RPM Billing Requirements for 2026: Codes, Rules and OIG Flags

Updated October 2026. Written by Matteo Grassi, clinical psychologist and cofounder of HANA Health.

Remote physiologic monitoring (RPM) is a Medicare service where a connected medical device sends a patient's health data to a practice, and the practice bills for setup, device supply and monthly treatment management. In 2026, device supply pays when data arrives on 16 or more days in 30, or on 2 to 15 days under new code 99445.

I think of the 16 day rule as a behavior question before it's a billing question: will this patient really take a reading that often?

Key facts

• RPM needs an established patient, patient consent, and a device that meets the FDA definition of a medical device, per the CMS Medicare Learning Network booklet on telehealth and remote monitoring (December 2025).
• Device supply is billed on days of data: 16 or more days in 30, or 2 to 15 days under 99445, which is new for 2026 (Noridian Medicare, December 2025).
• Treatment management is billed on time: 99457 for the first 20 minutes, 99458 for each additional 20, and new 99470 for the first 10 minutes (Noridian, December 2025).
• Only one practitioner can bill RPM per patient in a 30 day period, and RPM and remote therapeutic monitoring can't be billed together (CMS MLN, December 2025).
• Medicare and Medicare Advantage paid $536 million for RPM in 2024, up 31% from 2023, and nearly 1 million enrollees received it (HHS OIG data snapshot, August 2025).
• About 43% of enrollees who received RPM in 2022 didn't receive all three components of the service (HHS OIG, September 2024).
• The CY2027 proposed rule would pay for RPM only when employed clinical staff do the work, starting 1 January 2027 if finalized (Federal Register, July 2026).

What are the Medicare RPM billing requirements?

Medicare requires an established patient, a condition worth monitoring, consent, an FDA defined device that sends data on its own, and a billing practitioner who uses the data to manage care. Miss one and the claim is exposed.

Here's the checklist from the CMS booklet:

• Established patient. The practice needs a prior relationship with the patient. OIG notes the requirement was briefly waived during the COVID-19 emergency and reinstated in May 2023.
• A condition to monitor. The condition can be acute or chronic, and monitoring must be medically reasonable and necessary.
• Consent. CMS requires patient consent at the time you provide RPM.
• A medical device. The device must meet the FDA definition of a medical device. Data has to be collected electronically and uploaded automatically to a secure location the billing practitioner can use.
• Supervision. Auxiliary personnel can furnish RPM under the general supervision of the billing practitioner.
• Who bills. Only physicians and nonphysician practitioners who can bill evaluation and management services can bill RPM, and only one of them per patient in a 30 day period.

Which RPM codes do you bill each month?

You bill up to three kinds of code: setup, device supply and treatment management. Each has its own trigger, and the triggers are different (an event, days of data, and minutes of work).

This is the code by code view, as described by Medicare contractors and professional societies:

• 99453: initial setup and patient education on the equipment. It's billed once per episode of care, according to the American College of Physicians (March 2025).
• 99454: device supply with daily recordings or alerts, each 30 days, when data covers 16 or more days.
• 99445: new for 2026. Device supply when data covers 2 to 15 days. Don't bill it with 99454 in the same period.
• 99457: the first 20 minutes of treatment management in a calendar month, including interactive communication with the patient.
• 99458: each additional 20 minutes of treatment management.
• 99470: new for 2026. The first 10 minutes of treatment management in a calendar month.

The 16 day rule doesn't apply to the treatment management codes, so a month can support management billing even if the device threshold isn't met. Payment varies by locality, so look up your own rates in the CMS fee schedule tool before you model anything.

How does a month of RPM billing work in practice?

Count days and minutes separately, then match each total to a code. Here's a worked example for one patient in one 30 day period, following the 2026 rules above.

1. The patient transmits readings on 12 days. That's 4 days short of the 16 needed for 99454 (16 minus 12 is 4), so 99454 isn't available. 99445 covers 2 to 15 days, so it fits.
2. Staff spend 14 minutes on data review and one call with the patient. That's 6 minutes short of the 20 needed for 99457 (20 minus 14 is 6). The 10 minute code, 99470, describes this level of work.
3. If this is the first month of the episode, 99453 can apply for setup and education.
4. Document the dates of readings, the minutes, who did the work and the call itself.

One honest limit: the contractor article describes 99470 as covering management under 20 minutes, but I haven't found CMS language on how 99470 pairs with 99457 and 99458 in the same month. Confirm that with your MAC.

What changed for RPM codes in 2026?

CMS finalized payment for two new RPM codes, 99445 and 99470, in the CY2026 physician fee schedule final rule published in the Federal Register on 5 November 2025. Both took effect on 1 January 2026.

The change matters because the old rules had a cliff. A patient with 12 days of readings produced no device payment at all, even if the practice did real work.

The new codes close part of that gap, but they don't remove the need to show the work. Fewer days of data and fewer minutes still require documentation of the days, the minutes and the clinical use of the data.

Can you bill RPM with CCM, TCM and other care management?

Yes, with limits. CMS says you can bill RPM or remote therapeutic monitoring, but not both, alongside chronic care management, transitional care management, behavioral health integration, principal care management and chronic pain management for the same patient, as long as you don't count time and effort twice.

That last clause is where audits start. If a nurse spends 25 minutes on a patient in one month, those minutes can support CCM or RPM treatment management, but the same minutes can't count toward both. A time log that tags each minute to one program keeps the books clean.

For a code by code view of CCM, see our CCM billing codes guide.

What did the OIG find about RPM billing?

OIG published two reports in a year, and both are the backdrop for every new RPM rule. They describe patterns, not proof of fraud, but they shape how CMS and auditors read your claims.

The 2024 report looked at 2022 data:

• About 43% of enrollees who received RPM didn't receive all three components, which is roughly 244,000 people.
• About 28% had no claim for education and setup, about 23% had no claim for a device, and about 12% never had treatment management.
• CMS doesn't require billing all three, and OIG notes limited exceptions, but it said the gap raised questions about whether monitoring was used as intended.

The 2025 data snapshot looked at 2024:

• 10,388 practices billed at least one RPM service, and 4,639 billed routinely.
• A typical routine practice billed for about 70 enrollees a year and added about 5 new ones a month.
• 32 practices grew their new enrollees by at least 150% in a single month. One billed nearly 3,400 new enrollees in a month.
• 45 practices had no prior relationship with more than 80% of the patients they billed.
• About 20 practices frequently billed for two or more devices per enrollee per month.

How would the CY2027 proposal change RPM billing?

CMS proposed that RPM and remote therapeutic monitoring be payable only when clinical staff employed by the billing practitioner or practice do the work, starting 1 January 2027 if finalized. It also proposed a separately reportable initiating visit and an established patient rule for RTM.

Vendors could still sell devices and software under the proposal. The restriction is about who performs the clinical work. The final rule usually arrives in early November, and until then this is a proposal, not policy.

We covered the staffing proposal, the pushback and the timeline in our CY2027 RPM and RTM explainer. If your program uses contracted nurses, read it before you plan 2027 staffing.

What this means for your practice

Treat RPM like a three part service that you have to prove each month, because that's how OIG reads it.

• Track three numbers per patient per month: days of data, minutes of management, and whether a conversation happened.
• Decide your device policy. A patient who sends readings on 12 days now has a billable path, but a patient who sends none still doesn't.
• Check who does the clinical work. If it's a contractor, model what you'd do if the 2027 proposal is finalized.
• Keep a clean time log so RPM minutes never double count with CCM or TCM.
• Write down the prior relationship: the date of the visit that came before monitoring.

HANA Health works with practices on the patient outreach side of care management programs, and you can see how on our remote care page.

Frequently asked questions

Can I bill 99454 if the patient only sent readings on 12 days?

No. Device supply under 99454 needs data on 16 or more days in a 30 day period. For 2026, 99445 describes device supply when data covers 2 to 15 days, so 12 days fits there.

Does a medical assistant's call count toward RPM treatment management?

It can. CMS says auxiliary personnel can furnish RPM under the general supervision of the billing practitioner. State law and incident to rules still decide who qualifies, and the minutes can't also count toward another program.

Can a patient use their own blood pressure cuff for RPM?

The device has to meet the FDA definition of a medical device and send data automatically to a secure location. Whether a patient owned device qualifies for the device supply code is a question for your MAC.

Do I need a visit before I start RPM?

You need an established patient relationship today. OIG describes that as a prior in person or telehealth visit with the practice. The CY2027 proposal would add a separately billable initiating visit where monitoring is discussed.

Can RPM and CCM be billed in the same month?

Yes. CMS allows RPM with CCM, TCM, BHI, PCM and chronic pain management for the same patient if time and effort aren't counted twice. RPM and remote therapeutic monitoring can't both be billed for that patient.

Sources

1. Centers for Medicare & Medicaid Services, Medicare Learning Network. Telehealth & Remote Monitoring (MLN901705), December 2025. cms.gov
2. Noridian Healthcare Solutions (JE Part B). Remote Physiologic Monitoring (RPM): 2026 Evaluation and Management (E/M) Updates, December 2025. med.noridianmedicare.com
3. HHS Office of Inspector General. Additional Oversight of Remote Patient Monitoring in Medicare Is Needed (OEI-02-23-00260), September 2024. oig.hhs.gov
4. HHS Office of Inspector General. Billing for Remote Patient Monitoring in Medicare (OEI-02-23-00261), August 2025. oig.hhs.gov
5. Federal Register. Medicare and Medicaid Programs; CY 2026 Payment Policies Under the Physician Fee Schedule (CMS-1832-F), 5 November 2025. federalregister.gov
6. Federal Register. Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule (CMS-1848-P), 16 July 2026. federalregister.gov
7. American College of Physicians. Remote Patient Monitoring Billing, Coding and Regulations Information, March 2025. acponline.org

This article is educational and isn't billing, coding, clinical or legal advice. Check current CMS guidance and your MAC before you bill. If you're deciding how to run remote monitoring for 2027, book a discovery call.