RPM Manual
The practical 2026 guide to device rules, day thresholds, management time, and audit defensibility for Remote Patient Monitoring.
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Anthem Clinical UM Guideline CG-MED-91 (Publish Date: 12/18/2025)
Anthem CG-MED-91 adds 2026 RPM/RTM short-cycle codes: what changed and how to operationalize it
Anthem updated CG-MED-91 to explicitly incorporate the 2026 “short-cycle” RPM/RTM coding structure, adding new 2–15 day device supply codes and new 10-minute treatment management codes.
Organizations that still run “16 days or nothing” device logic and “20 minutes or nothing” management logic will misbill unless they restructure eligibility, time capture, and documentation around the new descriptors.
Last updated: December 22, 2025
For: Practice owners, billing managers, compliance leads, RPM/RTM program operators
Scope: Anthem plans and 2026 payer alignment
How to use this page: This is an operational compliance guide based on publicly available payer and CMS sources. It is not legal advice. Use it to update workflows, billing logic, documentation standards, and payer-specific configurations.
Regulatory Snapshot
Policy update
CG-MED-91 updated 12/18/2025
Effective date
01/01/2026 CPT changes
New short-cycle codes
99445, 99470, 98979, 98984–98986
Operational risk
Legacy 16-day and 20-minute logic leads to underbilling or denial exposure.
Section Index / Navigation Map
Jump to the section you need
- Key Takeaway in One Sentence
- Core Rule Explanation
- Common Failure Patterns / Traps
- Why This Is Non-Compliant
- Edge Cases & Clarifications
- Forward-Looking Policy Context
- Practical Implications for Practices
- Planning Checklist
- How This Fits the Bigger CMS / Payer Story
- How FairPath Automates or Enforces This
- FAQ
- References
Key Takeaway in One Sentence
Anthem’s CG-MED-91 (published December 18, 2025) explicitly adds 2026 RPM/RTM codes that split device supply into 2–15 days vs 16–30 days and add 10-minute treatment management options, so billing workflows must select codes based on the actual day-count tier and interactive-communication requirement rather than forcing episodes into legacy 16-day/20-minute assumptions.
Core Rule Explanation
What Anthem actually published and when
CG-MED-91 lists a publish date of 12/18/2025. In the History section, Anthem states it “Updated Coding section with 01/01/2026 CPT changes,” adding 98979, 98984, 98985, 98986, 99445, and 99470.
Why it matters now
Anthem’s update explicitly aligns its code list with 2026 CPT changes, supporting shorter monitoring episodes and a new 10-minute treatment-management increment. That changes how eligibility logic, time capture, and documentation must be structured.
The exact code descriptors Anthem lists (operationally decisive)
- 98984: RTM respiratory device supply, 2–15 days in a 30-day period.
- 98985: RTM musculoskeletal device supply, 2–15 days in a 30-day period.
- 98986: RTM cognitive behavioral therapy device supply, 2–15 days in a 30-day period.
- 98979: RTM treatment management, first 10 minutes in a calendar month, requiring at least one real-time interactive communication.
- 99445: RPM device supply with transmission, 2–15 days in a 30-day period.
- 99470: RPM treatment management, first 10 minutes in a calendar month, requiring at least one real-time interactive communication.
- Legacy tiers remain: 99454, 98976–98978 (16–30 days), 99457/99458 and 98980/98981 (20-minute management codes).
Medical-necessity gate Anthem applies
Anthem requires documentation that RTM/RPM is clinically appropriate (not for convenience), the patient is at risk of clinically significant change, the patient cannot access regular outpatient care or needs between-visit monitoring, and monitoring is reasonably likely to prevent deterioration or adverse events. For RPM, Anthem specifies an FDA-recognized medical device that directly measures physiologic data.
A payer-document inconsistency you should not ignore
The Definitions section states RPM is “longer than 16 days,” but the Coding section lists 99445 for 2–15 days. Operationally, treat the code descriptor as the controlling unit definition and treat the older sentence as stale text, while documenting medical necessity and the selected descriptor.
Common Failure Patterns / Traps
Trap 1: “16 days or nothing” device logic persists
Legacy RPM programs often treated device supply as binary. Under Anthem’s 2026 list, that logic is wrong because 99445 exists for 2–15 days.
Trap 2: “20 minutes or nothing” management logic persists
If workflows only bill after 20 minutes, they miss legitimate 10-minute cases. Anthem lists 99470 and 98979 for first 10 minutes with an interaction requirement.
Trap 3: Treating short episodes as “non-billable”
Delaying billing until a patient “stabilizes” risks constructing claims that no longer match the defined 30-day period and invites inconsistencies if reviewed.
Trap 4: Device-only RPM/RTM without active clinical use
Anthem expects data assessment to detect acute change and prompt intervention. Device-only programs without documented assessment and response are misaligned to the criteria.
Trap 5: Assuming RTM is “less audited” than RPM
Anthem’s update treats RTM with the same structural rigor as RPM. Expect denials and audits to mature similarly.
Why This Is Non-Compliant
CPT unit definitions and date integrity
If the descriptor defines a 2–15 day or 16–30 day unit in a 30-day period, then stretching or borrowing days across boundaries changes the unit you are claiming. Anthem’s list makes the unit boundaries explicit.
Interactive communication is not optional
Both 99470 and 98979 require at least one real-time interactive communication within the calendar month. Billing without a defensible interaction record is a direct descriptor mismatch.
Medical necessity is a second gate beyond code selection
Even when the code is selected correctly by days and time, Anthem’s “ALL of the following” medical-necessity criteria can still trigger denial if the documentation does not show active assessment, patient risk/instability, and a likelihood of preventing deterioration or adverse events.
Edge Cases & Clarifications
Partial months (episode ends at day 8)
If medically necessary and documented, Anthem’s list includes 99445 and 98984–98986 for 2–15 days. The documentation still must meet the medical-necessity criteria.
Calendar month vs 30-day period
Supply codes use a 30-day period, while management codes use calendar month time and require interactive communication within that month. Your system must track both units separately.
Hospitalization or concurrent services
Anthem states RTM/RPM is not medically necessary when similar services are provided concurrently (for example, home health). Documentation should show why the monitoring is not duplicative.
Device failures and missing days
The 2–15 day tier reduces pressure to “make up” missing days. Use the day-count tier achieved, or do not bill supply.
Forward-Looking Policy Context
CMS recognizes the new RTM codes for 2026
CMS MLN Matters MM14250 identifies 98984 and 98985 as new RTM device supply codes for 2–15 days and 98979 as a new RTM management code for the first 10 minutes, effective January 1, 2026, and discusses their “sometimes therapy” designation.
CMS is changing remote monitoring valuation methodology
The CY 2026 PFS final rule fact sheet notes CMS will use OPPS hospital data to inform costs for some remote monitoring services. AMA commentary also highlights the shift toward OPPS-driven practice expense valuation for the RPM family, signaling more scrutiny of unit integrity.
Practical Implications for Practices
What practices must stop doing
- Stop treating supply as “16 days or nothing.” Anthem lists explicit 2–15 day supply codes.
- Stop treating management as “20 minutes or nothing.” Anthem lists first-10-minute options with required interaction.
- Stop “stretching” episodes to hit thresholds. The claim unit must match the descriptor’s unit.
What practices must change
- Split device supply eligibility into two tiers (2–15 vs 16–30) and select the code accordingly.
- Treat interactive communication as a required compliance artifact for 10-minute and 20-minute management codes.
- Document medical necessity to show active assessment and intervention intent, not just data collection.
What practices must monitor more closely
Payer-by-payer support and adoption timelines. CG-MED-91 shows Anthem’s coding alignment, but benefit plans and claims edits can vary by line of business, and Anthem notes that plan language governs coverage.
Planning Checklist
- Inventory your current RPM/RTM billing logic to confirm whether you have hard-coded “16 days” and “20 minutes” thresholds.
- Update device-supply eligibility to support both tiers: RPM 99445 (2–15) vs 99454 (16–30); RTM 98984–98986 (2–15) vs 98976–98978 (16–30).
- Update management-time logic to support first-10-minute codes: RPM 99470 and RTM 98979.
- Validate that your workflow reliably captures and stores evidence of real-time interactive communication in any month where management codes are billed.
- Update documentation templates to explicitly map to Anthem’s medical-necessity criteria (risk/instability, assessment frequency, intervention intent, not duplicative of concurrent services).
- Run a denial-risk review on your short-episode population (2–15 days or under 20 minutes) because those episodes are now billable but also reviewable.
- For RTM programs tied to therapy plans of care, review Medicare “sometimes therapy” guidance and modifier requirements for 2026.
How This Fits the Bigger CMS / Payer Story
The 2026 changes reflect a broader trajectory: CMS and payers are shifting remote monitoring from rigid, month-sized constructs to unit definitions that support short, clinically meaningful episodes (2–15 day supply; 10-minute management). Anthem adopting these descriptors in CG-MED-91 signals commercial utilization management is tracking the same shape.
At the same time, CMS is moving toward more auditable, data-driven valuation and rate-setting for remote monitoring services, including OPPS data use. Episode flexibility is increasing, but expectations for unit integrity and documentation consistency are also increasing.
How FairPath Automates or Enforces This
Automatic, code-accurate claim construction
FairPath’s billing engine automatically generates RPM/RTM billing codes, including the new 2026 codes and correct tier selection logic (2–15 vs 16–30 day device supply and 10-minute management options), so teams are not manually counting days or reconstructing time logs.
Payer-configurable compliance gating
FairPath’s compliance engine can be configured payer-by-payer to deny or flag codes not supported by a specific line of business and to require prerequisite compliance artifacts (such as interactive communication) before a claim is marked billable.
FAQ
Yes. The History section states that on 12/18/2025 Anthem updated the Coding section for 01/01/2026 CPT changes and lists the added codes (98979, 98984–98986, 99445, 99470).
CG-MED-91 lists 99445 for device supply when transmission occurs 2–15 days in a 30-day period. Coverage depends on the member’s benefits and Anthem claim edits, but the descriptor is explicitly present in the guideline’s coding list.
CG-MED-91 lists 99470 and 98979 as “first 10 minutes” and requires at least one real-time interactive communication with the patient/caregiver during the calendar month.
No. CG-MED-91’s medical-necessity criteria still require clinical rationale, patient risk/instability, assessment to detect changes and prompt intervention, and likelihood to prevent deterioration or adverse events.
For claim construction, the unit definition in the code descriptor is controlling. CG-MED-91’s Coding section lists 99445 for 2–15 days, while the definition sentence appears stale. Use the code descriptor and document medical necessity clearly.
CMS MLN Matters MM14250 documents the 2026 RTM changes (98984/98985 for 2–15 days and 98979 for first 10 minutes) and their “sometimes therapy” designation, effective January 1, 2026.
References
Primary sources
- Anthem Clinical UM Guideline CG-MED-91: Remote Therapeutic and Physiologic Monitoring Services (Publish Date 12/18/2025; Coding descriptors and History table noting 01/01/2026 CPT changes and added codes).
- CMS Medicare Learning Network MM14250: Therapy Code List: 2026 Annual Update (RTM codes 98984/98985 2–15 days; 98979 first 10 minutes; effective January 1, 2026).
- CMS Change Request document (R13431CP / CR 14250) confirming addition of RTM codes to the therapy list effective 1/1/2026 and contractor update requirements.
- CMS Fact Sheet: Calendar Year 2026 Medicare Physician Fee Schedule Final Rule (CMS-1832-F) noting OPPS data use for some remote monitoring services.
Secondary commentary (clearly labeled)
- American Medical Association: 2026 MPFS Final Rule Summary and Analysis (remote monitoring code families and valuation methodology context).
