CMS proposes lower time thresholds for remote patient monitoring

The Centers for Medicare & Medicaid Services (CMS) is proposing to loosen the time requirements for billing remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM). 

For background on RPM, RTM, and related payment standards, click here.

The Medicare Physician Fee Schedule 2026 Proposed Rule, published in yesterday’s Federal Register, sets forth new billing codes for RPM medical device supply and data transmission and RTM medical device supply and data access or transmission that would allow Medicare payment if data is collected 2 to 15 days in a 30-day period (existing codes require at least 16 days) and for 10 minutes of RPM or RTM treatment management in a calendar month  (existing codes require at least 20 minutes).  The revisions would allow billing under either the lower or higher time threshold for supply and transmission or access (2 to 15 days or 16 to 30 days) and either the lower or higher threshold for RPM or RTM treatment management (10 minutes or increments of 20 minutes in a calendar month).

These new and revised billing codes are based on changes approved by the American Medical Association CPT Panel in September 2024. These new codes are scheduled to take effect January 1, 2026, and would expand RPM and RTM billing opportunities.

CMS is requesting information on other digital health topics, including:

• payment structures for software as a service (SaaS) and AI;
• prevention and management of chronic disease; and
• potential coding and payment for medical devices.

CMS will consider comments on the proposed rule that are received by September 12, 2025.

For more information on remote patient monitoring and related issues, please contact attorney Rick Hindmand.