CPT Editorial Panel also made edits to specify the minimum days of data transmission per 30-day period for CPT codes 98976, 98977, and 98978. CMS proposes to adopt these edits.
All codes in the RTM family are considered new technology and will be placed on the new technology list to be reviewed after three years of data are available, which will be in April 2030.
Table 2: RTM codes
| Code | Code Category | CY 2025 Long Descriptor | Proposed Code Descriptor Changes for CY 2026 |
|---|---|---|---|
| 98975 | Patient education and device set-up | Remote therapeutic monitoring (e.g., therapy adherence, therapy response, digital therapeutic remote therapy); initial set-up and patient education on use of equipment | No changes for CY 2026 |
| 98XX4 | Data transmission and device supply codes | N/A, new proposed code for CY 2026 | Remote therapeutic monitoring (e.g., 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 (emphasis added) |
| 98976 | Remote therapeutic monitoring (e.g., therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of respiratory system, each 30 days | Remote therapeutic monitoring (e.g., therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of respiratory system, 16 – 30 days in a 30-day period (emphasis added) | |
| 98XX5 | N/A, new proposed code for CY 2026 | Remote therapeutic monitoring (e.g., 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 (emphasis added) | |
| 98977 | Remote therapeutic monitoring (e.g., therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of musculoskeletal system, each 30 days | Remote therapeutic monitoring (e.g., therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of musculoskeletal system, 16 – 30 days in a 30-day period (emphasis added) | |
| 98XX6 | N/A, new proposed code for CY 2026 | Remote therapeutic monitoring (e.g., 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 (emphasis added) | |
| 98978 | Remote therapeutic monitoring (e.g., therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of cognitive behavioral therapy, each 30 days | Remote therapeutic monitoring (e.g., therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of cognitive behavioral therapy, 16 – 30 days in a 30-day period (emphasis added) | |
| 98XX7 | Treatment management services | N/A, new proposed code for CY 2026 | Remote therapeutic monitoring treatment management services, physician or other qualified healthcare professional time in a calendar month requiring at least one real-time interactive communication with the patient or caregiver during the calendar month; first 10 minutes (emphasis added) |
| 98980 | Remote therapeutic monitoring treatment management services; physician or other qualified healthcare professional time in a calendar month requiring at least one interactive communication with the patient or caregiver during the calendar month; first 20 minutes (emphasis added) | No changes for CY 2026 | |
| 98981 | Remote therapeutic monitoring treatment management services; physician or other qualified healthcare professional time in a calendar month requiring at least one interactive communication with the patient or caregiver during the calendar month; each additional 20 minutes (list separately in addition to code for primary procedure) (emphasis added) | No changes for CY 2026 |
Payment valuations
For the RTM codes, CMS uses four different approaches to payment valuation. For a subset of the existing codes (98975, 98980, and 98981), CMS does not propose any changes to the work or PE RVU in part because the codes did not meet the minimum survey requirements established by the RUC.
For 98977 and 98XX5 (RTM for musculoskeletal system), CMS proposes to use the same approach that it proposes for the RPM device supply codes (99454 and 99XX4). CMS proposes to use hospital cost data submitted under the OPPS to establish the PE RVU. For CY 2026, CMS proposes to use the hospital claims data for 98977 (specifically the total geometric mean cost that CMS calculates from hospital-reported cost data) to set the PE RVU for 98977. In the Proposed Rule, CMS uses the total geometric mean cost published in the CY 2025 OPPS final rule and divides it by the CY 2026 MPFS conversion factor. CMS proposes to use the same approach and same PE RVU for 98XX5. For CY 2026, in contrast to RPM, this approach leads to a proposed decrease in the payment rate for 98977 ($39.77, down from $43.02).
CMS did not accept the RUC recommendations for 98XX7 and proposes to establish a linear relationship between 98XX7 and 98980. As the work and intensity of work are similar and the primary difference is the time, CMS proposes to set the work RVU for 98XX7 at 50% of that for 98980, because the time required (10 minutes) is 50% of that for 98980 (20 minutes).
Finally, CMS proposes to have 98978 and its new corresponding code, 98XX6, contractor priced – an approach used for 98978 in 2025. In response to the RUC recommendations, CMS also proposes to have 98976 contractor priced (a change from 2025) and to use the same approach for its new accompanying code, 98XX6.
Request for comments
CMS seeks comments on whether there are differences in the valuation of RPM and RTM services, specifically whether the services have similar costs and/or PE inputs. CMS proposes similar valuations for what it has historically viewed as similar remote monitoring services (for example, RTM and RPM treatment management, RTM and RPM device supply, RTM and RPM data transmission), but is interested in gaining more information regarding any differences in work (in the case of timed codes, whether there are varying levels of intensity between RTM and RPM), clinical staff time, supplies or equipment. CMS notes that it is particularly interested in comments that include data or evidence to support their position.
Separately, CMS seeks comment on payment under the MPFS for SaaS. CMS requests public comment on what factors the agency should consider when paying for SaaS, alternative pricing methodologies that could be used to accurately pay for SaaS and artificial intelligence devices under the MPFS, and whether there are alternative data sources that accurately reflect the costs of SaaS technologies.
Analysis
CMS proposes a novel valuation methodology for the device supply codes for both RPM and RTM that would rely on hospital cost data submitted under the OPPS to determine the reimbursement rate under the MPFS. Although CMS has the ability to utilize cost, charge, or other data from service providers to establish reimbursement rates under the MPFS, it is unique that CMS proposes to take information from a higher cost setting (hospitals) and apply that cost data to establish reimbursement rates for services furnished in a lower cost setting (physician offices). Indeed, we are not aware of CMS ever previously using OPPS data to establish payment rates under the MPFS. CMS notes that it believes the OPPS cost data is more accurate than the PE inputs recommended by the RUC, although RPM and RTM services are typically (although not always) furnished in a physician office setting.
The proposed use of OPPS cost data to establish PE RVUs raises additional questions. How will CMS account for the less frequent use of RPM and RTM services in hospital settings (leading to potentially understated hospital cost report data) compared to physician office settings? It also remains unclear how CMS plans to adjust the PE RVU for the RPM and RTM device supply codes in the future and how frequently updated OPPS cost data would be incorporated into the rate setting methodology.
With respect to CMS’s request for additional information on payment for SaaS under the MPFS, CMS requests comments on whether its proposed approach for remote monitoring services should be followed more broadly for other SaaS devices (i.e., integrating OPPS geometric mean costs for SaaS to determine the device rate).
Healthcare providers who furnish RPM and RTM services and vendors that rely on the RPM and RTM codes should carefully review CMS’s proposals and consider providing comments. Comments are due at 5:00 pm EDT on September 12, 2025.
