Remote Patient Monitoring (RPM) has delivered real clinical value for years. Billing rules lagged behind real patient behavior. A large gap came from a single threshold that decided everything.
The CY 2026 Physician Fee Schedule (PFS) final rule shifted RPM toward a tiered structure. The rule supports reimbursement tied to clinically meaningful monitoring, not perfect daily adherence.
CPT 99445 is the core fix for the device-supply gap. The code recognizes 2–15 days of physiologic data transmission in 30 days as a billable device supply.
This guide is written for physicians, billing teams, revenue cycle leaders, and RPM program managers who need clean rules, claim-safe documentation, and audit-ready workflows.
What CPT Code 99445 Means
Multiple perspectives matter here because “RPM billing” mixes clinical intent, device rules, and claim rules.
CPT 99445 reports RPM device supply for months with 2–15 days of transmitted physiologic data in a 30-day monitoring period. The code covers the device supply and the capability for daily recordings or programmed alerts to transmit, based on the code descriptor structure used across RPM device-supply codes.
CPT 99445 does not represent provider time. Time-based work uses separate RPM management codes.
CPT 99445 exists because the prior device supply code, 99454, required a minimum number of days that often excluded real-world monitoring patterns. The 2026 update split device supply into two buckets:
- 99445 for 2–15 days
- 99454 for 16–30 days
That split gives programs a compliant way to bill stable patients, step-down monitoring, and short episodes such as post-discharge observation.
The 2026 RPM Update at a Glance
Multiple perspectives matter because RPM changes in 2026 touched device supply and management time.
New RPM codes effective January 1, 2026
Two codes matter in daily operations:
- CPT 99445: RPM device supply for 2–15 days of data transmission in a 30-day period
- CPT 99470: RPM treatment management for 10–19 minutes in a calendar month, with at least 1 real-time interactive communication with the patient or caregiver
Existing RPM codes that still apply
The foundational RPM structure remains active:
- 99453: device setup and patient education
- 99454: device supply for 16–30 days
- 99457: treatment management, first 20 minutes
- 99458: each additional 20 minutes
The new codes extend the structure. The new codes do not replace the older ones.
Why the Old 16-day Rule Created a Revenue Gap
Multiple perspectives matter because the 16-day rule created both financial and clinical distortions.
The device-supply cliff
Under the older approach, a patient with 15 transmission days produced the same device-supply reimbursement as a patient with 0 days.
Operational reality looked different:
- Care teams reviewed transmitted readings on many of those “short” months
- Nurses and medical assistants escalated abnormal values.
- Physicians changed medications, diet plans, and follow-up intervals.
The work existed. The device remained deployed. Reimbursement failed at a single threshold.
The management-time cliff
Time-based RPM had a similar cliff. Under the older model, 19 minutes of management time failed the 20-minute minimum, leaving brief but meaningful interventions unpaid.
CPT 99470 addresses that time gap by paying a defined bucket for 10–19 minutes when the interactive communication requirement is met.
How CPT 99445 Closes the 2–15 Day Device-Supply Gap
Multiple perspectives matter because short monitoring episodes often match clinical goals better than daily long-duration tracking.
CPT 99445 recognizes a simple truth: clinical relevance does not equal daily frequency.
Short monitoring periods fit common care pathways:
- post-discharge stabilization for blood pressure, weight, and pulse oximetry
- medication titration periods for antihypertensives and diuretics
- stable chronic disease management using periodic checks
- adherence-challenged patients who still transmit meaningful data
The key operational change is predictable: months with 2–15 transmission days no longer drop to zero for device supply.
CPT 99445 vs CPT 99454: Correct Code Selection
Multiple perspectives matter because many denials come from simple bucket errors.
The rule that decides everything
The deciding factor is only the number of days with valid transmitted data in the 30-day period.
- 2–15 days → bill 99445
- 16–30 days → bill 99454
Diagnosis does not change that bucket rule. The vendor does not change that bucket rule. Provider effort does not change that bucket rule.
Simple billing decision logic
- 0–1 days of transmitted data → no RPM device-supply code
- 2–15 days → 99445
- 16–30 days → 99454
- One 30-day period → only one device-supply code
Mutual exclusivity is strict. Billing both device-supply codes in the same 30-day period is a clean audit trigger.
Billing Rules and Requirements for CPT 99445
Multiple perspectives matter because compliance rests on device standards, data standards, and claim standards.
Billing frequency
- Bill once per 30 days per patient
- Do not bill 99445 and 99454 for the same patient in the same 30-day period.
Qualifying devices
Device qualification is not optional.
CPT 99445 requires an RPM device that meets medical device expectations and supports automatic recording and transmission.
Non-qualifying data sources include:
- manual patient entry into an app
- text messages with photos of readings
- consumer wellness devices without an appropriate medical device status
Common qualifying device categories include blood pressure cuffs, glucometers, weight scales, and pulse oximeters that transmit readings electronically.
Eligible billing practitioners and clinical staff
Physicians and other qualified health care professionals bill the service. Clinical staff perform many RPM tasks under the supervision of rules that apply to RPM services.
Local compliance policies should define supervision level, task delegation, and documentation standards.
Medicare Payment Expectations for CPT 99445 in 2026
Multiple perspectives matter because finance teams need realistic forecasting, not a single national number.
Many RPM summaries report roughly the same national average payment for 99445 and 99454, with an estimated non-facility national average around the mid-$40 range. Locality adjustments apply.
A safe way to state this internally:
- Budget at the national average for planning
- Load your MAC fee schedule rates in the billing system for real forecasting.
. - Track non-facility vs facility impacts where applicab..le
Why CMS valued the buckets similarly
CMS discussed using OPPS cost data to inform rate-setting for some remote monitoring services.
Several policy summaries tie that valuation approach to remote monitoring practice expense logic and emphasize auditable data sources.
How CPT 99445 Works with other RPM codes
Multiple perspectives matter because device supply, setup, and management time are separate claim “lanes.”
99445 with 99453 (setup month)
The first month of monitoring often includes setup and education.
- Bill 99453 for setup and patient education
- Bill 99445 in the same 30-day period when data transmission reaches 2–15 days
Documentation must show the setup activity and the patient education content.
99445 with management-time codes
CPT 99445 covers device supply only.
Management time uses:
- 99470 for 10–19 minutes with at least one real-time interactive communication
- 99457 for 20+ minutes with interactive communication requirement
- 99458 for each additional 20 minutes beyond the first 20
Non-additive rule:
- 99470 and 99457 are not billed together for the same month.
Real-world Use Cases of CPT 99445
Multiple perspectives matter because use cases drive documentation quality.
1) Post-discharge monitoring
Discharge transitions often involve a short stabilization period.
A common pattern:
- 14 days of daily blood pressure and weight
Week3 and week 4 without readings due to the step-down plan
A 14-day month bills 99445, not 99454.
2) Medication titration
Medication changes need tight observation for a defined window.
Examples include:
- antihypertensive dose changes
- diuretic adjustments in fluid management plans
A 10-day monitoring window still supports clinical decisions, and the device supply becomes billable in that month through 99445.
3) Stable hypertension monitoring
Stable patients often follow periodic monitoring.
A plan with 3 readings per week yields 12–13 transmission days in many months. That month’s bills are 99445.
4) Weight management programs
Weekly or biweekly weigh-ins reduce burnout and support adherence in obesity programs.
A month with 8 weigh-in bills of 99445.
5) Patients with adherence barriers
Patients who reach 8–12 transmission days remain clinically engaged. 99445 prevents device-supply revenue loss tied to imperfect adherence.
When CPT 99445 is Not Applicable
Multiple perspectives matter because denial avoidance starts with exclusion rules.
CPT 99445 is not billable in these situations:
- fewer than 2 days of transmitted data in the 30-day period
- data sent through manual entry, photos, or messages rather than automatic transmission
- Devices that do not meet medical device expectations for RPM
- monitoring without documented medical necessity
Medical necessity documentation should tie monitoring to problems such as hypertension, heart failure, diabetes, COPD, obesity, or post-discharge risk, using diagnoses, symptoms, and treatment-plan goals.
Common denials and audit triggers for CPT 99445
Multiple perspectives matter because audit failure often comes from process gaps, not intent.
Denial trigger 1: missing day count
Claims fail when the record lacks:
- start date and end date for the 30-day period
- total number of transmission days
- source of the count, such as RPM platform logs
Denial trigger 2: non-qualifying data pathway
Manual uploads often look like transmissions inside an EHR note. Auditors treat those as non-qualifying pathways.
Denial trigger 3: code conflicts
High-risk patterns include:
- billing 99445 and 99454 in the same 30-day period
- billing 99470 and 99457 in the same month
- overlapping time with CCM, PCM, or other time-based services
Audit-ready documentation checklist for CPT 99445
Multiple perspectives matter because documentation must satisfy clinical review and claims review.
A clean 99445 record includes 7 items:
- 30-day monitoring period start date and end date
- Transmission-day count for that period.
- Physiologic parameters monitored, such as blood pressure, weight, glucose, and oxygen saturation
- Device identification, including model name and device status, in your vendor file
- Data pathway proof, showing automatic transmission from device to platform
- Medical necessity statement, tied to a condition and a monitoring goal
- Clinical actions, such as medication changes, patient outreach attempts, threshold alerts, and care plan updates
Documentation quality improves when the RPM platform and EHR share a standard monthly summary note template.
CPT 99445 vs CCM, PCM, and RTM
Multiple perspectives matter because “double counting” creates recoupment risk.
RPM with CCM or PCM
RPM device supply can be billed alongside CCM or PCM. Time-based minutes must remain separated. One minute of staff time counts once.
A strict internal rule:
- RPM time log stays inside the RPM module
- The CCM time log stays inside the CCM module.
- Supervisors review overlap before claims release
RPM vs RTM
RTM tracks therapy adherence and therapy response. RPM tracks physiologic parameters. Code choice depends on the parameter and the device pathway.
RTM policies and codes have their own day buckets and time buckets, separate from RPM.
Medicare vs commercial payer adoption
Multiple perspectives matter because Medicare policy sets a baseline,, and commercial payers vary.
Medicare established the new RPM code structure for 2026 through the PFS final rule framework.
Commercial payers often follow with payer-specific timelines, coverage policies, prior authorization rules, and edits.
A practical control is a payer policy matrix that tracks:
- 99445 coverage status
- prior authorization requirements
- frequency limits
- modifier rules
- denial codes and appeal language
Some payer medical policies already list 99445 within remote physiologic monitoring code sets.
Putting CPT 99445 into your RPM program
Multiple perspectives matter because success needs workflow changes, not just new codes.
System updates
Billing success improves when the system performs 3 actions:
- counts transmission days automatically
- locks the device-supply code based on the bucket
- flags conflicts between 99445 and 99454
Team training
Training should cover:
- day thresholds for 99445 vs 99454
- time thresholds for 99470 vs 99457 vs 99458
- “automatic transmission” definition
- medical necessity documentation expectations
Monthly QA and internal audits
A basic QA process catches most errors:
- sample 10 charts per month per site
- Validate transmission-day count against platform logs. Verify device qualification documentation.
- Verify code exclusivity edits.
- Verify time separation rules across RPM and CCM.
Conclusion:
CPT 99445 changes RPM economics in a direct way. Months with 2–15 transmission days now support compliant device-supply reimbursement.
Preparation steps that reduce denials:
- Implement automated day counting
- enforce mutual exclusivity edits
- standardize monthly documentation templates
- Audit time overlap across RPM and CCM
- train staff on 99445 and 99470 thresholds
RPM programs that encode these controls scale faster and face fewer recoupment events.
Frequently asked questions
What is CPT 99445 used for?
CPT 99445 reports RPM device supply for months with 2–15 days of transmitted physiologic data in a 30-day period.
How many days are required to bill 99445?
At least 2 days and no more than 15 days in the 30-day period.
Can CPT 99445 and 99454 be billed together?
No. The codes are mutually exclusive for the same 30-day period.
Does CPT 99445 require interactive communication?
No. Interactive communication applies to RPM management codes such as 99470 and 99457.
How much does Medicare pay for CPT 99445 in 2026?
Many summaries cite a national average estimate in the mid-$40 range, with locality variation, and a similar valuation to 99454.
Can CPT 99445 be billed with CCM codes?
Yes. Time minutes must not be counted twice across RPM and CCM.
