Making Sense of CMS’s 2026 Proposed Rule: Q&A on Remote Care Impacts
CMS recently released its proposed 2026 Medicare Physician Fee Schedule (PFS), introducing several important updates that could reshape how providers deliver and bill for remote care. From new RPM and RTM codes to expanded care management options and permanent virtual supervision, these changes have direct implications for practices, health systems, ACOs, and rural providers.
In this practical Q&A, we break down what’s in the proposal, why it matters, and how organizations can prepare ahead of the final rule expected in November 2025.
Q: What’s the headline for remote care?
A: CMS is signaling that remote care is here to stay—and that it must become more flexible. The proposed 2026 PFS would:
- Add new RPM/RTM codes for shorter durations (e.g., 2–15 days of device data in a 30-day period) and shorter management time (first ~10 minutes)
- Make virtual direct supervision permanent (via real-time audio/video) for services that require direct supervision
- Streamline the Medicare Telehealth List process and remove several telehealth frequency limits.
- Raise the conversion factor modestly (+3.8% for clinicians who participate enough in an Advanced Alternative Payment Model to earn the Qualifying Participant (QP) status, and +3.3% for non-QPs).
Q: What exactly changes for RPM and RTM?
A: The proposal accepts new CPT codes (placeholder numbers in the draft) that:
- Allow billing for 2–15 days of RPM/RTM device data within a 30-day period (filling the gap below today’s 16-day requirement).
- Create a first 10-minute treatment-management code for RPM (and a parallel 10-minute code for RTM), capturing work that falls short of 20 minutes.
Q: What’s changing for care management (CCM, PCM, APCM)?
A: CMS proposes APCM add-on codes to pair behavioral health integration (BHI/CoCM) with APCM in the same month—without duplicative documentation. This aligns with the reality of primary care: chronic disease is often inseparable from mental health.
Q: What’s the impact on RHCs and FQHCs?
A: Two big things:
- CMS continues the shift away from catch-all G0511 (already underway in 2025) toward reporting individual care-management codes and proposes to adopt APCM-related add-ons for RHCs/FQHCs.
- For telehealth, CMS proposes extending G2025 distant-site billing through 12/31/2026 and making virtual direct supervision permanent in these settings.
Q: Who benefits most—and how should organizations respond?
Independent practices (primary care and specialty): New shorter codes mean you can bill for the care you’re already providing but couldn’t capture under the 16-day/20-minute thresholds.
Health systems/IDNs: APCM add-ons expand integrated care revenue; permanent virtual supervision eases scale.
ACOs & APMs: Higher QP conversion factors reinforce investment in remote care to hit quality and cost benchmarks.
RHCs/FQHCs: Code-level reporting clarifies reimbursement while extending telehealth coverage through 2026.
Virtual-first vendors & platforms: Expanded code set opens new markets—short-course monitoring, episodic care, titration.
Q: Will rates actually go up?
A: For most organizations, yes. Conversion factors rise modestly. Care-management and telehealth time-based codes are shielded from CMS’s new “efficiency adjustment,” though technical device codes may face downward pressure. Modeling both sides is essential.
Q: What should we do between now and the Final Rule?
- If you have data (outcomes, access, equity) on short-course monitoring, SaaS reimbursement, behavioral integration, submit comments—CMS asked.
- Redesign your remote care playbook. Add new RPM/RTM pathways, define billing guardrails across CCM, PCM, APCM, and BHI.
- Train teams on virtual direct supervision: Lock in workflows that leverage this flexibility safely and compliantly.
- Ready your revenue cycle. If you’re not working with an experienced partner, map new codes, modifiers, and documentation (especially the interactive communication element). Build edits to avoid double billing and to reflect code-specific monthly limits.
- For RHCs/FQHCs: Finish the G0511 → individual-code transition, adopt APCM add-ons as appropriate, and keep G2025 telehealth workflows current through 2026.
Q: Where does MD Revolution, a CoachCare company, stand?
A. We welcome CMS’s recognition that remote care must be practical, flexible, and equitable. For years, providers have struggled with “all-or-nothing” thresholds—16 days, 20 minutes—that excluded meaningful care episodes. These proposals finally reflect clinical reality.
But advocacy remains critical. As CMS ties reimbursement to OPPS data and efficiency adjustments, we must ensure rates don’t erode in ways that deter adoption—especially in rural and underserved settings. MD Revolution is committed to advocating for sustainable reimbursement and equitable access, so that every provider, from large health systems to small practices and RHCs, can deliver the remote care patients deserve.
Bottom line
If finalized, the 2026 CMS rule would normalize “right-sized” remote care by enabling reimbursement for shorter monitoring periods, briefer management time, and virtual supervision under streamlined telehealth rules. For organizations already delivering remote care, this means new opportunities to capture revenue with stronger compliance. For those not yet engaged, it creates a lower-friction pathway to launch programs and align with value-based care models.
