CMS PFS 2026: changes for RPM/RTM + billing checklist

What changed in the 2026 PFS (executive summary)

The 2026 CMS Physician Fee Schedule (PFS) continues a gradual shift from experimental adoption to operational tightening for Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM). CMS did not dismantle the RPM/RTM framework, but it clarified expectations in ways that materially affect who gets paid, for what, and with what documentation. For organizations treating RPM and RTM as scalable revenue lines, 2026 is less about new codes and more about audit readiness and workflow discipline.

At a high level, CMS reinforced three themes. First, RPM and RTM remain reimbursable when they are clinically integrated services, not device programs or vendor-led monitoring in name only. Second, CMS signaled increased scrutiny of time-based billing, particularly around what constitutes qualifying work, interaction, and medical necessity. Third, the agency continued to distinguish RPM and RTM more sharply, limiting creative interpretations that blurred the two.

Several things did not change. CMS did not eliminate RPM/RTM codes, did not meaningfully reduce payment rates, and did not require new technology certifications. However, the agency clarified that enforcement will focus less on whether data exists and more on whether care actually occurred in a way consistent with the intent of the codes.

For 2026, the biggest operational impact is that “paper compliance” is no longer enough. Copy-paste notes, generic monthly summaries, and vendor-generated time logs without clinical context are increasingly risky. CMS commentary accompanying the PFS emphasizes contemporaneous documentation, clear attribution of work to eligible staff, and defensible linkage between data, interaction, and clinical decision-making.

In short, RPM and RTM remain viable, but they are no longer forgiving. Organizations that invest in clean workflows, aligned clinical and billing teams, and conservative interpretations of time and interaction rules will be best positioned to survive audits and sustain reimbursement in 2026.

RPM vs RTM in 2026: what’s reimbursable

Typical clinical scenarios

In 2026, CMS continues to treat RPM and RTM as distinct services with different clinical intents, even though both involve remote data collection and ongoing monitoring. RPM is positioned around physiologic data used in the management of acute or chronic conditions. Typical reimbursable scenarios include hypertension, diabetes, heart failure, and post-acute monitoring where physiologic measurements meaningfully inform clinical decisions.

RTM, by contrast, remains focused on therapeutic data, not raw physiology. CMS examples and commentary emphasize musculoskeletal conditions, respiratory therapy, and medication adherence where the monitored data reflects patient behavior or therapy performance rather than vital signs. RTM is often tied to care plans involving physical therapy, occupational therapy, or respiratory therapy, with data used to adjust or reinforce treatment.

CMS has been clear that substituting one for the other is not acceptable. Using physiologic data to justify RTM, or behavioral data to justify RPM, remains a common source of denial. In 2026, auditors are expected to look closely at whether the type of data collected actually matches the code family billed, rather than accepting high-level descriptions at face value.

Who can provide services (roles / supervision overview)

CMS reaffirmed that physicians and non-physician practitioners (NPPs) may bill RPM and RTM when services are furnished under appropriate supervision. Clinical staff may perform certain monitoring and interactive activities, but billing responsibility remains with the practitioner of record. Supervision requirements continue to be a practical risk area. RPM generally allows general supervision, while RTM supervision depends more heavily on the underlying therapy context and applicable CMS rules. Third-party vendors may support data transmission and administrative tasks, but they cannot independently furnish or bill for RPM/RTM services.

In 2026, CMS commentary places renewed emphasis on clear attribution of work. Notes must identify who performed the service, under what supervision, and how the activity contributed to patient management. Ambiguity around roles, especially in vendor-heavy programs, remains one of the fastest paths to audit exposure.

Core requirements and documentation (what auditors look for)

Patient consent and enrollment

CMS continues to require documented patient consent for both RPM and RTM services, and 2026 guidance reinforces that this is not a one-time, check-the-box exercise. Consent must be obtained before services begin and must clearly indicate that the patient agrees to remote monitoring, understands what data will be collected, and is aware of potential cost-sharing obligations.

Verbal consent remains acceptable, but it must be explicitly documented in the medical record with date, time, and the individual obtaining consent. A common audit failure is generic language copied across charts without patient-specific confirmation. CMS reviewers increasingly expect to see consent tied to initial enrollment and re-addressed when programs materially change (for example, adding RTM after RPM or switching devices).

Enrollment documentation should also establish medical necessity. Notes should explain why RPM or RTM is appropriate for this patient, at this time, for this condition. Standing enrollment without periodic reassessment is a recurring audit vulnerability in long-running programs.

Data capture frequency and device expectations

CMS did not introduce new technical certification requirements in 2026, but it reiterated that RPM and RTM rely on data generated by a qualifying medical device as defined by statute and prior guidance. Auditors focus less on hardware specifications and more on whether the device plausibly supports the clinical use claimed.

For RPM, data must be physiologic and captured with sufficient frequency to inform care. Sparse, irregular, or obviously unused data streams undermine claims of active monitoring. For RTM, data must reflect therapy adherence or performance, not proxy physiologic metrics. A frequent denial trigger is over-reliance on consumer devices or apps without clear justification of how they meet RPM/RTM expectations. Documentation should describe what data is collected, how often it is reviewed, and how it informs patient management.

Time thresholds and interaction requirements (conceptually)

Time-based codes remain the most scrutinized element of RPM and RTM billing. CMS reiterated that only qualifying time counts, specifically, time spent by eligible personnel on monitoring, reviewing data, and engaging in interactive communication that contributes to treatment management. Passive data accumulation does not count. Automated alerts without human review do not count. Time must be active, attributable, and contemporaneously documented. Interactive communication must be meaningful; brief administrative calls or messages without clinical substance are commonly excluded in audits.

In 2026, CMS commentary emphasizes that meeting a numerical time threshold is insufficient if the record does not demonstrate clinical engagement. Auditors increasingly assess whether documented time logically aligns with the volume and complexity of patient data reviewed.

Billing workflow: step-by-step

Intake → setup → monitoring → monthly billing cycle

A defensible RPM/RTM billing program in 2026 follows a repeatable, end-to-end workflow that links clinical activity to billing artifacts. Breaks anywhere in this chain are where audits most often succeed.

The intake phase begins with patient identification and eligibility confirmation. Clinical notes should document why remote monitoring is appropriate, what condition is being addressed, and which code family (RPM vs RTM) applies. Consent is obtained and recorded at this stage, before any device activation. Setup includes device assignment, education, and activation. Documentation should show that the patient received instructions, the device was capable of transmitting required data, and monitoring actually began. Setup codes are frequently denied when activation dates are unclear or when devices never transmit usable data.

The monitoring phase spans the month and is where most billable activity occurs. Clinicians or clinical staff review incoming data, identify trends or issues, and engage in interactive communication as needed. Notes should reflect why interactions occurred and how they influenced care, not just that contact happened.

At month end, billing is triggered only if all requirements are met: qualifying data exists, time thresholds are reached, interactions are documented, and services align with the patient’s care plan. Partial months require careful handling; billing should reflect actual service delivery, not program enrollment.

Coordination between clinical team and billing team

CMS denials often stem from misalignment between clinical reality and billing assumptions. Clinical teams may believe services were provided, while billing teams lack sufficient documentation to support claims.

Effective programs establish clear handoffs: standardized note templates, defined time-tracking practices, and regular reconciliation between monitoring logs and billing reports. Billing staff should not be expected to infer clinical intent from raw data. Conversely, clinicians must understand which details auditors look for and document accordingly.

In 2026, CMS commentary suggests that organizations with integrated clinical-billing workflows, rather than vendor-isolated RPM programs, are better positioned to withstand review.

Denial patterns and how to prevent them

Missing documentation

Incomplete or inconsistent documentation remains the single most common reason for RPM and RTM denials in 2026. Audits frequently identify missing consent records, vague enrollment notes, or monthly summaries that do not clearly tie monitoring activity to clinical decision-making. Another recurring issue is copy-paste documentation: identical language across multiple patients or months undermines credibility and suggests that services may not have been individualized.

Prevention starts with front-loaded discipline. Consent should be clearly documented at enrollment, with patient-specific language. Monthly notes should reference actual data trends, patient interactions, and any resulting care adjustments. Templates are acceptable, but they must prompt customization rather than encourage boilerplate text.

“Insufficient time / interaction” issues

Time-based denials have increased as CMS focuses on whether qualifying time truly occurred. Common problems include counting non-billable activities (device shipping, technical troubleshooting, purely administrative outreach) or aggregating time across staff without clear attribution. Interactive communication is another pressure point. Short check-in calls or messages that do not address data or treatment management are often excluded. To prevent denials, organizations should define what counts as billable interaction, train staff accordingly, and document clinical substance, not just duration. Time logs should be contemporaneous and reconcile with narrative notes.

Device / data questions

Auditors also challenge claims when device use or data quality appears insufficient. Examples include long gaps in transmitted data, reliance on consumer apps without justification, or RTM programs that primarily collect physiologic metrics. CMS expects that data reviewed is relevant, regular, and actually used in patient management.

Prevention requires aligning device choice with code family, monitoring data flow proactively, and documenting how data informs care. If data is missing or unusable for part of the month, billing should be adjusted accordingly rather than assumed.

Billing checklist

Use the checklist below as a pre-submission audit tool for RPM/RTM claims in 2026. It is designed to be copy-pasted into internal SOPs or month-end close workflows.

Eligibility & classification

• Correct program selected (RPM vs RTM) based on data type and clinical use
• Medical necessity documented for the specific condition and time period
• Provider of record identified (physician or eligible NPP)

Consent & enrollment

• Patient consent obtained before services began
• Consent documented with date, method (verbal/written), and staff name
• Enrollment note explains purpose, device, and monitoring plan

Device & data

• Device supports required data type (physiologic for RPM; therapeutic for RTM)
• Data transmitted and reviewed during the billing period
• Data frequency and gaps documented and addressed

Time & interaction

• Qualifying time meets monthly thresholds
• Time attributed to eligible personnel only
• Interactive communications documented with clinical substance
• Non-billable activities excluded from time totals

Monthly documentation

• Note summarizes data trends and clinical interpretation
• Any care plan adjustments or follow-ups recorded
• Partial months handled conservatively and accurately

Billing controls

• Charges reconciled with monitoring logs and notes
• No duplicate billing across RPM/RTM or other services
• Internal review completed prior to claim submission

This checklist reflects CMS’s audit posture in 2026: completeness, attribution, and clinical logic matter as much as code selection.

FAQs

Can we bill RPM and RTM together?

In limited circumstances, yes, but CMS expects clear separation of purpose and documentation. RPM and RTM may be billed for the same patient in the same month only if they address distinct conditions, use different data types (physiologic vs therapeutic), and involve separate clinical work. Double-billing for overlapping activities or repurposing the same data stream for both code families is a common audit trigger. When in doubt, conservative separation, or choosing one pathway, is safer.

What if the patient disengages mid-month?

Partial participation does not automatically prohibit billing, but claims must reflect actual services delivered. If required data transmission, time thresholds, or interactions are not met, billing should be reduced or withheld for that month. CMS scrutiny increases when full monthly codes are billed despite minimal engagement. Documentation should explain disengagement and any follow-up attempts.

How strict is CMS on time thresholds in practice?

CMS remains numerically strict on time thresholds, but audits focus on plausibility as well as arithmetic. Meeting the threshold is necessary but not sufficient; documented time must align with the volume of data reviewed and the complexity of care provided. Inflated or poorly explained time logs are increasingly challenged in 2026.