Over the last few years, the Centers for Medicare & Medicaid Services (CMS) has introduced a series of policy updates that are significantly reshaping how Chronic Care Management (CCM) and Remote Patient Monitoring (RPM) services are delivered and reimbursed under Medicare. These revisions reflect CMS’s evolving strategy to modernize care management moving away from rigid billing rules toward flexibility, integration, and technology‑enabled chronic care delivery. 

1. Decoding the Shift Away from Bundled G0511 Billing 

Previously, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) used a single billing code HCPCS G0511 to encompass multiple care management services, including CCM, RPM, Remote Therapeutic Monitoring (RTM), and others under one umbrella. This created billing ambiguity and sometimes limited the ability of practices to capture reimbursement for specific care management components. 

In the 2025 CMS Physician Fee Schedule (PFS) Final Rule, CMS unbundled the G0511 code entirely. Instead, FQHCs and RHCs must now report each care management service individually using the corresponding CPT/HCPCS codes, bringing their billing structure more in line with traditional ambulatory care settings. This change encourages greater precision in care documentation and billing and allows practices to allocate time and resources more accurately for individual services rather than grouping them under a single code.  

A key implication of this shift is that facilities must now ensure correct and granular code usage. Improper use of CPT codes in lieu of G0511 can jeopardize reimbursement continuity if practices are not prepared for the detailed coding requirement.  

2. New Codes and Flexibility in RPM Billing Under the 2026 Physician Fee Schedule 

One of the most consequential changes in the 2026 CMS Final Rule involves expanded RPM codes that reflect the real‑world ways providers and patients interact with remote monitoring technologies. 

Before this update, RPM reimbursement was tightly tied to fixed thresholds: 

• A patient must transmit physiological data for at least 16 days in a 30‑day period to bill for device supply (CPT 99454) and related services. 

• Treatment management (CPT 99457) required a minimum of 20 minutes of interactive time between the provider and patient each calendar month.  

These rigid requirements often excluded patients who needed less frequent monitoring or whose clinical conditions did not demand continuous data flow. 

The 2026 final rule introduces two new RPM CPT codes designed to address these limitations: 

• CPT 99445: Covers 2–15 days of remote monitoring in a 30‑day period, offering broader reimbursement eligibility for patients with intermittent or short‑term needs. 

• CPT 99470: Allows billing for 10–20 minutes of treatment management, recognizing shorter but clinically relevant care interactions.  

These additions reflect CMS’s acknowledgment that RPM value exists across a spectrum of patient needs — not just when strict transmission or interaction thresholds are met. Importantly, the introduction of short‑duration billing codes expands opportunities for practices to capture revenue for patients whose conditions benefit from less intense monitoring, such as post‑operative follow‑ups or transient clinical issues.  

3. How RPM Reimbursement Is Changing Quantitatively 

Beyond flexibility, CMS is also revising how RPM services are valued under Medicare. 

For example, reimbursement for the traditional RPM treatment management code (99457) has increased modestly under the 2026 schedule. Clinical groups report that rates such as the valuation for 99457 have risen from approximately $47.87 to $51.93, while additional management codes like 99458 also saw increases. This net increase roughly an 8–9% bump for these codes signals continued support for remote care engagement as a reimbursable part of chronic care.  

The combined effect of new codes and pay raise creates a more attractive financial landscape for RPM programs and signals that CMS intends to make remote monitoring a more sustainable revenue stream within fee‑for‑service Medicare.  

4. Concurrent Billing and Integrated Care Models 

One crucial policy shift embedded in recent CMS guidance is the allowance for concurrent billing of CCM and RPM services within the same patient care month. Previously, some limitations discouraged combined billing or required careful documentation to avoid overlapping time counts between codes. 

This new flexibility is crucial for providers pursuing integrated care models where chronic care coordination and remote physiologic monitoring are part of a holistic strategy to prevent exacerbations and reduce hospitalizations. For instance, RPM activities including patient data review and brief interactions can now be appropriately captured under the expanded CPT code set without fear of violating billing rules designed for discrete, isolated services.  

5. Advanced Primary Care Management (APCM) Codes and Value‑Based Shifts 

Another notable development is CMS’s introduction of Advanced Primary Care Management (APCM) codes under the 2025 PFS. These codes package elements of care management activities including comprehensive patient assessment, personalized care planning, and technology‑enabled coordination into broader, integrated billing categories that emphasize outcomes over time spent. 

Unlike traditional time‑based CCM codes, APCM models reward providers for delivering proactive, population‑based care, aligned with Medicare’s shift toward value‑based care. While APCM codes may not be directly relevant to every CCM or RPM implementation, they are a clear signal that CMS wants providers to focus on clinical outcomes, patient engagement, and comprehensive care coordination rather than merely tracking minutes and checklists. 

6. Practical Implications for Providers and Practices 

These changes represent both opportunity and complexity for health systems, ambulatory providers, and care managers. 

Positive implications include: 

• Expanded Billing Opportunities: New RPM codes make it easier for clinicians to generate reimbursement for patients with intermittent or short‑term monitoring needs.  

• Greater Revenue Capture: Increased reimbursement rates and concurrent billing help practices maximize financial returns on RPM and CCM programs.  

• Improved Alignment to Patient Needs: Flexible coding supports customized care plans that are not penalized for shorter interactions or inconsistent data transmission.  

However, these updates also heighten documentation requirements and necessitate advanced systems including software tools  to accurately track data transmissions, patient interactions, and code applicability. Practices that fail to adopt compliant workflows may miss billing opportunities or face denials.  

Conclusion: A Transitional Era for Care Management 

CMS’s recent updates signal a major shift in how Medicare views care management: from episodic, threshold‑based billing to flexible, patient‑centered care coordination that rewards clinical engagement and appropriate use of monitoring technologies. For practices and technology vendors alike, these changes underline the importance of robust compliance, smart workflows, and strategic planning to thrive in the evolving chronic care landscape. 

As RPM and CCM become increasingly integrated into Medicare’s broader care delivery framework, providers who adapt early and leverage these new rules intelligently will be better positioned to improve patient outcomes and practice sustainability.