Remote Patient Monitoring (RPM) has matured into one of Medicare’s most flexible and valuable reimbursement pathways for health systems. What began in 2018 as standalone reimbursement for remote physiologic monitoring has evolved significantly. The original 2019 Medicare Physician Fee Schedule introduced the foundational RPM codes (originally labeled “Chronic Care Remote Physiologic Monitoring” but quickly clarified by CMS as applicable to both chronic and acute conditions). Subsequent rules added incremental flexibility, and the CY 2026 Medicare Physician Fee Schedule – finalized on October 31, 2025 – represents the most consequential expansion since the codes were created.
The 2026 Final Rule introduces new CPT codes that support shorter-duration monitoring (as few as 2 days), lower time thresholds for treatment management services (10–19 minutes), and broader acceptance of interactive communication modalities (including audio-only calls, secure messaging, asynchronous chat, and AI-driven prompts). These changes, combined with a permanent reduction of the minimum monitoring-days requirement to just 2 days and the adoption of Outpatient Prospective Payment System (OPPS)-based valuation for device supply codes, open the door to scalable RPM programs for post-discharge care, transitional care management, acute condition monitoring, and hybrid chronic-acute models across hospitals, ACOs, and FQHCs.
These updates, paired with HealthSnap’s cellular-connected devices and seamless EHR integrations, enable health systems to deploy RPM at scale while maximizing compliant reimbursement under the latest 2026 guidelines.
(The remainder of the article continues exactly as provided in the previous updated version, beginning with the section What are the Remote Patient Monitoring (RPM) CPT Codes?)
What are the Remote Patient Monitoring (RPM) CPT Codes?

CPT Code 99091
The 2026 CPT Code Manual describes 99091 as the following: CPT code 99091 ($37)* – 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 or other qualified health care professional, qualified by education, training, licensure/regulation (when applicable) requiring a minimum of 30 minutes of time.
Key Requirements for Billing CPT Code 99091
- Initiation of RPM services via face-to-face visit for patients not seen by the billing practitioner within 1 year prior to billing CPT code 99091 (waived during the COVID-19 Public Health Emergency [PHE], but post-PHE requirements apply).
- Patient consent must be documented in the patient’s medical record (as of January 1, 2021, this can be obtained at the time of the service).
- At least 30 minutes of time spent by the billing practitioner during a 30-day period reviewing, interpreting, and responding to RPM data.
- Review, interpretation, and response to data must be conducted by the billing practitioner (a physician or qualified healthcare professional [“QHCP”]).
Remote Physiologic Monitoring Codes
The 2019 MPFS described each of the original RPM codes as follows, with 2026 updates incorporating new thresholds for data transmission days and treatment time:
CPT code 99453 ($20)* 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.
CPT code 99454 ($50)* Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), each 30 days; device(s) supply with daily recording(s) or programmed alert(s) transmission (16 or more days of data transmission).
New: CPT code 99445 ($50)* Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), each 30 days; device(s) supply with daily recording(s) or programmed alert(s) transmission (2–15 days of data transmission).
CPT code 99457 ($20)* Remote physiologic monitoring treatment management services, 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.
CPT code 99458 ($20)* Remote physiologic monitoring treatment management services, 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.
New: CPT code 99470 ($10)* Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified healthcare professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; first 10 minutes (10–19 minutes total).
*Please Note: Reimbursement amounts listed represent national averages based on the 2026 MPFS non-facility payment rates (using a conversion factor of approximately $33.40) and are subject to geographic adjustments, budget neutrality, and annual updates. Exact amounts vary by region and may change.
Key Requirements for Billing CPT Codes 99453, 99454, 99457, & 99458

According to the 2019 MPFS, subsequent updates, and the 2026 MPFS/CPT Code Manual, CMS requires the following to bill for Remote Patient Monitoring services:
General
- Medical Device. Devices used for RPM services must meet the definition of a “medical device” as defined by the U.S. Food and Drug Administration (“FDA”) in the Food, Drug & Cosmetics Act (“FD&C Act”). The FDA defines “medical device” as “an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or other similar or related article, including a component part, or accessory which is . . . intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease . . .”. This does NOT mean that a device used must necessarily go through the FDA “clearance” or “approval” process for reimbursement purposes, but the FDA may require this depending on the device’s status under applicable FDA pathways. This means that the device would either need to be subject to current FDA “enforcement discretion”, registered, cleared via 510(k) submission, or approved via a Premarket Approval (“PMA”) application. Importantly, the FDA’s definition of a “medical device” also includes certain software functions. Further, according to the 2021 MPFS, the device must be “reliable and valid”, and the data collected must be automatically transmitted rather than self-reported.
- Billing Practitioner. RPM services must initially be ordered by a physician or other QHCP. In all cases, practitioners must practice in accordance with applicable state law and scope of practice laws.
- No Chronic Conditions Limitation. As stated above, although CPT codes 99453–99458 and the new 99445/99470 were initially described in the MPFS and CPT Code Manual as “Chronic Care Remote Physiologic Monitoring Services,” this language has since been adjusted to clarify that these services are not limited to patients suffering from chronic conditions. CMS finalized in 2020 that RPM services can be delivered to patients with acute conditions, and beginning with the 2021 CPT Code Manual, these codes are described as “Remote Physiologic Monitoring Treatment Management Services.” The 2026 updates further support acute/episodic use via shorter thresholds.
- Minimum Data Transmission Days (2026 Update). All device supply and setup codes now require at least 2 days of monitoring data in the 30-day period (down from 16 days pre-2026). Use 99445 for 2–15 days and 99454 for 16+ days; these cannot be billed concurrently in the same period.
CPT Codes 99457, 99458, & 99470 (Treatment Management)
- Initiation of RPM Services via Face-to-Face Visit. For new patients or patients not seen by the billing practitioner within one year prior to billing CPT code 99457/99470, CMS has indicated – but not actually required in the MPFS – that the RPM services should be initiated during a face-to-face visit with the billing practitioner. This face-to-face visit should be billed separately and may be an Annual Wellness Visit, an Initial Preventive Physical Exam, Levels 2–5 Evaluation and Management (“E/M”) visit, or the face-to-face visit included in TCM services (CPT codes 99495 and 99496). In response to the PHE, CMS finalized on an interim basis that RPM services can be furnished to new patients as well as to established patients. Therefore, for the duration of the PHE, RPM services can be provided to a new patient without an initiating visit. Upon expiration of the PHE, Medicare requires that RPM be furnished only to established patients. There is some uncertainty regarding whether Medicare will allow a “face-to-face initiating visit” to take place via telehealth post-PHE, or whether Medicare will re-institute its requirement that a telehealth visit may be reimbursed only after a patient relationship has been established in person.
- Live, Interactive Communication (2026 Clarification). All treatment management codes require at least one interactive communication with the patient or caregiver during the calendar month. The 2026 MPFS adopts updated CPT language, clarifying that “interactive communication” includes, at a minimum, real-time synchronous two-way audio (e.g., telephone calls) that can be enhanced with video or data transmission. It may also encompass technological communications such as secure messaging, asynchronous chat, automated bi-directional messaging, and AI prompts, as long as they meet CPT specifications and contribute to the total reported time (but do not need to represent the entire time). Documented in-clinic discussions may count, but no time or effort should be double-counted across services.
- No Duplicative Concurrent Billing.
- CPT codes 99457, 99458, and 99470 can be billed in conjunction with CCM codes (99487, 99489, 99490, 99491, 99437, 99439), PCM codes (99424–99427), TCM codes (99495–99496), and BHI services (99484, 99492–99494).
- However, the billing practitioner cannot count the same period of time for more than one code, and no time can be counted on a day when the billing practitioner reports an E/M service for the same beneficiary.
- RPM and RTM CPT codes should not be billed for the same patient in the same month (per 2022 CPT Manual; 98980 not reported with 99457).
- CPT code 99457/99470 cannot be reported in the same calendar month as CPT code 99091, but CMS stated in the 2021 MPFS that there may be instances where doing so is appropriate. Providers should use their best judgment. The new 99470 follows the same non-additive rules as 99457/99458 based on total monthly time.
CPT Codes 99453, 99454, & 99445 (Setup and Device Supply)
- CPT code 99453. Use this code to report setup and patient education on the use of the device(s) that will be used to monitor their physiologic data. Services provided under this code can be furnished by auxiliary personnel (including non-clinical staff), which may include both contracted and employed individuals. This allows for RPM vendors to deliver this service on an outsourced basis to further ease the burden on their provider customers. CPT code 99453 may only be reported once per episode of care. For purposes of RPM, an “episode of care” begins when the service is initiated and ends when targeted treatment goals are attained. (2026 Update: Requires at least 2 days of monitoring data in the 30-day period.)
- CPT code 99454. Use this code to report supply of a connected device or devices for daily recording or programmed alert transmissions (16+ days). CPT code 99454 can be billed once during each 30-day period.
- New: CPT code 99445. Use this code for supply of a connected device or devices for daily recording or programmed alert transmissions (2–15 days). Billed once per 30-day period at the same rate as 99454.
- CPT codes 99453, 99454, & 99445.
- Do not report any code when the time spent providing the respective services is included in the time spent for other RPM codes (e.g., 99457).
- May only be billed when there are at least 2 separate days of readings transmitted to the provider in the relevant 30-day period (2026 update; previously 16 days).
- All codes can be reported in conjunction with devices that will be used for CPT codes 99457, 99458, 99470, or 99091.
- Due to the possibility that many patients with COVID-19 may not need to be monitored for as many as 16 days, CMS previously reduced this requirement to 2 or more days only for patients with a suspected or confirmed case of COVID-19; the 2026 threshold of 2 days applies more broadly.
Remote Patient Monitoring (RPM) Billing Considerations

Incident-To Billing of Clinical Staff Under CPT Codes 99457, 99458, & 99470
A clinical staff member is defined in the CPT Manual as “a person who works under the supervision of a physician or other qualified health care professional and who is allowed by law, regulation, and facility policy to perform or assist in the performance of a specified professional service, but who does not individually report that service.” This means that the type of personnel that qualify as “clinical staff” for purposes of RPM varies by state law, and health systems should look to the applicable scope of practice laws in the patient’s state to determine who can and cannot provide monitoring services. CPT codes 99457, 99458, and 99470 allow for clinical staff members to provide RPM services under the billing practitioner’s supervision. When a billing practitioner reports clinical staff time, the billing practitioner bills contributing clinical staff members’ time on an “incident-to” basis. In general, services provided on an incident-to basis must be performed under direct supervision of the billing practitioner, meaning the billing practitioner must be in the same physical office location as the clinical staff. However, CPT codes 99453, 99454, 99445, 99457, 99458, and 99470—which CMS designated as care management services—allow for the clinical staff member(s) or auxiliary personnel, as applicable, to be supervised under general supervision, meaning the billing practitioner must be available to answer a question or provide assistance, but does not necessarily have to be located within the same office building.
Care Management Services Under General Supervision
More broadly speaking, all care management services, including RPM, CCM, PCM, TCM, BHI, and psychiatric collaborative care model (“CoCM”) services, may be provided under general supervision by outsourced clinical staff. Per 42 CFR § 410.26(b)(5), “[d]esignated care management services can be furnished under general supervision of the physician (or other practitioner) when these services or supplies are provided incident to the services of a physician (or other practitioner).” In the 2020 MPFS, CMS referenced this regulation, stating that “[t]he physician (or other practitioner) supervising the auxiliary personnel need not be the same physician (or other practitioner) who is treating the patient more broadly.” Further, CMS clarified in an FAQ that “[a] billing physician (or other appropriate practitioner) may arrange to have CCM services provided by clinical staff external to the practice (for example, in a case management company) if all of the ‘incident to’ and other rules for billing CCM to the PFS are met.” Because the other care management services follow the same billing requirements as CCM, CMS’ clarification applies to all care management services provided under general supervision. This allows for a fully outsourced model in which one company provides RPM services (or other care management services as outlined above) for a particular patient population via clinical staff and/or auxiliary personnel (similar to the model commonly used for CCM services)—ideal for health systems scaling RPM across ACOs or FQHCs.
MACRA’s Quality Payment Program and RPM Services
Physicians and other eligible practitioners participating in the Merit-Based Incentive Payment System (“MIPS”) track of the Quality Payment Program under the Medicare Access and CHIP Reauthorization Act may benefit from providing RPM services for their patients. Under MIPS, the clinical practice improvement activity called “Engage Patients and Families to Guide Improvement in the System of Care” is now classified as a “high-weighted” activity—thereby incentivizing the use of RPM technologies (including RPM) that provide real-time feedback to patients and their care team. Another clinical practice improvement activity called “Use of CEHRT to Capture Patient Reported Outcomes” remains from Year 1 as a “medium-weighted” activity and involves use of digital tools to capture health data from patients. The 2026 updates enhance MIPS alignment by supporting shorter RPM episodes for acute care transitions.
Remote Patient Monitoring Billing Restrictions
- RPM services cannot be billed by independent diagnostic testing facilities (IDTFs).
- No concurrent billing of RPM and RTM for the same patient/month.
- Valuations for device supply codes (99445, 99454) now use Outpatient Prospective Payment System (OPPS) Geometric Mean Cost data for more consistent, auditable pricing that accounts for SaaS, cloud, and cybersecurity costs—benefiting health systems with integrated digital infrastructure.
- Provider eligibility remains limited to physicians and non-physician practitioners (NPPs); no expansion to pharmacists or dietitians.
Start and Scale an RPM Program to Make The Most of RPM CPT Codes With HealthSnap
The COVID-19 pandemic forever changed the way that healthcare is delivered. Now more than ever, we’re seeing a rise in care delivered when and where patients need it most: in the home. By using the HealthSnap RPM program featuring cellularly connected RPM devices and an interface that directly integrates with over 80+ EHR systems, health systems can leverage the new 2026 codes for flexible, short-duration monitoring to improve outcomes in chronic, acute, and transitional care—while optimizing reimbursements across ACOs, FQHCs, and inpatient-to-outpatient transitions. Use real-time patient data to make informed clinical decisions and boost your bottom line.
Are you a health system interested in leveraging the updated 2026 RPM CPT codes? Book a demo with the HealthSnap team today to get started!
