The Final CY 2026 CMS Physician Fee Schedule (PFS) Brings Constructive Changes for Remote Care Programs

The Calendar Year (CY) 2026 Physician Fee Schedule (PFS) final rule from the Centers for Medicare & Medicaid Services (CMS) continues a direction that many high-performing outpatient practices already recognize as inevitable: the center of gravity in chronic disease management is shifting from episodic visits to longitudinal, between-visit operations. What makes the 2026 update particularly constructive is not that it invents remote care, but that it improves the mechanics that determine whether remote programs are actually runnable at scale: clinically disciplined, financially sustainable, and operationally defensible.

For practices that have invested in care management infrastructure, the signal is encouraging. CMS is continuing to normalize remote work as part of routine outpatient care, and it is doing so by making policy choices that better match how patients actually engage and how clinicians actually intervene. In practical terms, it is becoming easier to design remote care programs that are clinically honest (higher intensity when risk is high, lighter touch when stability returns) without forcing month-long, one-size-fits-all monitoring patterns that create friction for staff and patients.

If you lead a primary care, cardiology, endocrinology, pulmonary, orthopedics, physical therapy, or multispecialty practice, you already know the core tension. Much of the clinical leverage in chronic disease and recovery management happens outside the office visit: reviewing trends, catching deterioration early, adjusting plans, coaching adherence, coordinating across teams, and integrating behavioral health when it is the limiting factor. Yet reimbursement structures have often lagged behind those realities, leaving teams to choose between doing meaningful work that never becomes reliably billable or bending workflows to satisfy thresholds that do not reflect clinical need.

CY 2026 pushes the system in a practical, positive direction by aligning reimbursement more closely with real-world remote care patterns across Remote Patient Monitoring (RPM), Remote Therapeutic Monitoring (RTM), and Advanced Primary Care Management (APCM). Put plainly, CMS is signaling that shorter, clinically meaningful episodes should be reimbursable; that not every patient needs daily monitoring to justify clinician oversight; and that behavioral health integration should be attachable to primary care management in a way that practices can operationalize month after month.

This post is a strategic and operational guide for clinicians, practice administrators, and revenue cycle leaders. It summarizes what matters most for remote care programs in 2026 and then goes deeper (code by code) on the updates that will change how you design workflows, documentation standards, staffing models, and billing logic. Along the way, it highlights how Lara Health helps practices translate policy into a repeatable operating system rather than a brittle set of rules that only one person understands.

What CMS is signaling in 2026, in operational terms

Before getting into specific codes, it helps to name the strategic arc. CMS is not merely adding new billing options. It is refining the plumbing that makes longitudinal, team-based care feasible in the everyday environment of outpatient medicine, where staffing constraints, patient variability, and documentation burden determine whether a program survives beyond its pilot phase.

First, CMS is lowering friction for short episodes and lower-intensity months. In real practice, remote monitoring intensity is not constant. It spikes after medication changes, post-discharge transitions, symptom flares, and post-procedural recovery, and then appropriately tapers. Shorter thresholds recognize that value is often created in those transitions, even when the month never reaches older minimums.

Second, CMS is strengthening flexibility around what data is clinically meaningful. RPM is anchored in physiologic data collected by qualifying devices and transmitted for review. RTM, by design, is broader and can include non-physiologic data such as therapy adherence, symptoms, functional status, response to therapy, and other therapeutically relevant measures depending on the clinical context. Policies that acknowledge intermittent monitoring and non-physiologic data streams make remote care more usable across more cohorts, including rehabilitation, step-down monitoring, and episodic “tighten, stabilize, taper” pathways.

Third, CMS is leaning into integrated care by supporting APCM and enabling behavioral health add-ons. If you have tried to bolt on behavioral health as a separate workflow after you already built chronic care operations, you know how quickly it becomes an unscalable patchwork. APCM add-ons create a pathway to make behavioral health integration a repeatable part of routine care operations, with clearer alignment between what is delivered and what is reimbursed.

The practical implication is reassuring: CMS is moving remote care closer to being standard operating capability, not an experimental side project. That trend should increase confidence for practices that want to invest in staffing, training, and workflows that deliver measurable results and withstand billing scrutiny.

The three headline changes for remote care programs in 2026

The 2026 update is easiest to understand as three workflow shifts: shorter billing thresholds, expanded device and data flexibility, and behavioral health integration at scale through APCM.

To make this actionable, the table below frames the changes the way an operator would: what changed, what it enables clinically, and what you need to update in your workflows.

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What follows is intentionally code-specific. The new “short-period” device codes and the new 10-minute introductory management codes are not merely line items in a fee schedule; they change how you design care pathways and how reliably you can run month-end operations without frantic reconciliation. The APCM behavioral health add-ons matter for the same reason: they are easiest to implement when you treat them as a workflow, not as a billing afterthought.

CPT 99470: RPM intro (10 minutes of treatment management)

CPT 99470 is designed to describe a shorter first segment of RPM treatment management time in a calendar month. In practical terms, it is meant to capture months where the care team does clinically meaningful work: reviewing transmitted physiologic data, making contact with the patient or caregiver, adjusting the plan, and documenting the intervention; without requiring the month to reach longer historical thresholds that may not reflect the actual intensity required.

This matters because many RPM programs create value through brief, targeted interventions. Consider a patient with heart failure whose weight and symptom trends suggest early fluid retention. A focused review of transmitted data, a short outreach to clarify symptoms and adherence, and a timely plan adjustment can be enough to prevent a decline that would otherwise trigger urgent care or hospitalization. The work is not small; it is time-sensitive. The “first 10 minutes” construct is important precisely because it recognizes that a modest amount of time, applied early and consistently, can protect outcomes.

From a population health perspective, the value of remote monitoring is tied to responsiveness, not to sheer volume of data. In conditions like hypertension, the outcomes signal typically comes from the combination of home readings and clinical follow-up (review plus action) rather than from raw measurement frequency alone. When the reimbursement structure acknowledges shorter management segments, practices can design programs that match the clinical arc: more touch when risk is high, less touch when stability is achieved, and rapid re-escalation when the data indicates drift.

Operationally, the introduction of a shorter management segment changes what “counts” in month-end reality. You should expect more patient-months near the minimum threshold, which makes documentation quality more important, not less. Time capture, the record of what data was reviewed, what clinical action was taken, and how the patient was engaged become the difference between a clean, defensible month and a month that becomes a denial risk or an audit distraction.

How Lara Health supports this: Lara Health is designed so that time capture and patient interaction documentation happen inside the workflow, not as end-of-month cleanup. When staff review trends and take action, Lara Health prompts structured documentation that ties data review to clinical decision-making, captures the patient touchpoint, and produces a month-level summary that billing and compliance teams can rely on without chart archaeology.

CPT 99445: RPM device supply and transmission (2–15 days in a 30-day window)

CPT 99445 is designed to describe RPM device supply and data transmission when physiologic data is recorded and transmitted on 2–15 days within a 30-day period. The clinical implication is straightforward: intermittent monitoring can still be clinically meaningful, and it is often the right design for episodic care, step-down phases, and real-world patient behavior.

The cohort-level need for this is easy to recognize in practice. Some patients benefit from a short burst of monitoring after a medication change, discharge, or clinical event, but do not need daily measurement for a full month. Other patients do need continued oversight, yet daily engagement is unrealistic due to technology barriers, competing responsibilities, or the natural decay of adherence over time. Forcing daily behavior as a prerequisite for device supply reimbursement tends to select for idealized patients rather than for the patients where remote oversight can add the most clinical value.

Operationally, 99445 matters because it changes the device supply logic of RPM from a single intensity assumption to a tiered assumption. In practice, your billing and program rules should clearly distinguish which device supply code applies in a given 30-day period based on the number of days data is recorded and transmitted. This is where monitoring platforms, device vendors, and internal definitions must align: your team needs an unambiguous definition of what constitutes a “day with data,” how that is counted, and how exceptions (missed transmissions, partial days, troubleshooting) are handled.

The interaction with CPT 99454 is particularly important for operations. 99454 remains the device supply and data transmission pathway associated with a higher day threshold within the 30-day period. Taken together, 99445 and 99454 allow practices to design RPM programs with a more realistic cadence: tight monitoring when clinically necessary, intermittent monitoring when clinically appropriate, and a clear month-end determination of which supply code matches what actually occurred. The outcome, if implemented well, is fewer months where staff feel pressured to over-monitor to satisfy billing mechanics, and fewer months where meaningful care occurs but cannot be reliably captured.

Why it matters strategically is that it expands the reachable population for RPM. When reimbursement depends on high-frequency adherence, RPM programs often become “nice for the motivated.” A shorter-day device supply pathway helps practices design RPM programs for real patients, including those in step-down phases and those who benefit from intermittent oversight even if daily behavior is not sustained.

How Lara Health supports this: Lara Health helps practices operationalize device-day logic as a program rule rather than a manual counting exercise. The platform can standardize how a day with data is defined, surface missing transmissions early as a care signal, and generate month-end summaries that support the correct device supply code. That reduces internal ambiguity, lowers rework, and makes the program more reliable across staff and sites.

CPT 98979: RTM intro (10 minutes of treatment management)

CPT 98979 is the RTM analogue to the shorter-threshold “intro” concept in RPM. It is intended to capture calendar months where the care team provides meaningful RTM treatment management in a shorter time segment, paired with the required patient or caregiver engagement when applicable, rather than requiring the month to reach longer thresholds that are not always consistent with how therapeutic monitoring work actually happens.

RTM is often misunderstood as RPM “for therapy,” but the operational distinction matters. RTM is designed to support therapeutic response and adherence monitoring, which may involve non-physiologic data such as symptoms, pain scores, functional status, therapy completion, and response-to-therapy measures. In many RTM pathways, the clinical leverage comes from coaching and adjustment rather than from continuous physiologic measurement: modifying a home exercise plan, reinforcing inhaler technique and adherence, identifying barriers, or escalating when symptoms suggest a complication.

That is why 98979 matters. RTM management time frequently occurs in short, frequent bursts rather than in long monthly blocks. A physical therapist or respiratory clinician may review trends, identify nonadherence or worsening symptoms, and complete a focused outreach that changes the therapeutic plan. In step-down phases, or when the patient starts mid-month, these clinically meaningful months can fall below longer time thresholds despite being exactly the months where RTM does its best work.

Implementation discipline matters more, not less, when the threshold is shorter. Practices should define what counts as RTM management work, how real-time interactive communication is captured when required, how time is tracked, and how that time is separated from other services to prevent double counting. The goal is not to turn clinicians into coders; it is to build a workflow where the care story is captured in a structured, defensible way as it occurs.

How Lara Health supports this: Lara Health unifies trend review, patient touchpoints, care plan adjustments, and time capture into a coherent month-level record. That makes short-threshold RTM months easier to bill consistently and easier to defend, while also improving continuity of care across team members.

CPT 98984 and CPT 98985: RTM devices (2–15 days of data collection in a 30-day period)

CPT 98984 and CPT 98985 describe RTM device supply and data transmission for shorter monitoring windows, 2–15 days in a 30-day period, tailored to respiratory system and musculoskeletal system monitoring. Operationally, these codes recognize something that is obvious in rehabilitation and therapy-driven care: many clinically decisive monitoring intervals are measured in weeks, not months.

RTM often has an episodic shape. After an orthopedic procedure, early weeks may require close monitoring of function, pain, and adherence to an exercise plan. In respiratory therapy pathways, the initial period after an exacerbation or treatment change may be the window where adherence coaching and symptom tracking prevent relapse. In both cases, a short, intensive burst of monitoring can be clinically appropriate, followed by tapering as the patient stabilizes and gains confidence.

These short-period device codes matter because they reduce pressure to force a uniform month-long, high-frequency pattern that patients do not sustain and clinicians do not always need. They make it easier to build RTM pathways that match patient behavior and clinical need: intense when it matters, lighter when appropriate, and re-escalated when signals worsen.

From a workflow standpoint, practices still need explicit logic for which device supply code applies in a given 30-day period. The critical operational work is defining what constitutes a day with data for RTM in your chosen use case, ensuring your platform counts it consistently, and building a response pathway when data is missing. Missing data is not only a billing risk; it is often a care risk that indicates disengagement, barriers, or worsening function.

It also matters how these short-period codes relate to longer monitoring windows. When your program can move patients between short-period and longer-period monitoring appropriately, RTM becomes an operating system rather than a rigid protocol. That flexibility is often the difference between a pilot that works for a narrow population and a program that scales across sites and clinicians.

How Lara Health supports this: Lara Health helps practices enforce device-day logic as a program rule. The system can surface which patients are in short-period versus longer-period device windows, flag missing data days early, and generate month-end summaries that connect data collection to clinical actions taken. That makes RTM less dependent on individual spreadsheets and more reliable across the organization.

HCPCS G0568, G0569, and G0570: APCM behavioral health integration add-on codes

HCPCS codes G0568, G0569, and G0570 are designed as add-on codes to APCM that support behavioral health integration (BHI) and collaborative care-aligned services in connection with monthly primary care management. Their practical promise is that they create a more operationally coherent way for practices to deliver and be reimbursed for behavioral health integration activities when those services are part of the longitudinal care plan.

Behavioral health integration is not a niche service; it is frequently a multiplier for chronic disease outcomes. Depression, anxiety, insomnia, substance use, chronic stress, and social destabilization often show up as the hidden drivers of non-adherence, diet and activity collapse, missed appointments, and avoidable utilization. In real practice, a patient’s medical trajectory often cannot improve without addressing the behavioral constraints that determine whether the plan is followed.

What makes the APCM add-on approach operationally important is that it encourages behavioral health to be implemented as a structured monthly workflow rather than as a referral hope. Practices that succeed in integrated behavioral health typically have a defined cadence: screening and reassessment, proactive outreach, registry-based follow-up, escalation pathways, coordination with specialists, and documentation that connects behavioral interventions to the medical care plan. When those elements are present, integrated care models have demonstrated meaningful improvements in outcomes such as depression severity, anxiety outcomes, and patient satisfaction.

The tiered nature of the add-ons also matters. Behavioral health integration is not one-size-fits-all. Some patients need foundational integration: screening, brief interventions, coordination, and structured follow-up. Others benefit from more intensive collaborative care elements, including systematic measurement-based care and structured case review with psychiatric input. A tiered add-on structure can help practices deliver the right intensity without forcing every patient into the same workflow.

From an implementation standpoint, the highest-leverage principle is linkage. These are add-ons to APCM, which means your documentation needs to connect the behavioral health integration work to the monthly APCM base service in a way that is consistent and defensible. Practices that treat behavioral health add-ons as a separate service line often end up with fragmented notes, duplicated time, and unclear narratives. The safer approach is one integrated monthly story: the patient’s medical plan, the behavioral barriers, the interventions delivered, the follow-up plan, and the coordination that occurred.

How Lara Health supports this: Lara Health is built to connect behavioral health tasks to the same operational infrastructure as longitudinal care management. Screening, follow-up cadence, escalation, coordination tasks, and documentation prompts can live inside one system of action rather than scattered across inboxes, templates, and disconnected tools. When behavioral health integration is operationalized that way, it becomes easier to deliver, easier to supervise, and easier to defend.

A day in the life: what these changes look like inside a real practice

Policy summaries often stop at code changes. The more useful question is how your team’s day changes when you actually lean into these updates and treat remote care as an operating system rather than as a collection of discrete tasks.

In a mature remote care program, mornings begin with triage rather than chart review. A care manager or nurse opens a prioritized queue: patients with deteriorating trends, missed transmissions, symptom flags, therapy nonadherence, or behavioral health indicators that suggest rising risk. The team works that queue with a clear playbook: when to message, when to call, when to escalate to a clinician, and how to document the intervention so it supports both continuity of care and billing integrity.

Midday is where shorter thresholds become meaningful. Ten minutes here and ten minutes there becomes measurable value when the work is captured cleanly and paired with a documented clinical action. Practices that struggle typically struggle because the work is done but not recorded in a coherent, defensible way, and the program becomes dependent on end-of-month reconstruction.

Afternoons are when device-day logic and month-end completeness matter. Which patients are in a short-period device supply window, which are in a longer-period window, which have met real-time communication requirements when applicable, and which need one more clinically appropriate touchpoint to close the month cleanly? The better the system, the less this feels like a scramble and the more it feels like routine management.

This is where Lara Health is designed to stabilize operations. Lara Health’s role is not to create more work; it is to make the work you already do legible, consistent, and aligned to program rules so billing and compliance outputs become a byproduct of care delivery, not an after-hours archaeology exercise.

Implementation strategy: adopt the 2026 changes without chaos

Most practices do not fail because they lack clinical intent. They fail because they deploy remote care programs as broad transformations without first building disciplined operational loops. For 2026, a phased approach is both the safest and the fastest, and it also tends to produce the cleanest billing posture.

Start with one cohort where remote care reliably changes outcomes and reduces staff burden. Post-discharge monitoring, hypertension management, heart failure weight-based monitoring, postoperative musculoskeletal recovery, and pulmonary rehab are common starting points because they have clearer endpoints and measurable signals. Define the monitoring plan, escalation criteria, communication cadence, and documentation standards in one place, and train to that playbook rather than leaving it to individual style.

Then run a structured month-end review for the first sixty to ninety days, with a clinical lead and a billing lead together. The purpose is not to punish mistakes. The purpose is to harden program rules so the team stops debating what counts as a data day, how real-time communication is documented, and how time is attributed. If you skip this step, variation becomes your default, and variation is what makes remote programs unscalable.

After the first cohort is stable, expand deliberately. Add a second cohort only when your first cohort produces predictable outputs: clinically appropriate touchpoints, clean documentation, predictable billing patterns, and low rework. It is better to run a smaller program that is clean and defensible than a large program that generates constant internal uncertainty and compliance risk.

Lara Health supports implementation by turning rules into embedded workflows: eligibility checks, prompts for required elements, standardized documentation, and reporting that makes it obvious where you are complete and where you are exposed.

ROI and financial impact: a defensible way to model the opportunity

Remote care ROI is often discussed too simplistically, as if the code itself is the value. In reality, ROI comes from three sources, and a mature practice models them separately so decisions remain disciplined and the program can be defended internally.

First, reimbursement for work you already do but do not consistently capture. Many practices already perform between-visit care management. If 2026 makes smaller blocks of work more feasible to capture, the economic impact depends on whether you can operationalize documentation and billing with low friction rather than with end-of-month heroics.

Second, avoided deterioration and downstream utilization. Remote care’s clinical value is often that it prevents worsening by catching drift early and intervening promptly. Even modest improvements in adherence, early detection, and escalation can reduce emergency department utilization and hospitalizations in higher-risk cohorts, and can reduce the clinical “fire drills” that consume physician and nurse time.

Third, performance in value-based contracts. Even if a particular patient-month reimbursement is modest, the longitudinal effect on quality measures, total cost of care, and patient experience can be meaningful in accountable care arrangements and other risk-bearing models.

A conservative ROI approach is to pilot one cohort, estimate the number of patient-months likely to qualify under updated thresholds, and then apply a realistic operational leakage factor. Leakage is the percentage of clinically real months that fail to become cleanly billable due to workflow breakdown or documentation gaps. Reducing leakage is often more valuable than marginally increasing enrollment, because it improves predictability and reduces staff burnout caused by rework.

Lara Health’s contribution is reducing leakage. By making program requirements explicit and integrated into workflow, Lara Health helps ensure that the care you deliver becomes the care you can reliably document and bill.

Common pitfalls in 2026 remote care programs, and how to avoid them

The most common pitfall is double counting time across services. Patients may receive multiple forms of between-visit support in the same month, but time should not be counted twice. The safest operational design is to assign work to a service bucket in real time, as the work is performed, rather than trying to allocate time retrospectively.

The second pitfall is ambiguous documentation of real-time interactive communication when required. Shorter thresholds mean more patient-months will sit near minimums, and those are the months where documentation gaps turn into denial risk. A consistent template that ties the interaction to data review and clinical action reduces vulnerability while improving care continuity.

The third pitfall is inconsistent definitions of what qualifies by program. RPM and RTM are not interchangeable, and device and data requirements differ. If staff do not understand the distinction, a program can drift into a gray zone where the care may be clinically appropriate but the billing rationale is hard to defend.

The fourth pitfall is underestimating training. Remote care programs are clinical operations deployments. Training must cover playbooks, escalation pathways, documentation standards, and billing logic, not just how to use the platform.

Lara Health helps by embedding guardrails. Instead of requiring every individual to remember every nuance, Lara Health puts requirements into the system: prompts, structured documentation, and visibility into completion status.

Compliance and audit readiness: making between-visit care defensible

Audit readiness is not about writing defensive notes. It is about making the clinical narrative legible and consistent.

If your remote care program is reviewed, you want to answer a small set of questions quickly and consistently. Why was monitoring medically necessary? What was monitored? What did the data show? What clinical actions were taken because of the data? What patient communication occurred, and when? How was time captured and attributed?

A well-run program makes those answers easy. The record should read like a coherent story of ongoing care, not like a collection of disconnected touches. That is a clinical quality issue as much as it is a billing issue, because clarity drives continuity across staff and reduces the likelihood of miscommunication.

Lara Health supports audit readiness by generating a month-level artifact: a structured summary of monitoring, interactions, clinical decisions, and supporting documentation. That artifact reduces the burden on clinicians while improving consistency for billing and compliance teams.

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If you are translating the 2026 changes into a real operating plan, start by deciding which cohorts you will run under RPM and which under RTM, then harden the program rules that drive month-end clarity: what counts as a day with data, what constitutes management time, how you document required interactions when applicable, and how you prevent time from being counted twice across programs.

Remote care programs succeed when they feel like disciplined clinical operations, not like extra work bolted onto an already overloaded day. The CY 2026 PFS final rule moves reimbursement closer to that reality by supporting shorter, clinically meaningful interventions, more flexible monitoring patterns, and scalable behavioral health integration through APCM.

Ready to strengthen RPM and RTM utilization and make APCM-based care management easier to run and easier to defend? Lara Health’s platform helps practices automate eligibility checks, streamline documentation, capture required interactions, and produce audit-ready month-level summaries, without forcing clinicians to become billing experts. To learn more, book a demo with Lara Health.

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Other articles you might find interesting

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Improving Population Health with CCM

Integrating CCM and RPM for Better Outcomes

The Telehealth Cliff: What Ended, What Survived, and What Smart Practices Are Doing Next

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FAQs

Do these changes matter only for Medicare patients?

While the PFS is Medicare policy, it often influences broader reimbursement patterns across the market. You should still verify commercial payer policies and coverage rules, but Medicare updates frequently shape how remote programs are designed, documented, and audited for all patients.

Do shorter thresholds mean you should monitor everyone more lightly?

Not necessarily. Clinical need should drive monitoring intensity. The benefit of shorter thresholds is that you can match monitoring intensity to clinical reality without being forced into a uniform “daily for a month” design.

Can you run RPM and RTM at the same time?

Some patients may benefit from multiple monitoring modalities, but practices must ensure that service elements and time are not duplicated. A clean program design distinguishes what each program is intended to measure and how the care team uses the data, and it applies clear internal rules for attribution.

Does APCM replace chronic care management?

APCM is designed as an advanced primary care management framework, and for many practices it will become a foundational layer for longitudinal care delivery. The operational priority is preventing duplication and building a single coherent monthly narrative that remains defensible.

What is the most important operational change to make first?

In most practices, the highest-leverage move is to standardize documentation and time capture within workflow. The 2026 environment rewards consistency. It is better to have a smaller program that is clean and defensible than a large program that creates rework and compliance risk.

Sources

CMS fact sheet for the CY 2026 PFS final rule (CMS-1832-F).

CMS Medicare Learning Network (MLN) summary of the CY 2026 PFS final rule (MM14315).

CMS MLN guidance related to 2026 remote monitoring updates, including RTM descriptor updates and related transmittals.