RPM billing in 2026: 99445, 99470 and the 16-day rule

RPM billing in 2026 runs on two clocks. Device supply bills per 30-day period: 99454 for 16 to 30 days of data, and 99445, new for 2026, for 2 to 15. Treatment management bills per calendar month: 99470, new, for the first 10 minutes, or 99457 for the first 20, with 99458 for each additional 20. Every management code needs a live, two-way conversation with the patient.

This page summarizes public CMS rules for Original Medicare, Part B, for dates of service in 2026. It is not billing or legal advice. Medicare Advantage plans can set their own rules. Have your coder or compliance counsel confirm anything a claim depends on.

What changed for 2026

• 99445 is new. It pays for device supply when the device transmitted on 2 to 15 days of a 30-day period. Before 2026, a patient with 12 days produced no billable device month.
• 99470 is new. It pays for the first 10 minutes of treatment management in a calendar month, with the same live-communication requirement as 99457.
• 99453 now needs 2 days, not 16. CMS adopted the 2026 CPT change: set-up and education is reportable once the patient has 2 days of monitoring in a 30-day period.
• CMS restated that RPM is not telehealth. RPM, RTM and digital mental health treatment are non-face-to-face services outside section 1834(m). Telehealth place-of-service codes 02 and 10 do not apply.

The RPM codes for 2026

Payment figures are approximate national non-facility amounts from CMS's 2026 relative value file, before sequestration, the patient's 20% coinsurance and your locality's adjustment. The full RPM, RTM, CCM, PCM and APCM table is on the 2026 code guide.

The 16-day rule, and the 2-day floor

16 or more days of data bills 99454. 2 to 15 bills 99445. Fewer than 2 bills no device code. CMS calls the two device codes "not additive": one of them per patient per 30-day period, never both, and never one per device. A patient with a cuff and a scale is billed once.

A data day is a day the device sent a reading on its own. CMS requires the data to be collected electronically and uploaded automatically to a secure location the billing practitioner can review. A reading the patient types into a portal, or reads out on the phone, is not RPM data and does not count.

The device must meet the FDA's definition of a medical device. CMS found nothing in the CPT language requiring FDA clearance, though it noted clearance may be appropriate.

The day thresholds stop at the device codes. 99457, 99458 and 99470 carry no data-day requirement. A month with 9 days of readings can still carry a management code if the time and the live conversation are there.

99470 or 99457: choosing the management code

CMS says the 10-minute and 20-minute codes are also "not additive." Pick the one that fits the month.

99458 follows 99457 only. A month billed with 99470 never carries 99458.

Time is cumulative across the clinical staff and the billing practitioner, and each minute counts once. Minutes counted toward an E/M visit, CCM, PCM, TCM or BHI cannot also count toward RPM.

Interactive communication: what counts

CMS defined it in its 2021 rule: at a minimum, "a real-time synchronous, two-way audio interaction" with the patient or caregiver, which video or data can enhance. A phone call meets it.

A text message does not. It is neither real-time nor audio. When commenters asked CMS in 2025 to count secure messaging, asynchronous chat, automated two-way messaging and AI prompts, CMS answered by adopting the CPT language: the codes "require a live, interactive communication with the patient/caregiver."

The live conversation counts toward the month's total time. It does not have to be all of it.

Two clocks: the 30-day period and the calendar month

The device codes and 99453 run on a 30-day period. The management codes run on the calendar month. Commenters asked CMS to align them for 2026, and the final rule left them as they are. Track both, separately, for every patient.

Who can bill, and on what conditions

• The practice bills. Only physicians and non-physician practitioners who can bill E/M services can bill RPM. It is not a diagnostic test, so an independent diagnostic testing facility cannot bill it. A software vendor does not bill it either.
• Staff can do the work. RPM is a designated care management service. Auxiliary personnel can furnish it under the billing practitioner's general supervision.
• Established patients only. RPM requires an established patient relationship. RTM does not.
• An acute or chronic condition. RPM must monitor one.
• Consent. CMS requires the patient's consent at the time RPM is furnished.
• One practitioner per 30 days. Only one practitioner can bill remote monitoring for a patient in a 30-day period.
• RPM or RTM, not both. The same patient cannot be billed for both.
• Global surgery. RPM during a global period is billable only for a condition unrelated to the procedure.

RPM with CCM, PCM, APCM and TCM

CMS states the RPM and care-management rule plainly: either monitoring family, but not both, can be billed alongside CCM, TCM, BHI, PCM and chronic pain management "if you don't count time and effort twice." Practices running RPM and CCM together need time logged per program as it is spent, not split at month end.

Documentation an auditor looks for

The HHS Office of Inspector General reported in September 2024 that about 43 percent of Medicare enrollees who received RPM did not receive all three components (set-up, device supply and treatment management), and that 12 percent never received treatment management at all. It also found claims that did not say what was being monitored: more than 7,000 enrollees were billed under a diagnosis of "other specified counseling." Medicare does not explicitly require RPM to be ordered, and for about 44 percent of enrollees it had no information about who ordered it. Those findings tell you where review starts.

Keep, for every patient and every period:

1. The established relationship. A visit with the practice before RPM began.
2. Consent. The date, who obtained it, and the patient's decision.
3. A specific diagnosis. The acute or chronic condition being monitored, not a generic counseling code.
4. The device. What it is, and that it meets the FDA medical-device definition.
5. The data days. Each automatically transmitted reading with its timestamp, device and patient, and the count of distinct days in the 30-day period.
6. The time. Per patient, per calendar month: who did the work, their credential, the date, the minutes and the activity.
7. The live conversation. Date, phone or video, who took part, how long, and what was discussed.
8. What the data changed. Reviews, decisions and care-plan changes. Monitoring that nobody acts on is the pattern OIG flagged.

Keep it for at least 7 years. Medicare's enrollment rules set 7 years from the date of service for the documentation they cover, and your state's medical-record rule may run longer.

What may change in 2027

CMS's CY2027 proposed rule, published 16 July 2026, would change RPM from 1 January 2027 if finalized:

• Only clinical staff directly employed by the practitioner or practice could count RPM and RTM time. Contracted staff time would not count.
• A separately reportable initiating visit would be required at the start of RPM or RTM.
• RTM would be limited to established patients.

None of this is final. This page will be updated when the CY2027 final rule publishes.

Where Caesar Health fits

Caesar runs the work around the billable minutes: patient texts, staff tasks, the reading-day count against 16, a nightly check for patients slipping below 16 or toward the 2-day floor, and a day-20 check that a live call has happened. How Caesar runs RPM alerting shows the rules and the timeline.

The practice bills, under its own provider numbers. Caesar's activity is not billable time: the management codes pay for clinical staff and practitioner minutes, and the live conversation is a person on the phone.