Home / CCM vs RPM
Chronic Care Management and Remote Patient Monitoring Compared
Chronic care management vs remote patient monitoring: what each pays for, who fits, and how to bill both.
Short answer: Chronic care management and remote patient monitoring are separate Medicare Part B services. CCM pays for care-plan work between visits for patients with two or more chronic conditions. RPM pays for device setup, data transmission and treatment management for an acute or chronic condition; one condition can qualify. Both can be billed in the same month when each meets its requirements and no time or effort counts twice.
Chronic care management and remote patient monitoring run on different clocks: CCM counts clinical staff minutes in a calendar month, while RPM counts days of device data in a 30-day period and treatment-management minutes in a calendar month (MLN909188; CY2026 final rule).
This guide sets the CMS rules side by side for the administrator or billing lead deciding whether to run one program or both.
TL;DR: CCM and RPM in four lines
CCM: two or more chronic conditions, a care plan, 20 minutes of clinical staff time a month for 99490.
RPM: an acute or chronic condition, an established patient and a medical device; the device codes need 2 or more days of data in 30.
Together: allowed in the same month if no time is counted twice.
Watch: a CY2027 proposal, not final, to limit RPM staffing to direct employees.
Chronic care management vs remote patient monitoring: the differences
Each row is the CMS rule as of October 2026.
| Rule | Chronic care management (CCM) | Remote patient monitoring (RPM) |
|---|---|---|
| The patient | Two or more chronic conditions expected to last at least 12 months or until death, with significant risk | An acute or chronic condition, monitoring medically reasonable and necessary |
| Before it starts | Initiating visit if new or not seen by the billing practitioner within a year | An established patient relationship |
| What is paid for | Care-management time: care plan, medications, coordination | Set-up and education, device supply, treatment-management time |
| Equipment | None; core data in certified EHR technology and an electronic care plan | An FDA-defined medical device that uploads data automatically |
| Threshold | 20 minutes for 99490; 99439 per further 20 | Device codes: 2 to 15 or 16 to 30 days of data; treatment management: 10 or 20 minutes |
| Period | Calendar month | 30 days for device codes; calendar month for treatment management |
| Consent | Once, before CCM starts, with four disclosures; again if the billing practitioner changes | May be obtained when RPM services are first provided |
| One practitioner | Per calendar month | Per patient per 30-day period |
| Who bills | Physicians, NPs, PAs, clinical nurse specialists, certified nurse-midwives | Physicians and practitioners eligible to provide evaluation and management services |
| Who furnishes the time | Clinical staff under general supervision; external clinical staff allowed if incident-to rules are met | Auxiliary personnel under general supervision; a CY2027 proposal, not final, would require direct employees |
RPM and CCM billing in the same month
A practitioner may bill RPM or RTM, but not both, alongside CCM for the same patient in the same month if no time or effort is counted twice (CY2024 final rule; MLN909188). The full list of codes that can share a CCM month is in the CCM billing guide.
Same-month checks for a patient in both programs
One log: every activity is tagged to one code.
Two clocks: RPM device codes run on 30-day periods, CCM on calendar months; record both sets of dates.
Mixed calls: ask your Medicare Administrative Contractor how it expects one call covering both programs to be documented.
When a patient fits chronic care management and remote patient monitoring
For a patient with hypertension and diabetes who sends home blood pressure readings, both programs may fit when every code requirement is met:
- Device supply: 99445 or 99454, based on days of data in the 30-day period.
- RPM treatment management: 99470 or 99457 for reviewing readings and adjusting treatment, including live, interactive communication.
- CCM: 99490 for at least 20 separate clinical staff minutes on medication review and coordination.
- One call, one time count: a 15-minute call goes to RPM or CCM, never both (CY2026 final rule; MLN909188).
- Several long-term conditions, no device plan. CCM alone: the month is calls, medication review and coordination against a care plan.
- One high-risk condition managed from home readings. RPM, and principal care management can run in the same month if no time counts twice (CY2024 final rule). The codes are in PCM codes 99426 and 99427.
- A second chronic condition appears. Once the patient meets the CCM test, CCM can replace PCM alongside RPM.
Who qualifies for CCM and who qualifies for RPM
CCM needs two or more chronic conditions expected to last at least 12 months or until death that place the patient at significant risk of death, acute exacerbation or decompensation, or functional decline; CMS’s examples include hypertension, diabetes, COPD and cardiovascular disease, and the full list is in the guide to what conditions qualify for chronic care management (MLN909188). A patient with one high-risk chronic condition does not qualify for CCM but may fit principal care management (MLN909188).
RPM, which CMS calls remote physiologic monitoring, needs an acute or chronic condition, monitoring that is medically reasonable and necessary, and an established patient relationship (MLN901705). CMS’s example metrics are oxygen saturation, blood pressure, blood sugar and weight.
Its companion, remote therapeutic monitoring (RTM), captures non-physiological data, which can be self-reported, such as musculoskeletal or respiratory status and treatment adherence, and does not require an established patient relationship (MLN901705).
CCM and RPM CPT codes and time requirements
CCM codes: 99490 and 99439, counted in staff minutes
99490 requires at least 20 minutes of clinical staff time per calendar month, directed by a physician or other qualified health professional, with a comprehensive care plan established, implemented, revised or monitored. 99439 adds each further 20 minutes; submit the claim once the threshold is met (CY2022 final rule; CMS CCM FAQ). This comparison focuses on these two codes; the CCM CPT codes guide covers their limits.
RPM codes: 99453, 99445, 99454, 99470, 99457 and 99458
| Code | Service | Threshold |
|---|---|---|
| 99453 | Initial device setup and patient education | At setup |
| 99445 | Device supply | 2 to 15 days of data per 30-day period |
| 99454 | Device supply | 16 to 30 days of data per 30-day period |
| 99470 | Treatment management | First 10 minutes per calendar month |
| 99457 | Treatment management | First 20 minutes per calendar month |
| 99458 | Additional treatment management after 99457 | Each additional 20 minutes |
Choose either 99445 or 99454 for a 30-day period, and either 99470 or 99457 for the first treatment-management minutes. Treatment-management codes require live, interactive communication with the patient or caregiver; it contributes to the time but need not fill it. 99445 and 99470 are new for 2026 (CY2026 final rule; MLN901705).
Consent and the initiating visit for CCM and RPM
- Consent: obtain written or verbal consent before CCM starts, after the four required disclosures, and document it. Obtain consent again only if the billing practitioner changes.
- Initiating visit: required for a new patient or one the billing practitioner has not seen within a year; this is separate from consent.
- Billing: without consent, neither Medicare nor the patient can be billed (MLN909188; CMS CCM FAQ).
CMS requires patient consent at the time RPM services are provided, and it may be obtained when they are first provided (MLN901705). For CY2027, CMS proposed requiring a separately reportable initiating visit at the onset of RPM or RTM (CY2027 proposed rule).
Who can furnish CCM and RPM, and the CY2027 RPM staffing proposal
Under the CY2026 rules, a practitioner may arrange for CCM clinical staff external to the practice, such as a case management company, when every incident-to and CCM rule is met; with little oversight or no clinical integration, CMS says CCM should not be billed (CMS CCM FAQ). Under the same rules, auxiliary personnel may furnish RPM under the general supervision of the billing practitioner (MLN901705).
For CY2027, CMS proposed paying for RPM and RTM only when clinical staff are direct employees of the practitioner or practice. If finalized, the proposal would exclude contracted RPM and RTM staff from January 1, 2027; it does not name CCM.
CMS separately requested comments on care management supervision without proposing a change. Both items remain pending; the CY2026 rules govern 2026 (CY2027 proposed rule).
Staffing chronic care management
Companian does not offer remote patient monitoring. Your team refers; we handle enrollment, outreach and documentation. You bill monthly under your license.
The chronic care management service page explains the practice’s next step. Only clinical staff or billing-practitioner time counts toward the clinical-staff CCM and PCM codes (MLN909188).
Key takeaways
- One qualifying condition can support RPM but never CCM; a single high-risk condition may fit PCM.
- 99445 and 99470 are new for 2026: RPM device supply can be billed from 2 days of data, and treatment management from 10 minutes.
- RPM or RTM, one of them, can share a month with CCM or with principal care management (CY2024 final rule).
- CCM consent is obtained once, and again only if the billing practitioner changes; RPM consent may be obtained when RPM services are first provided.
- The CY2027 RPM staffing proposal is not final and names RPM and RTM only; CMS asked for comment on care management supervision without proposing a change.
Questions about CCM and RPM
Can you bill RPM and CCM in the same month?
Yes. CMS lets a practitioner bill RPM or RTM, but not both, alongside CCM for the same patient, as long as no time or effort is counted twice. The same rule lets RPM run alongside principal care management for a patient with one high-risk condition.
Does a patient need two chronic conditions for remote patient monitoring?
No. RPM requires an acute or chronic condition and an established patient relationship. The two-condition test belongs to CCM.
Is RPM part of chronic care management?
No. They are separate Medicare Part B services with their own codes, consent rules and time counts, billed alongside each other rather than as one program.
How many days of readings does RPM require in 2026?
For the device-supply codes, at least 2 days in a 30-day period: 99445 covers 2 to 15 days and 99454 covers 16 to 30, and only one is billed per period. CMS says the days-of-data rule does not apply to treatment-management codes 99457 and 99458.
What is the difference between CCM and RPM?
CCM is for a patient with two or more chronic conditions who needs care-plan work between visits, and it uses no device. RPM is for a patient whose acute or chronic condition is managed from home readings, and it starts with an FDA-defined medical device. CCM counts staff minutes per calendar month; RPM device codes count days of data per 30 days.
What kind of device does RPM require?
One that meets the FDA definition of a medical device under section 201(h) of the Federal Food, Drug, and Cosmetic Act. It must collect data electronically and upload it automatically for the billing practitioner to review.
CCM and RPM are separate Medicare Part B services. CCM counts care-management time per calendar month; RPM counts device-data days per 30-day period and treatment-management time per calendar month. Companian does not offer RPM.
Sources
- CMS, Chronic Care Management Services (MLN909188), June 2025
- CMS, Frequently Asked Questions about Practitioner Billing for Chronic Care Management Services, August 2022
- CY 2022 Physician Fee Schedule final rule (86 FR 64996)
- CY 2024 Physician Fee Schedule final rule (88 FR 78818)
- CMS, Telehealth and Remote Monitoring (MLN901705), December 2025
- CY 2026 Physician Fee Schedule final rule (90 FR 49266)
- CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P), July 16, 2026
- CMS fact sheet, CY 2021 Physician Fee Schedule final rule
Read more: PCM codes 99426 and 99427 explained · CCM billing: how a care management month becomes a claim
Start with a 15-minute intro
See how Companian runs chronic care management for practices nationwide. Your practice bills Medicare under its own NPI.