Key RPM takeaways from the 2026 PFS proposed rule

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The Centers for Medicare & Medicaid Service (CMS) recently published its2026 physician fee schedule (PFS) proposed rule. One subject receiving significant attention in the rule is remote care management, and there are a few key proposals that jumped out right away that could significantly reshape how providers approach remote patient monitoring (RPM), care management in rural and underserved settings, and more.

Let's break down some of the highlights, keeping in mind these are proposed changes and not yet finalized.

RPM expansion: More flexible, more patient-centered

The proposed rule introduces significant changes to RPM. Here are the three major components of these changes.

New supply/device codes for greater flexibility

One of the biggest updates in the proposed rule is a new RPM supply code (CPT 99XX4) for patients who only need 2 to 15 days of monitoring in a month that would bring the same reimbursement as the current 16 to 30-day CPT code. This would be a big win for patients with conditions where daily vitals might not be clinically necessary, like obesity being treated with GLP-1s. If finalized, this change would allow for a more nuanced, tailored approach to RPM. In addition to the added flexibility for RPM programs, lowering the required measurement threshold will also generally increase the patient compliance rate — and reimbursement — for existing RPM programs and conditions.

New time-based management code

CMS is also proposing a new RPM management code (CPT 99XX5) for between 10 and fewer than 20 minutes of clinical time. Think of this as a "lightweight alternative" to the current 99457 CPT code, which requires 20 minutes. With a proposed work relative value unit (RVU) of 0.31, it is expected to reimburse at roughly half the rate of CPT 99457. However, it opens the door to build remote care management programs that better match individual patient needs.

CMS vs. AMA: A rift in RPM valuation

CMS notably rejected the American Medical Association's (AMA) proposed redefinition of time thresholds for RPM codes, specifically, AMA's plan to redefine CPT 99457 as 11-20 minutes and allow CPT 99458 to stack in 10-minute increments.

Even more significantly, CMS rejected the AMA RVS Update Committee's (RUC) recommendations for valuing the new RPM codes 99XX4 and 99XX5 and existing code 99457, citing insufficient survey data from the RUC to appropriately value the codes. Instead, CMS proposes using Hospital Outpatient Prospective Payment System (OPPS) data to value these services, marking a potential shift in how remote care services are evaluated.

This disconnect between CMS and the AMA on remote care valuation is far from resolved. CMS has indicated it wants to review RPM valuation after 2026 data becomes available, while the RUC is already planning to revisit code valuations at its January 2028 meeting. This means that while the proposed 2026 RPM changes represent a clear expansion of coverage and would increase overall reimbursement for RPM programs, the debate over how to properly value these services will continue well into the future.

CMS signals commitment to APCM

CMS is clearly invested in the advanced primary care management (APCM) program, and the proposed rule reinforces that commitment. After the introduction of APCM in last year's final rule, many stakeholders expected the 2026 proposed rule to provide more specific guidance about delivery requirements and operational details. Surprisingly, CMS chose not to elaborate on these implementation aspects, leaving providers to navigate the program with the existing framework.

One area where CMS did provide new clarity involves federally qualified health centers (FQHCs). The proposed rule includes new codes that make it easier for FQHCs to bill for behavioral health integration (BHI) and the psychiatric collaborative care model (CoCM) when these services are delivered to patients enrolled in APCM. These new add-on HCPCS codes — GPCM1, GPCM2, and GPCM3 — are particularly notable because they do not carry time-based requirements. If finalized, this would be great news for FQHCs that want to use existing technology to deliver integrated care without jumping through time-tracking hoops. CMS is proposing a direct crosswalk from these add-on codes to the standard CPT code RVUs for BHI and CoCM, ensuring alignment in reimbursement.

Beyond the FQHC provisions, CMS is seeking public comment on the overlap between services provided through the annual wellness visit (AWV) and other preventive benefits — which come with no patient co-pay — and those delivered under APCM, which do carry cost sharing. CMS acknowledges that certain aspects of APCM are distinct and is specifically requesting stakeholder input on whether preventive services should be bundled into APCM, and, if so, how cost sharing should be handled, especially given that some of these services are already covered elsewhere without any out-of-pocket costs for patients.

What it all means for providers

The proposed rule contains significant changes under consideration that could reshape remote care delivery. What does it mean for providers?

First, the new RPM codes signal CMS's recognition that one-size-fits-all monitoring requirements don't match clinical reality. The addition of a 2-15 day supply code with full reimbursement parity and a 10 to under 20-minute management code creates more flexible, patient-centric care options. If finalized, providers could better tailor RPM programs to actual patient needs rather than arbitrary thresholds.

For FQHCs participating in APCM, the new add-on codes for behavioral health integration and psychiatric collaborative care — without time-tracking requirements — would represent a significant opportunity to expand integrated services.

The growing divide between CMS and the AMA over valuation methodology signals uncertainty ahead. With CMS proposing to use OPPS data instead of RUC recommendations, and both entities planning to revisit valuations in the coming years, providers should expect continued flux in RPM reimbursement rates.

Bottom line: If finalized, these changes expand access to remote monitoring while acknowledging the clinical nuance these programs require. However, providers should prepare for ongoing debates about appropriate valuation and stay engaged in the comment process to help shape these critical programs.

If you are interested in a deeper dive into the remote care management changes under consideration, I will be hosting a complimentary webinar on July 31. I plan to explore not just what is in this proposal, but also what it signals about increased federal oversight of remote care and how I anticipate a renewed focus on chronic disease management under the Trump administration could shape the future of these programs. You can register here. I hope you will join me!

Daniel Tashnek is the co-founder of Prevounce Health, a healthcare software and services company that simplifies the provision of preventive medical services, chronic care management and remote patient management. Daniel is also a practicing healthcare attorney specializing in regulatory compliance, reimbursement, scope of practice, and patient care issues.