Medicare Billing Codes for CCM and RPM (2025-2026): A Practical Guide for Practices & Ambulatory Teams
A concise, source-backed guide to CCM/RPM billing essentials, regulatory updates, and operational guardrails for physician practices, RHCs/FQHCs, and hospital-owned ambulatory clinics.
Logic Health Management•
Remote care programs have evolved from pilot projects into core service lines for many Medicare-focused practices and health systems. Yet differences between Chronic Care Management (CCM) and Remote Physiologic Monitoring (RPM) codes, documentation rules, and the next wave of policy changes still create confusion.
This post distills the latest requirements and field lessons so you can build a compliant and financially sustainable CCM/RPM program as an independent practice, RHC/FQHC, or hospital-owned ambulatory organization.
Care Management Readiness Checklist (Free PDF)
Quick-scan checklist to launch or scale compliant CCM, RPM and related services - built for independent primary care clinics, RHCs, and FQHCs.
Core criterion: >= 2 chronic conditions expected to last >= 12 months and pose significant risk
Consent requirement: Verbal consent documented in the record
Typical enrollee share: Often a majority of Medicare panels, depending on patient mix and documentation
Remote Physiologic Monitoring (RPM)
Core criterion: Ordered by a treating practitioner for medically necessary monitoring using a connected device to collect and transmit physiologic data; no minimum number of conditions required
Consent requirement: Patient consent documented in the medical record per current CMS and payer guidance (commonly written/electronic)
Typical enrollee share: Smaller pool; many overlap with CCM cohort, enabling dual billing when rules are met
Key: RPM is usually a subset of your CCM population; CCM often becomes the "base" chronic care service, with RPM layered on top for the right cohorts.
Current CPT Code Sets (CCM & RPM)
Below are the principal codes in use today. National payment varies by locality and annual updates, so always verify dollar amounts with your MAC before generating pro formas.
CCM (Non-Complex)
99490 - first 20 minutes of clinical staff time per calendar month
99439 - each additional 20 minutes (add-on to 99490)
CCM (Complex)
99487 - first 60 minutes of complex CCM per calendar month (moderate/high MDM)
99489 - each additional 30 minutes (add-on to 99487)
These codes assume:
A comprehensive care plan in the record
Non-face-to-face work by clinical staff directed by the billing practitioner
Patient consent documented in the record
Supervision and documentation consistent with current CMS and payer guidance
RPM
99453 - One-time device set-up and patient education (initial episode)
99454 - Device supply and data transmission (16-30 days in a 30-day period)
99445 - Device supply and data transmission (2-15 days in a 30-day period, effective 2026)
99470 - RPM treatment management (10-19 minutes per calendar month; includes interactive communication, effective 2026)
99457 - First 20 minutes of RPM treatment management per calendar month (includes interactive communication)
99458 - Each additional 20 minutes of RPM treatment management (add-on to 99457)
99091 - Legacy physician/QHCP time alternative (>= 30 minutes); less commonly used
2026 RPM Updates to Watch (Confirm in CMS Final Rule)
Recent CY-2026 policy updates signal meaningful shifts in how RPM is billed and operationalized. Key changes include:
New RPM supply tiers: CY-2026 introduces distinct RPM supply billing for 2-15 days vs 16-30 days of device data transmission within a 30-day period.
New shorter management time tier: CY-2026 adds an RPM treatment management code for 10-19 minutes per month, creating a bridge for programs that do not consistently reach the 20-minute threshold.
Rates and final policy details: Always confirm final CY-2026 payment policy and rates with the CMS final rule and MAC guidance.
Action: Work with billing, IT, and any RPM vendors now to ensure time tracking and device-day logic can reliably support both the 2-15 day and 16-30 day supply tiers, plus the updated time-tiered management structure.
Must-Know Billing Rules
Practical Guardrails for Frontline Teams
Consent: Document patient consent per current CMS and payer guidance. CCM consent may be verbal and documented in the record; RPM consent should be documented appropriately (commonly written/electronic).
No double-counting: Time billed under CCM/RPM must be separately tracked and must not overlap with other billed time-based services per CMS and payer rules. Documentation should clearly separate these time streams.
Single-practitioner rule: Only one practitioner should bill CCM (or RPM) for a beneficiary per calendar month; coordinate with subspecialists (e.g., cardiology, pulmonology) and hospital-owned clinics to avoid billing conflicts.
Device-data minimums: 99454 requires 16-30 days of transmitted readings in a 30-day period. 2026 adds a 2-15 day tier, so device-day logic and documentation should support both ranges.
Clinical staff vs physician time:
CCM minutes are often delivered by clinical staff under general supervision, consistent with program requirements and organizational policy
RPM interactive minutes can be staff-delivered under provider oversight, with documented interactive communication and a clear treatment plan.
Reimbursement & Regulatory Momentum
Field experience and recent policy developments reveal several important patterns:
CCM often outperforms RPM in scale: Practices launching CCM programs often find panel sizes and clinical impact exceeding RPM, despite initial expectations that RPM would dominate. The larger eligible population and lower operational barriers make CCM the faster path to recurring revenue.
Operational complexity varies: RPM carries more logistical complexity (devices, shipping, adherence coaching) than CCM, which is largely documentation-driven within the EMR. Industry experts note that successful RPM programs require dedicated coordination and clear device-management workflows.
Policy refinement continues: CY-2026 updates expand flexibility in RPM billing, including distinct supply tiers for 2-15 days vs 16-30 days of device data transmission and a shorter treatment-management time tier to better match real-world workflows. Practices should confirm their technology can track device-days, interactive communication, and time documentation cleanly across these tiers.
Operational Considerations
Device logistics & patient engagement
Device logistics matter more than most teams expect. Vendors that manage shipping, connectivity, and tech support can reduce staff burden, but parameters must be set thoughtfully. Overly broad thresholds can bury teams in non-actionable signals, drive alert fatigue, and diminish program value.
Documentation hygiene (CCM)
CCM denials often trace back to incomplete documentation of qualifying chronic conditions and care plan continuity. Practices should ensure:
Diagnoses are refreshed during annual wellness or problem-focused visits
Care plans reference current conditions, not outdated problem lists
Staffing models
Operationally successful programs typically follow these patterns:
CCM: RNs or LPNs conduct monthly outreach and care-plan updates, escalating issues to APPs or physicians as needed. Many organizations find CCM is the easier program to launch and scale from a staffing perspective.
RPM: A dedicated coordinator often triages abnormal biometric alerts before engaging the clinician. This filtering layer is critical to prevent alert fatigue.
Action Plan for 2025-2026
Based on field experience and regulatory momentum, consider this roadmap:
Start (or scale) CCM first. Lower operational barriers and a large eligible population make CCM one of the fastest ways to build recurring revenue.
Layer RPM for higher-risk subsets. Hypertension, CHF, and COPD are common starting points where monitoring can be clinically meaningful and operationally scalable.
Audit your time and device-day tracking now. Ensure workflows can support accurate documentation for RPM supply tiers (2-15 days vs 16-30 days) and treatment-management time tracking (including the new 10-19 minute tier in 2026).
Monitor CMS fee schedule updates. Incorporate final national and locality-specific rates into budgets and pro formas once published.
Engage payers beyond Medicare. Commercial plans often mirror CMS policy; early CCM/RPM success can support payer contracting and MA/ACO negotiations.
How LOGIC Helps Practices, RHCs/FQHCs, and Health Systems Navigate This
LOGIC runs CCM, RPM, and related programs as a centralized care-management service inside your EMR, under provider oversight, with audit-ready documentation.
In practical terms, that means:
Designing EMR-native templates for CCM/RPM time tracking, consent, care plans, and supervision
Running day-to-day outreach and monitoring using shared nurses and navigators, not asking your clinics to "just do more work"
Keeping time streams separate so CCM, RPM, and other time-based services do not collide
Respecting one-practitioner-per-month realities and making attribution visible
Building EMR-driven lists for enrollment by payer, risk, and cohort (e.g., HTN/DM/COPD, post-discharge, SNF)
Producing CFO- and compliance-ready logs and audit-ready evidence packs
Mapping CCM/RPM billing flows to your specific MAC rules, RHC/FQHC status, and small-hospital environment
Bottom Line
CCM and RPM programs work when billing, documentation, and clinical workflows are designed as one system. Practices that execute them reliably can expand access to continuous chronic-disease support while building financially sustainable care models.
Sources & Notes
This overview draws on recent CMS Physician Fee Schedule rulemaking (including the 2026 proposed and final rules from Pershing Yoakley & Associates and Stephens Inc.), expert perspectives from health IT and RPM vendor leaders (Athenahealth, Optimize Health, Innovaccer, HealthSnap), home health payment data from Premier Inc., and industry analyses from the Consumer Technology Association and other stakeholders.
It is general information for operational leaders, not legal or coding advice. Always confirm current requirements, coverage, and payment rates with your own billing and compliance teams, your Medicare Administrative Contractor (MAC), and the latest CMS publications before making decisions.
