Remote patient monitoring in 2025: The major changes physicians need to know about

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In early November, the Centers for Medicare & Medicaid Services (CMS) issued its 2025 Physician Fee Schedule (PFS) final rule. I recently presented a webinar that highlighted the biggest final rule developments affecting remote care management and also covered a few other recent and significant announcements impacting these services. Remote care management is undergoing big changes, so I thought it would be helpful to provide a summary of some of the key things to know about how the 2025 final rule and one of these other important developments impact remote monitoring and related topics.

Advance primary care management takes the limelight

Background

With the ongoing push toward value-based care, CMS decided to see whether it could further move the needle with the introduction of advanced primary care management (APCM) for 2025. Before I dive into this new service, I think it would be helpful to provide some background.

In 2021, CMS established a goal to have 100% of Medicare beneficiaries in some type of “accountable” reimbursement arrangement by 2030. The CMS Innovation Center was tasked with strategy, testing models and finding tools to improve adoption of value-based care. Over the last 10 years, there have been multiple opt-in programs that adjust or replace fee-for-service (FFS) payment within primary care, but adoption is still low, and there is significant pressure from primary care providers (PCPs) against major change.

How do you introduce population-based concepts to FFS providers to pave the way? Enter APCM, one of CMS’s most noteworthy inclusions in this year’s final rule. It’s a reimagining of FFS care management services to a population-based payment structure in the primary care setting. The APCM program (also a payment model) combines elements of existing care management programs, like chronic care management (CCM) and principal care management (PCM). APCM also incorporates select communications technology-based services, like virtual check-ins and remote evaluation of images, which have been introduced as separately billable in recent years.

Unlike the existing FFS care management programs, APCM’s codes are not time-based. Rather, they are broken out by patient risk (i.e., levels) and include 13 distinct service elements — areas that I’ll discuss further shortly.

Billing and coding

APCM services are to be delivered by clinical staff and directed by a physician or other qualified health care professional who is responsible for all primary care and serves as the continuing focal point for all needed health care services. CMS specified that such providers could operate out of traditional (i.e., family or internal medicine) or nontraditional primary care specialties. Providers operating out of federally qualified health centers (FQHCs) can provide and bill for APCM services under the common code set provided.

Similar to CCM and PCM, CMS does not include a list of qualifying chronic conditions for APCM, presumably to encourage innovation.

There are three APCM billing codes, as follows:

• Level 1, Healthcare Common Procedure Coding System (HCPCS) G0556, is for patients with one chronic condition or fewer (i.e., zero). Its approximate reimbursement valuation for 2025 is $15 per month.
• Level 2, HCPCS G0557, is for those with two or more chronic conditions. Its approximate reimbursement valuation for 2025 is $50 per month.
• Level 3, HCPCS G0558, is for patients with multiple chronic conditions who are also Qualified Medicare Beneficiaries. Its approximate reimbursement valuation for 2025 is $110 per month.

Service requirements

Each APCM code requires 13 service elements, some of which overlap with CCM or PCM services. Every service element must be available to patients, but not all service elements need to be provided each month. Here’s a simplified list of the service elements:

1. Patient consent
2. Initiating visit
3. Continuity of care
4. Alternative care delivery
5. Overall comprehensive care management
6. Patient-centered care plan
7. 24/7 access to care
8. Coordination of care transitions
9. Ongoing communication
10. Enhanced communication opportunities
11. Population data analysis
12. Risk stratification
13. Performance measurement

APCM and other care management services

The 2025 PFS final rule included a surprise reversal from its proposed rule: CMS said patients could receive APCM services at the same time as overlapping services, like CCM and PCM. However, these services must be medically necessary and delivered and billed by a practitioner not already furnishing APCM services for a patient.

Unlike CCM and PCM, CMS confirmed that remote patient monitoring (RPM) and remote therapeutic monitoring (RTM), as well as the three new care management services finalized in the 2024 PFS final rule — community health integration, principal illness navigation and social determinants of health risk assessments — “may complement” APCM services. In other words, these services can be billed on top of APCM by the same provider. This offers an interesting incentive for currently dual-enrolled RPM and CCM patients, as qualifying care management time can still be billed under the RPM care management codes while the patient is enrolled in ACPM.

Here is some quick math on what this could mean from a financial perspective. Consider a PCP with 500 Medicare patients each with two chronic conditions. Assume each dual-enrolled APCM/RPM patient takes the minimum required 16 device readings each month and receives 20 minutes of RPM care management time per month. Given 20 minutes of general care management time per patient, if the practitioner provided only APCM, they would generate monthly revenue of about $25,000 and annual revenue of about $300,000. If the practitioner can use those 20 minutes toward RPM care management, those figures increase to about $72,000 and $864,000, respectively.

There’s a lot to unpack with APCM, but what’s clear is that its current incarnation has little downside risk to PCPs, achieving CMS’ goal to deliver a win-win entry point for FFS providers to explore and become more comfortable with population-based structures. While APCM is entirely voluntary for now, PCPs may want to take steps to optimize their organization to align with the new APCM requirements and benefit from the opportunities this program and payment model presents.

Future of APCM: Advanced primary care hybrid payments?

CMS is already starting to look at the future of the APCM program. The agency has stated that the new APCM code set “could serve as a chassis to incorporate primary care model learnings” into primary care. CMS included a request for information (RFI) in the 2025 proposed rule on a new concept called advanced primary care hybrid payments. The RFI aimed to elicit feedback on the theme of moving the focus of primary care from evaluation and management (E/M) visits to value-based reimbursement and what other FFS services might be brought into a per-head APCM payment.

CMS did not finalize these payments in the final rule and expressed its appreciation for the feedback it received via the RFI. But it seems even more evident that CMS intends to use the new APCM model as a conduit to achieve its goal to grow population-based and value-based payments.

Virtual care changes

In the 2025 final rule, CMS finalized permanent coverage of two-way, real-time, audio-only telehealth services (i.e., telephone calls) with a caveat: “...any telehealth service furnished to a beneficiary in their home if the distant site physician or practitioner is technically capable of using an interactive telecommunications system but the patient is not capable of, or does not consent to, the use of video technology.”

This rule change is designed to enable providers to expand treatment services in rural and remote areas, which are more likely to have limited broadband and thus greater challenges with video communication. The permanent coverage is great news for patients who cannot access audio-video telemedicine, while giving providers the continued flexibility to use audio-only telehealth. The rule change also implies that the default should be audio-video unless there is a valid reason. Documenting the reason why telephone was used over videoconference is worthwhile until CMS provides more clarity on compliance.

Another positive development for virtual care in the 2025 final rule concerns “direct supervision.” During the COVID-19 public health emergency (PHE), CMS temporarily revised the definition of direct supervision to permit supervising physicians/practitioners to be readily available through virtual technology. In the final rule, CMS extended that waiver for all direct supervision services through 2025.

As a compromise past 2025, CMS finalized permanent allowance of virtual direct supervision for a subset of services, including any service for which the underlying HCPCS code has been assigned a professional component/technical component indicator of 5 (“incident to”) and outpatient E/M of established patients who do not require the presence of a physician.

This is a very narrow subset of services comprised mostly of injections, infusions and minor procedures. Notably missing from the list: annual wellness visits and preventive services. It will be interesting to see whether CMS expands its list in the 2026 rules.

RPM/CCM coding overhaul for FQHCs and RHCs

For the second year in a row, CMS finalized huge care management changes for FQHCs and rural health clinics (RHCs). The 2024 PFS final rule saw CMS adding RPM and RTM as services billable by FQHCs and RHCs under HCPCS G0511. RPM and RTM joined a host of other care management services (e.g., CCM, PCM, behavioral health integration [BHI]) already billable under G0511. G0511 could be billed multiple times per patient, per month based on the mix of services provided. This caused considerable program development and billing confusion.

In the 2025 PFS final rule, CMS broke up G0511 and is now permitting FQHCs and RHCs to use existing care management Current Procedural Terminology (CPT) codes to bill for RPM, RTM, CCM, BHI and other care management services. FQHC and RHC patients are more likely to need more care management time, but the current HCPCS coding scheme incentivized providers to limit services to no more than 20 minutes. Switching to CPT codes eliminates any pressure FQHCs and RHCs felt to expedite service delivery.

The CPT code valuations are at the national nonfacility Medicare payment rate. From a reimbursement perspective, the coding rule change means that when RPM and/or CCM is provided, there’s a lower billing floor for FQHCs and RCHs but a higher ceiling. All in all, the movement from HCPCS to CPT codes will improve care and help make billing easier, and should lead to a boost in revenue for the average program that nets out at higher times.

AMA’s RPM code expansion

The 2025 PFS final rule was far from the only big development impacting remote care management in the second half of this year. The American Medical Association (AMA) made waves with an announcement about RPM codes.

The AMA had considered a significant RPM code expansion in several of its CPT Editorial Panel meetings in 2024, culminating in approved changes during the September meeting. We do not have the full code definitions yet, but AMA released a “summary of panel actions” suggesting the following changes, effective January 2026:

• Adding an RPM device supply CPT (99XX4) code that covers two to 15 calendar days of collected and transmitted data. AMA is revising existing CPT 99454 to cover 16 to 30 days.
• Adding a new RPM treatment management services code (99XX5). Given the proposal, we suspect this code will allow for reimbursement when there has been between 10 and 20 minutes of care management time. Currently, reimbursement becomes available only after 20 minutes.

The new codes will go to the AMA’s Relative Value Scale Update Committee to set pricing and reimbursement metrics. Past that, we will need to see whether Medicare follows suit and provides coverage for the new codes. This would likely be the case with initial inclusion of the codes in the 2026 PFS proposed rule.

Key care management takeaways for 2025

What can we take away from all of this substantial care management activity? The 2025 final rule spent a significant amount of time contemplating and announcing a more concerted push toward accountable and value-based care. Releasing APCM codes is CMS putting the carrot first before tackling E/M bundling and other more disruptive changes that the agency wants to utilize to move away from FFS.

With the addition of APCM and changes to FQHC and RHC billing for care management programs, it’s clear that CMS is going all in on remote care management and will continue to promote growth and adoption of its services.

AMA’s approval of RPM code expansion is a key step toward making RPM more flexible for providers and patients alike, broadening potential applications and enhancing reimbursement opportunities. This approval also shows the ongoing commitment to remote monitoring.

Finally, with the COVID-19 PHE well behind us and adoption increasing, more high-quality studies are being done on RPM across a variety of use cases. The results are largely further demonstrating the significant clinical and financial value of RPM.

For 2025, practices and FQHCs would be wise to create a comprehensive remote patient care management program that supports patients utilizing a mix of the care management services that are best suited to their specific conditions and risks. This means leveraging a combination of APCM, RPM, CCM and any other applicable service. When executed effectively, organizations with these comprehensive programs should see notable improvements in patient health, engagement, access and satisfaction as well as growth in revenue at a time when reimbursement remains under increased pressure.

Daniel Tashnek, JD, is the co-founder of Prevounce Health, a health care software and services company that simplifies the provision of preventive medical services, chronic care management and remote patient management. Daniel is also a practicing health care attorney specializing in regulatory compliance, reimbursement, scope of practice and patient care issues.