RPM Manual
The practical 2026 guide to device rules, day thresholds, management time, and audit defensibility for Remote Patient Monitoring.
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Strategic Industry Report
The Integrated Pharmacist: Strategies for Telepharmacy, Remote Monitoring, and Value-Based Care
Independent pharmacies are being forced to evolve. A large national analysis found that about 29% of retail pharmacies operating between 2010 and 2021 had closed by 2021, with disproportionate impact in underserved communities. The survival path is not more square footage. It is more reach and more clinical contribution.
Published: February 3, 2026
For Pharmacy Owners, Clinical Directors, Compliance Leads
Compliance note: This resource is educational and does not constitute legal advice. Telepharmacy is state-regulated, and Medicare billing depends on the billing practitioner, enrollment, supervision, and documentation. Validate program design with your compliance team and qualified counsel.
The Integrated Model
Pillar 1
Telepharmacy reach: Extend dispensing access into new geographies using hub and spoke, remote dispensing sites, or automated kiosks within state board constraints.
Pillar 2
Clinical services: Operate a care delivery layer supporting the billing practitioner for chronic disease management and medication optimization, with defensible documentation.
Pillar 3
Value-based alignment: Become the execution engine for adherence, medication safety, and access, which are measurable levers in modern quality contracts.
Overview
This report describes how a modern independent pharmacy can operate as an integrated access and clinical services organization without pretending that federal and state rules are simpler than they are.
The key concept is separation of concerns:
- Dispensing access is governed primarily by state pharmacy law and board rules, and is operationally about chain of custody, supervision, counseling, and controlled substance constraints.
- Medicare clinical billing is governed by Medicare benefit rules and PFS policy, and is operationally about eligible billing practitioners, consent, documentation, supervision, and not paying twice for the same work.
The integrated pharmacist model wins when you treat those as two distinct operating systems that share a patient relationship but do not contaminate each other’s workflows and records.
Section index
- The Market Reality: Closures, deserts, and margin compression
- Telepharmacy models and state regulatory constraints
- Medicare pathways: what pharmacies can do and what they cannot bill
- Clinical program designs: RPM, CCM, and APCM as execution targets
- Contracting models: how the money flows without creating compliance risk
- Technology stack requirements
- How FairPath operationalizes the integrated model
- FAQs
- References
Key Takeaway
The integrated pharmacist model is not a marketing slogan. It is an operating design that combines remote dispensing reach with a care-management execution layer that supports eligible billing practitioners. The differentiator is not intent. It is audit-proof workflow separation, consistent documentation, and measurable clinical outcomes.
I. The Market Reality: Closures, deserts, and margin compression
The closure wave is not a narrative. It is data. A Health Affairs analysis found that 29.4% of retail pharmacies operating during 2010 to 2020 had closed by 2021, and independent pharmacies had higher closure risk across neighborhood and market characteristics. This impacts access, adherence, and basic public health services.
The operational consequence is that independent operators need a strategy that does not depend on per-fill margin stability. That usually means two parallel moves:
- Expand access into new territories using telepharmacy models where allowed.
- Monetize clinical contribution through Part B care-management pathways, executed under an eligible billing practitioner.
A practical definition of value-based alignment for pharmacies: take measurable responsibility for adherence, medication safety, and access, then contract around that capability.
Operational implications
Access deserts are a sales surface
Telepharmacy models can extend dispensing access with lower capital than a full new pharmacy buildout.
Clinical work needs a billing shell
Medicare pays eligible practitioners, not pharmacies, so your strategy must assume partnership and contracted services.
Documentation is the product
The care program is only real if it produces patient-level artifacts that survive chart review.
II. Telepharmacy models and state regulatory constraints
Telepharmacy is not one thing. It is a family of models that all attempt to decouple dispensing supervision from physical co-location. State boards define what is allowed, and the constraints matter more than the technology.
Model A: Hub and spoke
Technicians at a spoke site, pharmacist supervision from a hub via audio-video.
- Best for rural access and pharmacy deserts
- Governed by technician ratio, distance limits, and supervision modality
- Often includes site permitting and board inspection requirements
Model B: Remote dispensing site
A registered remote site where the practice of pharmacy occurs through a telepharmacy system.
- Strong fit for clinics, FQHCs, and employer sites
- Heavier regulatory requirements and recordkeeping expectations
- Typically requires real-time counseling availability through telepharmacy
Model C: Automated kiosk
Automated dispensing with pharmacist verification and counseling using live audio-video.
- Best for after-hours pickup and access expansion
- State laws may explicitly require live real-time counseling before release
- Controlled substance policies can be highly restrictive
What the rules tend to regulate
Although state-by-state rules vary, telepharmacy regulations tend to focus on:
- Supervision and ratios: how many remote sites or technicians one pharmacist can oversee.
- Distance and geography: hub-to-spoke limits, or restrictions based on areas of need.
- Counseling requirements: mechanism for live pharmacist counseling using audio-video, and whether counseling must occur before medication release.
- Security and chain of custody: access control, audit logs, video retention, and controlled substance handling.
- Permitting and inspections: remote site registration, reporting changes, and documentation retention.
Evidence and adoption
A peer-reviewed policy analysis reported telepharmacy permitted in 28 states as of the study period and highlighted wide variation in constraints that affect real-world deployment. [2]
Industry summaries report adherence improvements associated with telepharmacy, with reported gains in Medicaid populations in some implementations. [3]
Do not treat state telepharmacy legality as static. Always confirm the current board rule text and the permitted model type for your planned deployment.
III. Medicare pathways: what pharmacies can do and what they cannot bill
There are two separate questions that operators often conflate:
- Can a pharmacist deliver clinical work remotely? Often yes, within scope of practice and within a supervised care team model.
- Can the pharmacy or pharmacist bill Medicare Part B directly for that work? Often no, because Medicare billing is tied to eligible billing practitioners and specific policy constraints.
Medicare telehealth billing is practitioner-limited
CMS publishes the list of provider types eligible to bill Medicare for telehealth professional services. Pharmacists are generally not on that list, which is why pharmacies should not build a strategy that depends on direct telehealth billing. [4]
This does not mean pharmacists are excluded from telehealth-delivered care. It means the billing shell is usually an eligible physician or non-physician practitioner.
Incident to and auxiliary personnel can be the bridge
CMS has clarified that pharmacists fall within the definition of auxiliary personnel under Medicare incident to rules and may provide services incident to the services of the billing physician or NPP, if payment is not made under Medicare Part D and the services are within state scope of practice. [6]
This is a compliance-sensitive area. The billing practitioner must retain responsibility for the patient’s care and documentation must support the billed service.
IV. Clinical program designs: RPM, CCM, and APCM as execution targets
The integrated pharmacy does not try to “do everything.” It chooses a small number of program archetypes where pharmacies have structural advantage: adherence, medication optimization, and high-frequency patient contact.
A. Remote monitoring operations
Daily data plus monthly clinical actions.
CMS materials bundle telehealth and remote monitoring policy in a single reference and summarize key constraints including eligible billing provider types and documentation expectations. [4]
Pharmacies tend to win when they operationalize data collection, outreach cadence, and escalation pathways, while the billing practitioner performs and documents the required clinical decisions and patient communications.
B. CCM as a medication engine
Monthly continuity for complex patients.
CCM becomes pharmacy-friendly when it is treated as a medication-risk management workflow: adherence gaps, side effects, interactions, high-risk meds, and care plan reinforcement.
The operational trap is time contamination with dispensing. The defensible model uses role-based work separation, a clean care log, and explicit clinical intent in notes.
C. APCM as a bundle
Monthly bundle, not minute-by-minute.
CMS created APCM starting January 1, 2025 and describes billing requirements, including consent, “one provider per month,” and the expectation that clinical staff provide services under direction of the responsible clinician. [7]
The pharmacy fit is obvious: medication management and coordination are core, and many practices lack the staff capacity to execute these workflows reliably.
Clinical outcomes are the leverage
The reason practices and payers pay for these programs is not sentiment. It is measurable outcome movement and reduced utilization. A pharmacist-supported remote hypertension management program reported 67% blood pressure control at 6 months and 74% at 12 months using a less than 140/90 threshold. [9]
Do not overfit your business model to any single study. The takeaway is that pharmacists are structurally positioned to move outcomes when the program has tight workflow design.
Minimum viable program artifacts
- Consent captured and retrievable
- Enrollment and start dates tracked
- Documented clinical intent for each episode
- Escalation notes and communications with the billing practitioner
- Monthly audit packet exportable without manual reconstruction
V. Contracting models: how the money flows without creating compliance risk
Most independent pharmacies will participate in Medicare Part B care management through a contracting relationship with a billing practitioner or group. That is normal. The mistake is treating the contract as a footnote.
Model 1: Clinical services agreement with the billing practice
The billing practitioner bills Medicare for the covered service. The pharmacy is paid a contracted fee for defined operational work (outreach, adherence coaching, survey administration, triage, documentation assistance), subject to scope of practice and the program design.
- Best when you operate a stable care team and can deliver consistent throughput
- Requires clear division of responsibilities and documentation rules
- Should be structured for commercial reasonableness and fair market value
Model 2: Value-based execution partner
Separate from any single billing code, the pharmacy contracts for measurable deliverables: adherence improvement, gaps in care closure, medication safety interventions, and access extension. This works well when the practice is under quality-linked reimbursement.
- Best when you can report metrics at scale
- Demands an evidence-ready audit trail of interventions
- Pairs well with telepharmacy access expansion in pharmacy deserts
Compliance guardrails
A safe contracting posture is simple: avoid payment tied to volume of referrals, avoid duplicative billing for the same work, and ensure documentation supports medical necessity and the billed service. This page is educational. Program contracts should be reviewed for applicable federal and state requirements.
VI. Technology stack requirements
The integrated pharmacy model fails when technology is treated as an app list. The stack must produce auditable artifacts across dispensing access and clinical operations.
Dispensing reach stack
- Telepharmacy supervision: audio-video counseling, pharmacist verification, and activity logging
- Chain of custody: device access control, authentication, and release events
- Remote site inventory control: reconciliation, waste tracking, and exception handling
- Controlled substance policy controls: state-specific constraints and reporting workflows
Clinical operations stack
- Consent and enrollment: capture, storage, and retrieval for audits
- Care log: time-stamped clinical episodes with explicit intent
- Escalation pipeline: structured messages to the billing practitioner with resolution status
- Interoperability: exportable summaries and artifacts for EHR integration
- Compliance reporting: monthly audit packets without manual reconstruction
How FairPath operationalizes the integrated model
FairPath is designed to run the clinical operating layer that sits beside your dispensing system. The objective is not to replace your PMS. The objective is to produce a care-management execution engine with artifacts that are defensible when a billing practitioner or payer requests documentation.
Workflow separation and audit trail
FairPath supports operational separation between dispensing-associated work and clinical episodes by using a dedicated care log with time stamps, user attribution, and structured clinical intent selection.
- Clinical intent selection before starting a care episode
- Episode time stamps and user attribution
- Exportable care logs for audit packets
Billing-practitioner partnership enablement
FairPath is built around the reality that the eligible billing practitioner submits the claim. The platform supports communication, escalation, and documentation workflows that allow the billing clinician to supervise and document care decisions while the pharmacy executes operational tasks.
- Consent and enrollment tracking fields
- Escalation to billing practitioner with resolution workflow
- Structured note templates that prompt medical decision documentation
Important clarification
Software supports workflow discipline and documentation consistency. It does not determine billing eligibility. Eligibility and billing decisions remain the responsibility of the billing practitioner and the program’s compliance design.
FAQ Section
1
Can pharmacists bill Medicare directly for telehealth?
Generally, no. CMS limits Medicare telehealth billing to defined practitioner types. Pharmacists typically participate by delivering clinical work under a team model and under the billing practitioner’s supervision and documentation framework.
2
Is telepharmacy legal in my state?
It depends. Telepharmacy is governed by your state board of pharmacy and rules vary across supervision requirements, remote site permitting, distance limits, and controlled substance constraints. A peer-reviewed analysis reported telepharmacy permitted in 28 states at the time of study, but you should validate your current board rule text for your planned model.
3
How does remote dispensing differ from mail-order?
Mail-order is primarily fulfillment and shipping. Telepharmacy remote dispensing is a state-regulated model where pharmacist supervision and patient counseling are provided using real-time audio-video to support safe dispensing at a remote site or kiosk.
4
What outcomes support the value-based case for pharmacists?
Outcome movement is the lever. Published results from a pharmacist-supported remote hypertension management program reported 67% blood pressure control at 6 months and 74% at 12 months using a less than 140/90 threshold. Programs that reliably produce adherence and safety artifacts become easier to contract for.
5
Does APCM require a pharmacist?
No. APCM is billed by a physician or certain non-physician practitioners and does not require a pharmacist by rule. In practice, APCM depends on ongoing medication management and coordination workflows, which makes pharmacies a high-leverage operational partner when structured correctly.
References
- Guadamuz JS, et al. More US Pharmacies Closed Than Opened In 2018-21; Closures Were More Common In Racialized Communities. Health Affairs. 2024. (Also summarized in JAMA).
- Urick BY, et al. State Telepharmacy Policies and Pharmacy Deserts. JAMA Network Open. 2023.
- Dowell MA. The Evolving Telepharmacy Dispensing Landscape. US Pharmacist. 2025.
- CMS Medicare Learning Network (MLN). Telehealth and Remote Monitoring (MLN901705). December 2025.
- CMS. Incident To Services and Supplies. Updated January 20, 2026.
- CMS Transmittal R10505CP. Clarification: Pharmacists Providing Services Incident To Physicians’ Services. December 4, 2020.
- CMS. Advanced Primary Care Management (APCM) Services. Updated January 26, 2026. (Includes G0556, G0557, G0558 requirements and consent rules).
- CMS. Calendar Year 2025 Medicare Physician Fee Schedule Final Rule Fact Sheet. November 1, 2024. (APCM policy and code levels).
- American Heart Association Newsroom. Remote monitoring and pharmacist helped improve hard-to-control blood pressure. September 5, 2024.
- Executives for Health Innovation. Impact of Pharmacist Involvement on Telehealth Transitional Care Management (TCM) for High Medication Risk Patients. December 1, 2019.
FairPath is designed to handle this complexity for you.
While most platforms simply record what happened, FairPath actively runs the program. It continuously monitors every patient, staff action, and billing rule across CCM, RPM, RTM, and APCM, intervening immediately when a requirement is missed.
This allows you to scale your own program without losing quality, breaking trust with physicians, or losing control of your revenue. We provide the precision of an automated medical director without the chaos.
