Telehealth / Remote Care Coding: 2026 Updates, Challenges, and Practical Tips

Telehealth / Remote Care Coding: 2026 Updates, Challenges, and Practical Tips for medical coders, compliance professionals, and clinicians. Use this as a reference or checklist—always confirm with final CMS/payer rules and local policies before implementation.

The COVID-19 pandemic prompted sweeping changes to telehealth regulations and reimbursement. Over the intervening years, many of those flexibilities were extended, refined, or made permanent. As 2026 approaches, new proposals and guideline shifts suggest further evolution in how telehealth (and adjacent remote services like RPM/RTM) must be coded, documented, and justified.

This blog reviews the major telehealth changes proposed (or likely) for 2026, discusses implications for coding and billing, and offers tips to prepare your organization for the transition.

Key Proposed & Anticipated Changes for 2026

Below is a summary of the most important telehealth- and remote care–related proposals in the 2026 Medicare Physician Fee Schedule (PFS) proposed rule and associated guidance. These may or may not be finalized as written, but they reflect the direction the industry is heading.

Coding & Documentation Considerations Under the New Paradigm

As these changes evolve, coders and billing staff must adapt to ensure claims remain compliant and maximize reimbursement. Below are recommended considerations and “watch-outs”:

Continue Using Traditional E/M Codes + Modifiers

Despite evolving telehealth, CMS is not proposing the adoption of new “telemedicine E/M” codes (e.g., 98000–98015) under Medicare. Instead, telehealth visits will continue to use standard in-person E/M codes (99202–99215, etc.) with the appropriate modifiers (e.g,. 95, or perhaps others) to denote telehealth delivery.

Thus:

• Use the usual E/M code levels (based on history, exam, medical decision-making or time).

• Append the modifier for telehealth (e.g., 95, or as required).

• Use the correct Place of Service (POS) (e.g., POS 02 for telehealth, or whatever CMS requires).

• Document modality (audio-video vs audio-only), technical limitations, and patient consent.

Audio-Only / Telephone-Only Visits

CMS has allowed some audio-only telehealth (or telephone) services in certain behavioral health or other permitted settings. That flexibility may continue or expand.

But be careful:

• Audio-only may require a specific modifier (e.g., “93”) or other qualifier, depending on the payer.

• Not all services are eligible for audio-only delivery (e.g., supervision or certain procedures may require video).

• Document why the video was not used (e.g,. patient limitation, technical issues).

RPM / RTM Coding Rules & Transitions

As new RPM/RTM codes are proposed, you’ll need to:

• Understand exactly when to use the new shorter-duration device codes (2–15 days) vs existing 16+ day codes (99454).

• Map time interaction codes correctly (e.g., new 10–20 min vs existing 20-min thresholds).

• Avoid double-billing or overlap: check bundling rules, global periods, or supervisory constraints.

• Verify medical necessity documentation: remote monitoring must be justified in the patient’s care plan, with appropriate physician oversight and interventions based on data.

• Keep an eye on device and software valuation: CMS expresses concern about how to value digital tools and “apps” in cost inputs.

Supervision / Incident-to Contexts

With virtual direct supervision allowed, practices using incident-to or shared visit models must:

• Ensure supervision is synchronous with real-time audio-video when required.

• Confirm regulations for global procedures, resident supervision, and metropolitan vs rural constraints.

• Document that the supervising provider was “virtually present” in real time during the service (when allowed).

• Be aware of services exempt from supervision flexibility (some global procedures may still require physical presence).

Teaching Physician / Resident Documentation

If your system involves resident-provided care:

• In many areas, a teaching physician may be required to be physically present for key portions of care (per pre-pandemic rules) unless in rural settings.

• Document which portions the teaching physician did (e.g., review of chart, plan, patient discussion) in accord with CMS’s teaching physician rules.

• Ensure your workflows reflect when telehealth-based supervision is permitted vs disallowed.

Documentation Essentials

To support telehealth claims, documentation should (at a minimum) include:

• Modality details: that the service was furnished via interactive audio-video (or audio-only, if allowed) and the platform used (HIPAA-compliant tool, if required).

• Patient’s location (originating location) and, if relevant, whether it qualifies (e.g., patient home, rural area, facility).

• Consent: documentation that the patient agreed to receive telehealth services and understands limitations.

• Technical limitations: note connectivity problems or reasons for inability to use video (if audio-only).

• Medical necessity/rationale: justification for why telehealth was appropriate vs an in-person visit (especially for higher-risk patients).

• Supervision statements: when supervising virtually, note that the supervising physician was present via real-time video and specify what oversight was done.

• Time (if using time-based billing) or relevant details supporting the level of service chosen.

Policy / Payer Variability & Contract Review

Although these changes focus on Medicare, many commercial and other payers will closely watch CMS’s final rule. Some key tips:

• Track which payers adopt new codes (e.g., RPM shorter-duration) and which stick with current ones.

• Understand each payer’s rules for modifiers, audio-only, telehealth list, and supervised service models.

• Update provider and coding manuals, practice management software, and claim-edit logic to accommodate new telehealth rules.

• Educate providers and coders well in advance of a 2026 launch so they are comfortable with the new paradigms.

Tips for Preparing Your Practice / Coding Team

Here are strategic steps to get ready for the 2026 telehealth + RPM changes:

• Monitor Final Rule Publication and Transition Dates
  The proposals discussed here are based on the 2026 PFS proposed rule. The final rule may adjust or reject certain elements. Once the final rule is released (likely in late 2025), compare and incorporate changes.

• Gap Analysis & Workflow Mapping
  Map your current telehealth and RPM workflows (from patient scheduling, consent, tech setup, documentation, and billing). Identify areas that will need modification e.g., supervision, use of new RPM codes, new allowable services.

• Update Billing & EHR Systems
  Work with your practice management / EHR vendors to ensure the system can accept new codes, modifiers, POS options, supervision flags, and telehealth logic.
  Preconfigure claim edits or flags to catch invalid combinations (e.g., disallowed supervision, missing modifiers).

• Training & Education
  Conduct training sessions with clinicians, coders, billing staff, and compliance teams on new rules, documentation requirements, and use cases. Use mock charts and scenarios to simulate new telehealth visits.

• Policy & Procedure Updates
  Revise your telehealth policies, supervision policies, consent forms, documentation checklists, and audit protocols to reflect 2026 changes.

• Pilot & Test Claims
  Before full roll-out, submit a few test claims (or “shadow claims”) under new coding rules to check for denials, system rejections, or payer behavior. Use payer feedback to refine your approach.

• Audit & Quality Assurance
  Establish internal audits to ensure telehealth claims are compliant (e.g., correct modifiers, documentation, supervision). Use feedback loops to catch errors early and re-educate.

• Engage Stakeholders & Leadership
  Keep practice leadership, compliance, and IT teams aligned. Telehealth coding changes may require resource investments (software updates, training time, audit staffing). Justify those via risk mitigation and reimbursement gains.

Challenges & Risk Areas to Watch

• Final Rule Differences: Because the 2026 rule is still “proposed,” some elements (esp around valuation, supervision limits, and new codes) may change.

• Payer Adoption Lags: Commercial payers may not adopt CMS’s changes immediately (or may adopt differently). You may need parallel coding paths for different payers.

• Denials During Transition: New or unfamiliar codes often trigger denials or payment delays. Be ready with appeals strategies and documentation support.

• Software / System Delays: Vendor updates (billing systems, EHRs) may lag, causing mismatches or claim rejections.

• Provider Compliance & Behavior: Clinicians may under-document or misapply supervision rules; strong education and oversight is essential.

• Bundling & Conflict Rules: Watch for conflicts between new telehealth or RPM codes and existing ones, global procedures, or overlapping services.

• Valuation Uncertainty: CMS’s methodology for valuing digital tools, software, or apps may evolve, affecting reimbursement.

• Regulatory Oversight & Audits: With more telehealth, payers and CMS may increase scrutiny of telemedicine claims and supervision documentation.

Sample Use Cases & Hypotheticals

Below are a few illustrative examples (not exhaustive) showing how the 2026 changes might play out in coding and billing:

• Use Case A: Post-op Critical Care via Telehealth
  Under current rules, you might have faced limits on how many critical care consultations via telehealth you can bill. With the frequency caps removed, you might provide multiple telehealth critical care consults (CPT 99291/99292) during a patient’s stay, subject to medical necessity and documentation.

• Use Case B: RPM for Short Duration (7 days)
  A patient needs close follow-up for a 7-day physiologic monitoring period. Under the proposed 2026 rules, you may use a new device code (e.g., proposed “99XX4”) rather than being forced to meet a 16-day minimum, making the RPM program more flexible.

• Use Case C: Teaching Physician Supervision in a Metro Area
  In a major urban hospital, a resident conducts a telehealth evaluation. Under proposed rules, the teaching physician may not be allowed to supervise remotely (in metropolitan regions). The practice must ensure physical presence during critical portions or adjust staffing to comply.

• Use Case D: Behavioral Health Group Psychotherapy
  A clinician provides multiple-family group psychotherapy via telehealth using CPT 90849 (if added). This formerly non-telehealth service can now be coded and billed via telehealth (assuming the service is accepted and the modality rules are met).

The 2026 telehealth and remote care coding landscape promises to shift in meaningful ways, offering greater flexibility, broader service eligibility, and refined RPM billing. However, with opportunity comes complexity: new codes, supervision rules, documentation requirements, and payer variability will demand careful preparation.

To thrive:

• Stay ahead by monitoring final rule publication.

• Map and revise your workflows now.

• Train providers and coders.

• Update your systems and audit processes.

• Be ready for a transition period with some trial, denial handling, and adjustment.

2026 Medicare Physician Payment Schedule and Quality Payment Program Proposed Rule Summary 

Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule (CMS-1832-P)