CMS Proposes 2026 Changes to RPM, APCM, DMHT, and More: What Digital Health Companies Need to Know
The 2026 Proposed Medicare Physician Fee Schedule (MPFS) has arrived, and it’s packed with significant developments for digital health companies—from shifting reimbursement pathways to evolving supervision rules, terminology updates, and the sunsetting of certain transitional codes. As always, CMS is soliciting public comment, and this rule presents a critical opportunity for innovators to help shape the regulatory and reimbursement landscape before it becomes final.
Below, we highlight key proposals with implications for digital health stakeholders, particularly those operating in remote monitoring, behavioral health, chronic care management, community health integration, and tech-enabled services for rural and underserved populations.
We’ll follow up in future posts with deeper dives into proposed changes related to Remote Monitoring (RPM and RTM), Digital Mental Health Treatment (DMHT), and integration of behavioral health into Advanced Primary Care Management (APCM), along with an overview of the CMS Request for Information (RFI) and additional specific solicitations for comments. But first, here’s an overview of what digital health companies need to know now.
New Device Supply and Treatment Management Codes for Remote Monitoring
Among the most notable updates in the 2026 Proposed Rule is CMS’s proposal to create two new device supply codes for remote monitoring services—one for Remote Physiologic Monitoring (RPM) and one for Remote Therapeutic Monitoring (RTM)—when 2 to 15 days of data are collected, expanding options beyond the current 16-day threshold. This reflects CMS’s recognition of clinical value in shorter monitoring periods and provides a new pathway for billing in scenarios where patients do not meet the 16-day requirement.
In addition, CMS proposes to create two new treatment management codes – one for RPM and one for RTM -- that allow billing for 10–19 minutes of time instead of the current 20-minute threshold.
Stay tuned for our upcoming post with a full breakdown of these changes and what they mean for digital health providers and vendors in the RPM and RTM space.
Digital Mental Health Treatment (DMHT): Contractor Pricing and ADHD Use Case
CMS has affirmed that contractor pricing will continue for the device supply code associated with digital mental health treatment—a decision that preserves flexibility but may result in variability in reimbursement rates across jurisdictions.
Notably, CMS has also proposed expanding DMHT reimbursement to include DMHT tools for ADHD. This may encourage broader adoption of DMHT tools for patients with attention disorders and creates a clear signal of CMS’s willingness to expand applicable mental health use cases and reimbursement opportunities.
More details to come in our DMHT-focused blog post.
RFIs and Solicitation for Comments
CMS has also included a Request for Information (RFI) on how to improve the prevention and management of chronic diseases in the Medicare population. Digital health companies are uniquely positioned to offer scalable, tech-enabled solutions in this space and should consider submitting comments.
We'll cover this RFI and its implications, along with specific information on several additional solicitations for comment, more thoroughly in an upcoming post.
Integrating Behavioral Health with APCM Services
In a major step forward for whole-person care for those in underserved communities, CMS is proposing to:
Create optional add-on codes for APCM services that would enable Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to bill for Behavioral Health Integration (BHI) and Collaborative Care Model (CoCM) services in tandem with APCM.
Require these clinics to report the individual codes that make up G0512 (the CoCM code) rather than billing G0512 itself. This unbundling move mirrors similar changes proposed elsewhere in the rule.
These updates could unlock billing opportunities for rural clinics currently offering behavioral health as part of their primary care model and drive better integration of mental and physical health care.
Payment for Communication Technology-Based Services (CTBS)
CMS is proposing that, beginning January 1, 2026, RHCs and FQHCs report individual codes (e.g., G2010, G2250, and CPT 98016) that currently make up HCPCS code G0071, which is being unbundled. This move aligns with CMS’s approach to promote transparency in how services are delivered and paid and ties into broader proposals around unbundling of care management codes.
Digital health companies supporting FQHCs and RHCs should be prepared to update billing logic and workflows to accommodate the shift to discrete codes.
Expanded Recognition of Auxiliary Personnel in CHI and PIN Services
CMS continues to clarify and expand the list of personnel eligible to furnish Community Health Integration (CHI) and Principal Illness Navigation (PIN) services. Under the 2026 proposal, Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) are now explicitly included in the definition of "certified or trained auxiliary personnel" eligible to perform CHI and PIN when supervised by an eligible billing practitioner.
Additionally, CMS proposes allowing certain behavioral health CPT codes—including 90791 (psychiatric diagnostic evaluation) and various Health Behavior Assessment and Intervention (HBAI) codes—to serve as initiating visits for CHI services. This is a meaningful change for behavioral health providers seeking to address social needs as part of whole-person care.
Reframing of CHI Code Language and Elimination of SDOH Risk Assessment Code
CMS is proposing to replace the term “social determinants of health” (SDOH) with the broader term “upstream driver(s)” in the CHI code descriptor. This shift acknowledges the complex web of environmental, behavioral, and systemic factors that affect patient outcomes and aligns more closely with evolving CMS language across programs.
Simultaneously, CMS proposes to delete HCPCS code G0136 for standalone SDOH risk assessments, citing overlap with other reimbursed services. Companies offering digital SDOH screening tools should review their billing strategies in light of this proposal.
Now’s the Time to Comment!
CMS is accepting public comments on the 2026 Proposed Rule now through midnight, September 12, 2025. For health innovators, this is a crucial chance to influence the future of digital health reimbursement.
Whether you’re a technology vendor, provider group, or investor, the Nixon Law Group team is here to help you understand what these proposals mean for your organization—and how to make your voice heard.
Contact us today for help drafting and submitting your comments or assessing the impact of these changes on your business model.