Medicare's 2026 Physician Fee Schedule added two remote patient monitoring (RPM) codes. CPT 99445 pays for device supply when a patient transmits between 2 and 15 days of data in a 30-day period, so shorter monitoring periods can now be billed; the existing device supply code, 99454, covers 16 or more days. CPT 99470 pays for the first 10 minutes of monthly treatment management that includes one real-time interactive communication with the patient.
For device makers, the change is less a billing detail than a design input. Whether a patient's device gets set up, connects and keeps transmitting on enough days now maps directly to which code, if any, a practice can bill.
The 2026 RPM Codes
| Code | What It Covers | Engineering Relevance |
|---|---|---|
| 99453 | Initial setup and patient education; from 2026, at least 2 days of monitoring are required | Onboarding flow, first-use success |
| 99454 | Device supply with data transmission, 16 or more days in a 30-day period | Sustained adherence, connectivity uptime |
| 99445 (new) | Device supply with data transmission, 2 to 15 days in a 30-day period | Reliable transmission even in short monitoring periods |
| 99457 / 99458 | Treatment management, first 20 minutes and each additional 20 minutes | Data presentation for clinical review |
| 99470 (new) | Treatment management, first 10 minutes, with one real-time interactive communication | Tools that support short reviews |
CMS's requirements shape the engineering as well. Its remote monitoring booklet (MLN901705, December 2025) says physiologic data must be collected electronically and uploaded automatically, the device must meet FDA's definition of a medical device, and data collection must cover 2–15 or 16 or more days out of 30, depending on the code. Remote therapeutic monitoring (RTM) gained parallel 2026 codes for 2–15-day device supply and 10-minute management.
Engineering That Affects Billable Days
1. Low-Touch Provisioning
Every setup step is a point where a patient can stall before the first reading. Approaches that reduce setup steps include:
- QR-code enrollment: the patient scans a code and the device registers
- Cellular connectivity: no Wi-Fi configuration required
- Pre-configured shipment: devices provisioned before they leave the warehouse
- Over-the-air firmware updates: updates without user intervention
2. Self-Guided Onboarding
Practice staff time is a cost, so self-service capability matters:
- Interactive LED or display guidance: step-by-step visual instructions on the device
- Audio prompts: accessible voice guidance
- Companion app tutorials: in-app video walkthroughs
- Automatic escalation: the device detects a setup failure and triggers support
Design Principle
Staff time spent on setup is a cost the practice has to cover. How many minutes of staff involvement a device needs is worth measuring and disclosing.
3. Connectivity Reliability
A reading that never arrives doesn't count toward a monitored day. Designs that protect transmission include:
- Multi-path connectivity: cellular, Wi-Fi and Bluetooth fallback
- Store-and-forward: buffer readings during connectivity gaps
- Connection health monitoring: alerts before data gaps occur
- Automatic reconnection: no manual step after the signal returns
4. Activation and Adherence Metrics
With device supply billing tied to the number of days with transmitted data, these metrics show whether a device supports the codes a practice expects to use:
- Time to first reading: how quickly the patient takes a first measurement
- Setup completion rate: share of shipped devices successfully activated
- Days with transmitted data per 30-day period: the figure that separates 99454, 99445 and neither
- Support ticket correlation: setup issues flagged before the patient calls
Design Differences That Show Up in the Data
| Attribute | Higher-Friction Design | Lower-Friction Design |
|---|---|---|
| Setup | Staff-assisted | Self-service |
| Connectivity | Wi-Fi only, manual configuration | Cellular, pre-provisioned |
| Patient education | Paper manual only | On-device and app tutorials |
| Troubleshooting | Reactive support calls | Proactive issue detection |
| Analytics | Readings only | Activation and adherence metrics |
Architectural Choices to Ask About
Common architectural choices in connected RPM devices, and what each is for:
Hardware
- Embedded cellular module: LTE-M or NB-IoT with a multi-carrier SIM
- E-ink or low-power display: persistent setup status without battery drain
- Hardware security element: secure provisioning and device identity
- Capacitive touch with haptic feedback: accessible interaction
Firmware
- State machine-driven onboarding: a deterministic setup flow
- A/B partitions for over-the-air updates: rollback capability
- Lightweight RTOS: fast boot
- Edge processing: anomaly detection before cloud transmission
Cloud Platform
- Device management console: fleet-level activation tracking
- Automated onboarding workflows: triggers based on device state
- EHR integration: HL7 FHIR or CDA support
- Billing support: day counts and time logs that support the practice's own documentation
Due Diligence Focus
When evaluating an RPM company, ask to see the device activation funnel: setup completion rates, time to first reading, and days with transmitted data per 30-day period, by cohort. Without them, a company can't show how its devices map to the 2026 codes.
Implications by Device Category
Blood Pressure Monitors
Bluetooth-only cuffs depend on a paired phone or hub to transmit; cellular cuffs don't. Which kind a program uses affects how many days of data arrive.
Weight Scales
Setup is simpler, but multi-user households create an engineering problem: the device has to identify the right patient reliably.
Pulse Oximeters
FDA's January 2025 draft guidance on pulse oximeters for medical purposes recommends more clinical performance testing, citing concerns that accuracy can be affected by, among other factors, a person's skin pigmentation. Accuracy data across skin tones is a fair diligence question.
Questions for an RPM Device Diligence Read
- Is the onboarding funnel instrumented from unboxing to first reading?
- How does the device connect, and what happens to readings during a connectivity gap?
- What share of monitored patients reach 2, and 16, days of transmitted data in a 30-day period?
- How much staff time does setup take?
- What activation and adherence data can providers see?
References
- Nixon Law Group. "CMS Finalizes 2026 Remote Monitoring Reimbursement Updates: What Changed for RPM and RTM." November 4, 2025. nixonlawgroup.com
- CMS. "Telehealth & Remote Monitoring." MLN901705. December 2025. cms.gov
- Prevounce. "2026 Remote Patient Monitoring CPT Codes: What's New and What to Know." November 6, 2025. prevounce.com
- Smart Meter. "Remote Patient Monitoring Goes Mainstream with 2026 CPT Code Proposal." November 6, 2025. smartmeterrpm.com
- Tenovi. "RTM CPT Codes 2026." December 18, 2025. tenovi.com
- FDA. "Pulse Oximeters for Medical Purposes - Non-Clinical and Clinical Performance Testing, Labeling, and Premarket Submission Recommendations." Draft guidance, January 2025. fda.gov
- FDA. "Policy for Device Software Functions and Mobile Medical Applications." fda.gov
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