On July 14, 2025, the Centers for Medicare and Medicaid Services (CMS) released its Calendar Year 2026 Medicare Physician Fee Schedule (PFS) proposed rule. The proposed rule contains a number of regulatory and reimbursement updates for Remote Therapeutic Monitoring (RTM).

_{New Remote Therapeutic Monitoring CPT Codes for 2026}

_{Two Additional MSK RTM Codes Proposed}

CMS is proposing to adopt two new CPT codes to the current MSK Remote Therapeutic Monitoring family of codes. 

The new CPT codes for RTM, proposed to be effective starting January 1, 2026, enable new reimbursement opportunities for provider practices utilizing RTM, specifically:

• Reimbursement for patients with 2-15 days of data transmission through RTM MSK devices
• Reimbursement for patients with 10-19 minutes of monthly treatment management services.

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_{Long-Term Support for Remote Therapeutic Monitoring}

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The latest development signals long-term support for RTM. It complements Remote Physiologic Monitoring (RPM) and supports practices in adopting technology and services to improve care for patients with musculoskeletal (MSK) conditions.

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Below are the two new MSK RTM codes that are proposed to be covered and paid for beginning January 1, 2026:

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Note: At this time, the X in the CPT codes are placeholders. When the American Medical Association (AMA) releases the 2026 CPT codes in September 2025, it will include the 5-digit numerical code for each new RTM CPT code.

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Remote Therapeutic Monitoring 2026 Reimbursement Proposed Changes

Conversion Factor Updates

Additionally, there are several changes in the proposed conversion factor for 2026 – which reflects an increase compared to 2025, in contrast to previous years.

First, as required by statute, there are two separate conversion factors beginning in 2026: 

• Qualifying Alternative Payment Model (APM) participants (+0.75%)
• Physicians and practitioners who are not in qualified APMs (+0.25%). 

Note: Most outpatient therapy providers are not in qualified APMs.

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Second, recent legislation included a one-year increase of +2.5% for 2026.

Third, the proposed 2026 conversion factor includes an estimated +0.55% adjustment to account for proposed changes in work RVUs for some services.

This results in a proposed 2026 qualifying APM conversion factor of $33.59 (+3.83% from 2025) and a proposed 2026 non-qualifying APM conversion factor of $33.42 (+3.62% from 2025).

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The following table outlines the 2025 Medicare national average payments for the RTM codes and the proposed reimbursement for the 2026 RTM code family:

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Comment Period and Final Rule Timeline

CMS is accepting comments to the 2026 Physician Fee Schedule Proposed Rule until September 12, 2025. The final rule will most likely be out in November 2025. 

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Please note: This blog is for informational purposes only, does not constitute billing or legal advice, and includes a review of information about the 2026 CMS Proposed Rule yet to be finalized, which is publicly available here.

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