4 key takeaways from the 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule ​

By Juli Eschenbach, Custom Solutions Manager and Clinical SME

The Centers for Medicare & Medicaid Services (CMS) recently released the 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule. While there are many key takeaways, there’s one notable conclusion: CMS is committed to remote care models. The proposed changes for remote patient monitoring (RPM) are significant and expand what’s covered under RPM.

In addition to new proposed RPM codes, there are updates regarding Advanced Primary Care Management (APCM), Behavioral Health Integration (BHI), and Federally Qualified Health Health Center (FQHC) billing — with an emphasis on integrating BHI more heavily into the other care management spaces.

Here is a brief overview of proposed changes for 2026:

Remote Patient Monitoring (RPM) updates:

CMS has proposed the addition of two new codes:

1. The addition of 99XX4 to cover two to 15 days of readings in a 30-day period from a connected device. This new code is a long-awaited change to the current “hard rule” of 16 days of readings in a 30-day period.
2. The addition of 99XX5 to cover 10 to 20 minutes of clinical staff time as a billable threshold. This is an additional code option to be able to bill for time over the currently allowed 20 minutes or more code (99457).

CMS has also proposed updates to code 99454 to cover 16 to 30 days of readings in a 30-day period.

What does this mean? CMS is emphasizing the importance of physiologic data and the value of remote care time spent to patient care and indicates it aims to protect reimbursements in this area.  It is important to note that CMS continues to use the language of “practice-dispensed devices” – meaning “patient-bought” devices still do not qualify for RPM reimbursements.

CMS also clarified that they see RPM as a “longitudinal service” that should continue as long as it is medically necessary. The agency requests stakeholder input on data regarding frequency of device use to cost savings and clinical improvement considering proposed payment reductions for 99454.

Advanced Primary Care Management (APCM) Updates

CMS has proposed introducing an add-on code to APCM that allows providers to bill for service for BHI. These APCM add-ons are for BHI services that do not document time, but are provided by interdisciplinary teams.  If finalized, codes GPCM1, GPCM2, GPCM3, would be equivalent to the BHI/CoCM code set, but not require tracking of time.

In the APCM space, CMS is soliciting feedback from stakeholders on several areas such as the inclusion of preventative services; how cost-sharing should be handled if preventative services are bundled into APCM; and what other services or additional coding should be considered for APCM.

Remote Therapeutic Monitoring (RTM) Updates:

CMS has proposed the addition of two new codes:

1. The addition of 99XX7 to cover 10 to 20 minutes of clinical staff time as a billable threshold. This is an additional code option to be able to bill for time over the currently allowed 20 minutes or more code (99457).
2. The addition of 99XX4 and 98XX5 to cover two to 15 days of readings in a 30-day period from a connected device for either musculoskeletal system status or respiratory system status respectively. This new code is a long-awaited change to the current “hard rule” of 16 days of readings in a 30-day period.

What does this indicate? In the same vein as its RPM proposals, CMS is underscoring its belief in the value of remote therapeutic care time spent and non-physiologic patient data.  RTM is a newer section of the remote patient monitoring arena and CMS is requesting stakeholder data on cost-saving and clinical outcomes that providers have experienced with these codes.

Federally Qualified Health Center (FQHC) and Rural Health Center (RHC) Updates:

CMS is proposing that FQHC/RHC code G0512 be unbundled, as was the case in 2025 on G0511 conversion to the PFS equivalent codes. FQHC/RHCs would also qualify for add-on codes proposed for BHI services under the APCM umbrella.

What’s next?

The open feedback period for public comments to CMS for all 2026 proposals will continue through September 12. The final ruling by CMS is expected mid-November; only the proposals that make it to the final rule will be instituted.