RPM Manual
The practical 2026 guide to device rules, day thresholds, management time, and audit defensibility for Remote Patient Monitoring.
Read the RPM Guide →2026 Revenue & Compliance Survival Guide: APCM + Behavioral Health + RPM/RTM
CMS finalized APCM monthly bundles, optional behavioral-health add-ons, and modernized RPM/RTM payment. This guide shows exactly what can run in the same month, what evidence is required, and where revenue leaks occur--so you can ship compliant claims on day one.
Citations to CMS fact sheets, Federal Register, MLN.
The few facts that move your revenue in 2026
- APCM remains the monthly base. You select one of G0556/G0557/G0558 each month when APCM requirements are met (consent/initiating-visit logic, 24/7 access & continuity, comprehensive care plan, population-management). This is longitudinal--not minute-tracked. [1]
- Behavioral-health add-ons are now real. CMS finalized three optional APCM add-on G-codes billed in the same month by the same practitioner who reports the APCM base code; they’re directly comparable to CoCM/BHI. Final numbers: G0568, G0569, G0570. [2]
- RPM/RTM flexibility expands. For 2026, CMS adopts new/revised CPT for remote monitoring: codes that recognize 2–15 days of device data in a 30-day period and 10-minute treatment-management increments (alongside the existing 16+-day and 20+-minute families). Use the exact CPT that matches your evidence.
- Efficiency adjustment hits non-time-based services. CMS finalized a –2.5% efficiency adjustment to work RVUs and intraservice time for non-time-based services; exemptions include time-based services and those on the Medicare Telehealth List (CMS posted an exempt-code list). [2, 4]
- Virtual direct supervision is permanent (where applicable). CMS finalized a definition allowing real-time audio-video for direct supervision; audio-only is excluded. [2]
- RHC/FQHC adoption. CMS adopts APCM BH add-ons for RHCs/FQHCs delivering advanced primary care and updates component reporting (e.g., G0512/G0071 unbundling to the underlying codes beginning 2026). [2]
What you can bill together (and when)
APCM + BH add-on (same month, same practitioner)
Allowed when the same practitioner reports the APCM base code and the BH add-on for the same patient in that month, with documentation demonstrating CoCM/BHI-comparable activities tied to the APCM month. [2]
APCM + RPM or RTM (parallel modules)
Generally allowed when each service independently meets eligibility and documentation, and the work is not double-counted. Keep APCM artifacts (care-plan, continuity, coordination) separate from RPM/RTM logs/time. [2]
RPM guardrails remain unless superseded by MLN updates
As of the current MLN: one RPM practitioner per patient per 30 days, and you can’t bill RPM and RTM together. The historic 16-day device rule still appears in MLN for 30-day codes; for 2026 use the new 2–15-day CPT when applicable and documented. [3]
Where denials and overpayments happen
- Missing the “same practitioner” rule on BH add-ons. BH add-on attached to APCM but billed by a different practitioner or without an APCM base code that month. [2]
- Double-counting clinical work. Using APCM monthly care-coordination activities to support RPM/RTM management time, or vice versa. CMS expects distinct documentation streams. [2]
- Wrong remote-monitoring code selection. Claiming a 16+-day code with only 2–15 days of transmissions, or claiming a 20-minute management code with only ~10 minutes documented. The 2026 short-window/time codes exist to be used precisely.
- Efficiency adjustment misreads. Failing to recognize that the –2.5% adjustment doesn’t apply to time-based services and telehealth-list services, leading to incorrect revenue projections. [2,4]
Pre-claim checklist (month-end)
- APCM base present? G0556/7/8 selected with all APCM requirements satisfied (consent/initiating-visit logic; 24/7 access & continuity; comprehensive care plan updated). [1]
- BH add-on (if used): Same practitioner as APCM; documentation shows CoCM/BHI-comparable activities; code selection among G0568/69/70 justified. [2]
- RPM/RTM (if used): Medical necessity explicit; correct days-of-data bucket (2–15 vs 16–30) and management time bucket (10–19 vs 20+); single RPM practitioner per 30 days; no RPM+RTM pairing.
- Supervision: For services needing direct supervision, confirm real-time audio-video supervision is documented (no audio-only). [2]
- Efficiency adjustment awareness: Confirm whether billed codes are exempt; align revenue forecast accordingly. [2,4]
Documentation & evidence map (keep streams separate)
APCM monthly note
Problems/goals, meds reconciliation, transitions, continuity & access attestations, population-management actions, and APCM code selection rationale. [1]
BH add-on payload (inside APCM month)
Screenings (PHQ-9/GAD-7/others), care-manager notes, case review cadence, outcomes tracking; clearly tied to the APCM month and practitioner. [2]
RPM/RTM evidence pack (parallel)
Device assignment and 2–15 vs 16–30 day counts; patient contacts and clinical actions; 10–19 vs 20+ minutes time logs; escalation pathways.
Cash-flow & risk: what to model before January 1
- Throttles on revenue: the –2.5% efficiency adjustment for non-time-based services, plus any MAC edits you encounter on short-window RPM/RTM codes. Build two P&L views (with and without exemptions). [2,4]
- Continuity-weighted forecasting: multiply per-patient expected value by a continuity factor reflecting streak length, device adherence, timely follow-ups, and touchpoint cadence--strictly for planning and incentives, not for eligibility or coding.
- RHC/FQHC impacts: APCM BH add-on adoption + unbundling of composite codes (e.g., G0512/G0071) changes mechanics; coordinate with finance on CTBS/remote evaluation reporting changes. [2]
First 30 days: concrete actions
- Stand up a pre-claim validator: BH add-on requires APCM base same month/same practitioner; RPM/RTM day/time thresholds met; single RPM practitioner rule enforced; supervision checks in place. [2,3]
- Refresh templates: APCM monthly note + embedded BH checklist; RPM/RTM log templates with explicit day/time buckets that map to 2026 CPT.
- Train clinicians and billers on distinct-work doctrine and new short-window/time codes for remote monitoring; update SOPs with examples. [2]
Download the Billing Workflow Matrix
Get a one-page matrix of valid APCM + BH + RPM/RTM combinations, with evidence requirements and “do-not-bill” flags for 2026.
View sample rows (APCM alone, APCM + BH, APCM + RPM)
| Scenario | Allowed? | Evidence snapshot | Pre-claim guardrails |
|---|---|---|---|
| APCM alone | Yes |
Consent & initiating-visit logic documented. 24/7 access + continuity named. Comprehensive care plan updated this month. |
One APCM base per patient/month. Ensure the APCM note stands alone if audited. |
| APCM + BH add-on | Yes (same practitioner) |
APCM criteria met this month. BH screenings, case review, and outcomes tied to the APCM month. |
Reject combos without an APCM base code that month. Reject if APCM/BH practitioners differ. Don’t bill legacy CoCM/BHI simultaneously. |
| APCM + RPM | Yes (parallel) |
APCM documentation as above. RPM necessity + device days bucket (2–15 vs. 16–30) logged. Management time bucket (10–19 vs. 20+) documented separately. |
One RPM billing practitioner per patient/30 days. No double-counting APCM coordination time as RPM mgmt time. CPT must match documented days/time. |
Get a 20-minute review of your current claims mix
We’ll look at your current APCM/BH/RPM/RTM mix and highlight risk and upside using the 2026 rules.
Book a 20-minute reviewCitations
- CMS APCM page -- APCM monthly nature and base codes G0556/G0557/G0558 [1]
- CMS CY-2026 PFS Final Rule Fact Sheet (CMS-1832-F) [2]
- CMS MLN Telehealth & Remote Patient Monitoring (MLN901705) [3]
- CMS-1832-F Addenda and postings (efficiency adjustment & exempt code lists) [4]
Summarizes CMS public materials and Federal Register. Always confirm with your MAC and current MLN before billing; payer edits may vary.
