In 2026, Medicare introduced the most flexible billing rules it has offered for remote patient monitoring. As the year is about to end, CMS has proposed new 2027 rules that would change who can deliver RPM, which codes practices bill, and how much Medicare pays for the service.
So, which RPM CPT codes can a practice still rely on, and what will its program need to look like on January 1, 2027?
This guide answers both, from the device supply and management time codes practices bill today to the CY 2027 Physician Fee Schedule proposals that could redefine RPM staffing and reimbursement.
RPM Rules From 2026 to 2027
What Are the RPM CPT Codes for 2026?
Medicare currently pays for remote patient monitoring through six RPM CPT codes. They fall into three groups: setup and education, device supply, and treatment management time.
CPT 99453, CPT 99454, CPT 99457, and CPT 99458 are still in place from earlier years, joined this year by CPT 99445 and CPT 99470. All six appear among the current RPM codes in the CY 2027 Physician Fee Schedule proposed rule.
Setup Device supply Management time
| Code | What It Covers | 2026 Requirement | Billing Period |
|---|---|---|---|
| 99453 | Device setup and patient education | At least 2 days of monitoring data | Once per episode of care |
| 99454 | Device supply and data transmission | 16 to 30 days of data | Each 30 days |
| 99445New | Device supply and data transmission | 2 to 15 days of data | Each 30 days |
| 99457 | Treatment management, first 20 minutes | 20 minutes, one real-time interaction | Calendar month |
| 99470New | Treatment management, first 10 minutes | 10 to 19 minutes, one real-time interaction | Calendar month |
| 99458 | Each additional 20 minutes of management | Add-on to 99457 | Calendar month |
The device setup code also changed this year. CPT 99453 now needs only two days of monitoring data, where it previously followed the 16-day rule.
RPM still applies only to established patients, and every management code requires at least one real-time interactive communication. Payment varies by locality, so current rates are best confirmed in the CMS Physician Fee Schedule Look-Up Tool.
CPT 99445 and CPT 99470 Lower the Billing Thresholds
Before 2026, a patient who transmitted readings on 15 days earned the practice no device supply payment. A month with 18 minutes of documented management time went unpaid as well.
However, since January 1, 2026, CPT 99445 has covered device supply when a patient transmits data on 2 to 15 days in a 30-day period. CPT 99470 has covered the first 10 to 19 minutes of treatment management in a calendar month.
Each new RPM CPT code works as an alternative to an existing one. CPT 99445 and CPT 99454 can’t be billed for the same 30-day period, and CPT 99470 and CPT 99457 can’t be billed in the same month.
Practices benefit most from these codes when managing patients who need lighter monitoring, such as post-discharge follow-up, medication titration, and stable chronic conditions. Those patients rarely transmit 16 days of readings, so practices couldn’t bill their device supply before 2026.
Four RPM Changes CMS Is Considering for 2027
The CY 2027 Medicare Physician Fee Schedule proposed rule, CMS-1848-P, includes three RPM proposals and a request for comments on a fourth change. Public comments closed September 14, 2026, and the proposed effective date is January 1, 2027.
CMS links the proposal to OIG findings that about 43% of Medicare enrollees who received RPM didn’t receive all three components of the service.
Below are the four RPM changes in the proposed rule. The first three would take effect on January 1, 2027, if finalized, and the fourth is a request for comments:
Proposed Direct-employment staffing Medicare would pay for RPM only when the clinical staff furnishing it are direct employees of the billing practice. Show what it means ▾
In plain termsMedicare would stop paying for monitoring done by staff a practice contracts through an outside company.
Proposed An initiating visit A separately billable visit, in person or by telehealth, would need to start each patient’s monitoring, with RPM explicitly discussed. Show what it means ▾
In plain termsEach patient would need a visit that covers RPM before monitoring begins, and the practice would bill that visit as its own service. See what happens after enrollment.
Proposed Lower valuations CMS would reduce the practice expense values tied to devices and setup, citing limited pricing data for monitoring equipment. Show what it means ▾
In plain termsMedicare would pay practices less for the device and setup portion of RPM.
Comment request Code consolidation CMS asked for comments on replacing the current code set with two RPM G‑codes. Show what it means ▾
In plain termsIf CMS adopts this option, practices would bill one setup code and one monthly code instead of separate setup, device, and time codes.
None of these provisions is final. The 2027 Medicare Physician Fee Schedule final rule may adopt, revise, or drop each one.
Proposed G-Codes Could Replace the Current RPM Code Set
Under the consolidation option in the proposed rule, GRPM1 would cover one-time setup and patient education. GRPM2 would become a single monthly bundle for device supply, data transmission, and treatment management.
To bill GRPM2, a practice would need at least two days of transmitted data and at least 20 minutes of management time in the month. That time would include at least one real-time interaction with the patient or caregiver.
Under GRPM2, practices could no longer bill the lighter-touch months they can bill under the 2026 codes. A patient who needs 12 minutes of management in a month would fall below the GRPM2 minimum, even though practices can bill that month under CPT 99470 today.
Which Codes Can a Practice Bill This Month?
| Sample month | Before 2026 | 2026 codes | Proposed GRPM2 |
|---|---|---|---|
| Post-discharge: 8 days, 12 min | Not billable | 9944599470 | Not billable |
| Steady month: 24 days, 25 min | 9945499457 | 9945499457 | GRPM2 |
| Readings, little contact: 20 days, 6 min | 99454 | 99454 | Not billable |
| Missed readings: 1 day, 30 min | 99457 | 99457 | Not billable |
Based on the 2026 CPT thresholds and the GRPM2 option described in the CY 2027 proposed rule. Assumes an established patient and at least one real-time interaction in the month, and leaves out the one-time setup code.
Today, device days and management minutes are billed under separate codes, so a practice that misses one threshold in a month can still bill for the other.
GRPM2 would combine the RPM billing requirements into one test: a practice that falls short on either data days or minutes wouldn’t be able to bill for that month at all.
The Staffing Proposal Would Change Who Can Deliver RPM
The staffing provision would end Medicare payment for RPM furnished by contracted clinical staff. Monitoring staff would need to be direct employees of the billing practice, working under the general supervision that incident-to rules already require.
| Who furnishes monitoring | 2026 Medicare rules | 2027, as proposed |
|---|---|---|
| Practice-employed staff | ✓Payable | ✓Payable |
| Contracted staff | ✓Payable under general supervision | ✕Not payable as proposed |
Applies to Medicare Part B claims. Commercial insurers set their own RPM policies.
The requirement has defined limits. As proposed, CMS would enforce it only on Medicare Part B claims from January 1, 2027, and commercial insurers set their own RPM policies. CMS may also revise or drop it after reviewing public comments.
Practices that rely on outsourced RPM will need to review how their partner’s clinical team is employed and supervised under the new RPM staffing rules.
Preparing an RPM Program for January 2027
Practices can prepare now by reviewing three areas of their RPM program, each tied to one of the proposed changes. With that review complete, a practice can adjust quickly once CMS publishes the final rule.
- 1 Patient roster. RPM patients without a documented visit that discussed monitoring may need an initiating visit under the proposal.
- 2 Claims history. Months billed under CPT 99470 show how much remote patient monitoring billing depends on lighter-touch management that GRPM2 wouldn’t cover.
- 3 Staffing records. Employment status and supervision records for everyone who handles RPM data would become central to compliance.
The final rule may soften or remove any of these provisions, and practices that already know where their program stands will spend January adjusting instead of investigating.
FAQs
Is the 2027 RPM rule final? +
No. As of November 2026, CMS hasn’t published the CY 2027 Physician Fee Schedule final rule. The proposed effective date for its RPM provisions is January 1, 2027.
Can CPT 99445 and CPT 99454 be billed in the same month? +
No. Both codes cover device supply for the same 30-day period. A practice reports CPT 99445 for 2 to 15 days of data, or CPT 99454 for 16 to 30 days.
Do commercial payers cover CPT 99445 and CPT 99470? +
Coverage depends on each insurer. Commercial insurers set their own policies for RPM CPT codes, so practices verify coverage with each insurer before billing the new codes.
Will current RPM patients need a new initiating visit in 2027? +
The proposal would require an initiating visit at the onset of RPM services. CMS hasn’t confirmed how that requirement would apply to patients already enrolled, so the final rule text will settle the question.
Plan Your 2027 RPM Strategy With TrueBlueMD
Few practices want to spend December rebuilding their RPM workflows. If CMS finalizes these proposals, that rebuild will include initiating visits, staffing reviews, and new documentation for every claim, all within a few weeks.
TrueBlueMD takes on the parts of that work that slow practices down. We manage patient identification and enrollment, so your team can schedule initiating visits inside a workflow it already uses. We also help your billing staff code and audit every claim, whether Medicare keeps today’s RPM CPT codes or moves to G-codes.
We’ve kept practices’ RPM and CCM programs compliant for 10 years, through every fee schedule CMS has released in that time. Today, we serve 75,000 patients every month.
Book a call with the TrueBlueMD team, and we’ll review your RPM program against the 2027 proposals before January 1.
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