CMS Proposed Rule 2026: Key Updates and Implications

Introduction

The Centers for Medicare & Medicaid Services (CMS) has released its 2026 Medicare Physician Fee Schedule (PFS) proposed rule. This introduces key updates in behavioral health, remote monitoring, care management, and rural health billing. These changes are intended to improve patient care coordination, align billing practices, and provide more flexibility for providers.

Behavioral Health Integration in APCM – New Code

CMS proposes integrating BHI into Advanced Primary Care Management (APCM) with new add-on Gcodes. These codes will allow providers to bill both APCM and BHI/Collaborative Care Model (CoCM) services for the same patient within the same month.

These new codes are as follows:

GPCM1: Reflects CoCM first-month services, similar to 99492, covering 70 minutes of work.
GPCM2: Represents CoCM subsequent-month services, similar to 99493, covering 60 minutes.
GPCM3: Provides care management for behavioral health conditions, similar to 99484, requiring at least 20 minutes of clinical staff time.

Overall, this helps to ensure that BHI complements, rather than replaces, existing behavioral health codes while offering providers more billing flexibility.

Remote Patient Monitoring and Remote Therapeutic Monitoring Enhancements

This proposed rule change from CMS introduces new RPM and RTM codes that will apply to 2-15 days of data; existing codes now only apply to 16-30 days. The changes ensure fair reimbursement for shorter monitoring periods, reflecting real-world patient engagement.

Enhanced Time Management in RPM & RTM

To streamline patient care and optimize reimbursement, a new “10-Minute” CPT code has been introduced for Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) programs. This update is designed to make clinical workflows more efficient while supporting better patient engagement.

RPM – 99XX5

Remote physiologic monitoring treatment management services.

Time: First 10 minutes per calendar month.
Performed by: Clinical staff, physician, or other qualified health care professional.
Requirement: At least 1 real-time interactive communication with the patient or caregiver.

RTM – 98XX7

Remote therapeutic monitoring treatment management services.

Time: First 10 minutes per calendar month.
Performed by: Physician or other qualified health care professional.
Requirement: At least 1 real-time interactive communication with the patient or caregiver.

Note: The CPT codes referenced above (99XX5, 98XX7) are placeholder codes. CMS will release the finalized CPT codes in the official publication.

Elimination of SDOH Code G0136

CMS proposes deleting G0136, previously used for SDOH assessments. Instead, providers should use Evaluation and Management codes.

Removal of G0511 and G0512

CMS will sunset G0511 in 2025 and discontinue G0512 in 2026. Instead, RHCs and FQHCs must bill individual CPT/HCPCS codes.

Flexibility in Remote Monitoring

Clinics can now bill RPM and RTM codes along with APCM, making it easier to provide coordinated care for patients who need different services.

Care Management vs. Care Coordination

CMS distinguishes the two approaches:

Care Management: Direct clinical services like CCM, BHI, and RPM for chronic or complex needs.
Care Coordination: Administrative tasks such as scheduling, record sharing, and outreach.

In 2026, care management will also qualify as care coordination for separate billing.

Request for Information (RFI) by CMS

CMS seeks input on several areas, including:

Closing gaps in chronic disease coding and prevention.
Expanding wearable technology and digital therapeutics.
Addressing social isolation and lifestyle barriers.
Adding supportive services such as motivational interviewing and health coaching.

Conclusion

The CMS Proposed Rule 2026 marks a shift toward flexible billing, integrated behavioral health, and greater recognition of care coordination. By aligning rural and traditional provider practices and embracing digital health, CMS aims to improve care delivery while simplifying reimbursement. Providers must adapt their workflows to take full advantage of these updates.