An RPM and telehealth program build is the work of writing the operating program for a new remote patient monitoring or telehealth service: the program description, policies, workflows, forms and training your staff will run it on. It is for organizations launching a remote patient monitoring or telehealth program. Integral Healthcare Solutions (IHS) drafts the program, policies and clinical content for your clinicians to review and approve, and maps each document to the CMS remote monitoring and telehealth requirements that apply to your service.

Last reviewed: October 2026.

What is an RPM and telehealth program build?

It is the build of a program, measured against the rules your service will run under. For Medicare, those rules sit in four places IHS works from:

• The CY 2026 Physician Fee Schedule final rule (Federal Register document 2025-19787, published November 5, 2025), which added two remote patient monitoring codes: "For CY 2026, the CPT Editorial Panel created two new RPM codes to describe RPM services that describe less than 16 days of data transmission per 30-day period and less than 20 minutes of interactive communication per month: CPT codes 99445 and 99470" (Federal Register, 2025-19787).
• CMS MLN booklet MLN901705, "Telehealth & Remote Monitoring" (December 2025), which summarizes the remote monitoring billing rules (MLN901705).
• The Medicare telehealth regulation at 42 CFR 410.78 (eCFR, current text).
• The CMS Telehealth FAQ, updated February 26, 2026 (CMS Telehealth FAQ).

MLN901705 sets out the operating rules a remote monitoring program has to be built around. Among them:

• "Remote physiologic monitoring, but not RTM, requires an established patient relationship" (p. 13).
• For remote physiologic monitoring: "You must collect data for 2–15 or 16+ days out of 30 days, depending on the code descriptor (doesn't apply to treatment management codes 98980, 98981, 99457, and 99458)."
• "Only 1 practitioner can bill for remote monitoring per patient in a 30-day period."
• "We require patient consent at the time you provide RPM services" and "The device used to collect and transmit the data must meet the definition of a medical device defined by FDA."
• "Auxiliary personnel can provide remote monitoring services under the general supervision of the billing practitioner."

Source for each item above: CMS MLN901705, December 2025.

For telehealth visits, 42 CFR 410.78(a)(3) defines the equipment: "Interactive telecommunications system means, except as otherwise provided in this paragraph (a)(3), multimedia communications equipment that includes, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner" (42 CFR 410.78).

State telehealth, licensure and practice law is outside this page. IHS identifies the state provisions your counsel should read; it does not summarize them here.

Who needs it and what triggers it

Organizations launching a remote patient monitoring or telehealth program need the program written before the first patient is enrolled. The common triggers, each tied to a CMS text:

• Starting to bill Medicare for remote monitoring. Each claim depends on rules the program has to enforce every month: data days per 30-day period, one billing practitioner per patient per 30 days, consent and an FDA-defined device (MLN901705).
• Adopting the 2026 code set. The CY 2026 final rule added codes 99445 and 99470 for fewer data days and less interactive time (Federal Register, 2025-19787). Programs built before 2026 may need their workflows and logs rewritten to capture those thresholds.
• Moving work to clinical staff. When auxiliary personnel do the monitoring, the program needs a written supervision structure, because CMS ties that work to "the general supervision of the billing practitioner" (MLN901705).
• Planning telehealth past 2027. CMS states: "Through December 31, 2027, beneficiaries can receive Medicare telehealth services anywhere in the United States and territories. Starting January 1, 2028, except for behavioral health services, beneficiaries will generally need to be in a medical facility and in a rural area to receive Medicare telehealth services" (CMS Telehealth FAQ, Q1, updated 2/26/26).

How IHS helps

IHS drafts the program, policies and clinical content for your clinicians to review and approve. The process:

1. Gap assessment against the governing texts above and any others you name, including your payer contracts.
2. Questionnaires that collect your operating facts: population, conditions monitored, devices, roles, hours and escalation.
3. Document and evidence mapping: a crosswalk from each CMS requirement and each state requirement you name to the policy, form, log or record that meets it.
4. Drafting the program description; policies and procedures for enrollment and eligibility, consent, device issue and return, data review, alert response and escalation, documentation, privacy and security, and billing-rule controls; workflows from referral to discharge from the program; forms (consent, enrollment, device agreement, monitoring log, escalation record); and staff training material. Each clinical document carries an approval line for your medical leaders, and any fact only you can supply is marked as an open item.
5. Mock review of the drafted program against the governing texts, before launch.
6. Readiness support: a launch work plan and training material for the staff who will run the program.

What you supply

Your service model, device vendor contracts, staffing and supervision plan, the states where your patients are, screenshots of your EHR and monitoring platform, and access to your counsel for state-law and licensure questions.

Who decides what

Your medical leaders set the clinical protocols, alert thresholds and escalation rules, and approve every clinical document. Your billing staff own code selection and claims.

The limit

IHS does not select devices, configure platforms, submit claims or give a legal opinion on state law.

What to have ready

None of this has to be finished before you call. Each item ties to the CMS text that makes it matter.

• Your service model: RPM, remote therapeutic monitoring (RTM), telehealth visits, or a mix. MLN901705 treats RPM and RTM differently (MLN901705, December 2025, p. 13).
• How you will confirm an established patient relationship before RPM enrollment (MLN901705, p. 13).
• Your current consent process and where consent is recorded, since CMS requires "patient consent at the time you provide RPM services" (MLN901705).
• Vendor documentation for each device, since it "must meet the definition of a medical device defined by FDA" (MLN901705).
• How your platform counts days of data in each 30-day period (2–15 or 16+ days, by code) (MLN901705).
• How you will confirm that no other practitioner bills remote monitoring for the same patient in the same 30-day period (MLN901705).
• Your staffing plan, naming the billing practitioners and the auxiliary personnel they supervise (MLN901705).
• The 2026 remote monitoring codes your billing staff expect to use, including whether 99445 and 99470 apply (Federal Register, 2025-19787).
• For telehealth visits, the audio and video equipment you will use, measured against 42 CFR 410.78(a)(3) (eCFR, current text).
• Where your Medicare telehealth patients will be located after December 31, 2027 (CMS Telehealth FAQ, updated 2/26/26).

Bring whatever you have to the introductory call; the gaps on this list are where the build starts.

How it compares

Building the program, reviewing an existing program's compliance, and seeking accreditation are separate pieces of work. Organizations do them in different orders.

See also the Program Development practice line.

What it costs

URAC does not publish a fee schedule on the pages we reviewed; fees depend on scope. IHS scopes each engagement after a free introductory call.

What this is not

• This page is not legal advice, and IHS gives no opinion on state telehealth or licensure law. Your counsel does.
• IHS does not select devices, configure platforms or submit claims, and does not promise payment of any claim.
• IHS does not file anything with CMS, URAC, ACHC or any state agency. IHS drafts; your organization adopts the program, runs it and files.

Frequently asked questions

What has to be in place before we start billing Medicare for remote patient monitoring?

CMS MLN901705 (December 2025) lists conditions that include an established patient relationship for remote physiologic monitoring, patient consent at the time of service, a device that meets FDA's medical device definition, and, for remote physiologic monitoring, data collected for 2-15 or 16+ days out of 30, depending on the code descriptor. Only one practitioner can bill remote monitoring per patient in a 30-day period. The program's policies, forms and logs are how your staff show each of those on every claim.

Which RPM codes apply in 2026, and what changed with 99445 and 99470?

The CY 2026 Physician Fee Schedule final rule, published November 5, 2025, states that the CPT Editorial Panel created two new RPM codes, 99445 and 99470, for RPM services with less than 16 days of data transmission per 30-day period and less than 20 minutes of interactive communication per month. Your billing staff choose the codes; the program's monitoring log has to capture the day counts and minutes those codes depend on.

Do we need an established patient relationship before enrolling a patient in RPM?

For remote physiologic monitoring, yes. MLN901705 states that remote physiologic monitoring, but not remote therapeutic monitoring, requires an established patient relationship. The enrollment procedure IHS drafts includes a step that records how that relationship was confirmed.

How do we document patient consent for RPM?

CMS states that it requires patient consent at the time you provide RPM services. IHS drafts a consent form and a consent procedure that say who obtains consent, when, and where it is recorded. Your clinical leaders approve both, and the record location is set to fit your EHR.

Who on our staff can perform RPM work, and under what supervision?

MLN901705 states that auxiliary personnel can provide remote monitoring services under the general supervision of the billing practitioner. IHS drafts a roles and supervision section that names which staff do which tasks and which practitioner supervises them. Your medical leaders decide the assignments.

What makes a device acceptable for Medicare RPM?

CMS states that the device used to collect and transmit the data must meet the definition of a medical device defined by FDA. IHS does not select devices. The program's device policy records how your organization confirms that each device meets that definition, using documentation from your vendor.

How long do the Medicare telehealth flexibilities last, and what changes on January 1, 2028?

The CMS Telehealth FAQ, updated February 26, 2026, states that through December 31, 2027, beneficiaries can receive Medicare telehealth services anywhere in the United States and territories. Starting January 1, 2028, except for behavioral health services, beneficiaries will generally need to be in a medical facility and in a rural area. A program built now can include a dated review step for that change.

How do we set alert thresholds and escalation rules, and who approves them?

Your medical leaders set the clinical thresholds and escalation rules. IHS drafts the alert response and escalation procedure and the escalation record, with the thresholds left as marked fields for your clinicians to fill in and approve.

What is the difference between building the program and getting it accredited?

The build writes the program a new service runs on. Accreditation, such as URAC Telehealth Accreditation, reviews an existing program against the accreditor's standards. IHS covers accreditation on separate pages; this page covers the build.