Virtual Health Management & Reimbursement for More Than a Decade

evolution of telehealth and virtual care

The evolution of telehealth over the past decade has significantly advanced virtual care management, improving patient outcomes and expanding access to care. This article explores key milestones in that evolution, focusing on changes in reimbursement models. We begin with the introduction of transitional care management in 2013 and follow the progression through chronic care coordination, remote monitoring, and behavioral health integration—leading up to the 2025 updates in remote patient monitoring billing for rural health clinics (RHCs) and federally qualified health centers (FQHCs).

2013 – The Evolution of Telehealth and Virtual Care Management

In 2013, the Centers for Medicare & Medicaid Services (CMS) enabled the evolution of telehealth and virtual care management by introducing new transitional care management (TCM) codes. This was to contain costs and reduce 30-day re-hospitalization with reimbursement for care management and care coordination services. TCM codes 99495 and 99496 became effective on January 1, 2013.

The TCM codes allowed clinicians to bill for time spent coordinating care 30 days after a patient was discharged from a hospital or skilled nursing facility. Most importantly, physicians could leverage technology to enhance patient care coordination and continuity between acute care and outpatient settings. In addition, it paved the way for more clinician involvement with less risk of medical error and readmission. Physicians were required to contact the patient within two business days after discharge. 

2015 – The Evolution of Chronic Virtual Care Management Takes Hold

In 2015, the evolution of telehealth in virtual healthcare management evolved to address the needs of patients with long-term, chronic conditions. On January 1, 2015, Medicare introduced new chronic care management (CCM) codes. This meant clinicians could bill for non-face-to-face care coordination services for patients with multiple chronic conditions.

CMS outlined that CCM patients included those with two or more chronic conditions expected to last at least 12 months or until the death of the patient. The conditions must place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline. These frameworks and reimbursement structures encouraged healthcare providers to adopt virtual care solutions to improve outcomes for these complex patients.

2016 – The Evolution of Telebehavioral Health Through Collaborative Care

In 2016, CMS introduced the psychiatric collaborative care model. This allowed many more patients to access psychiatric expertise through virtual interdisciplinary telehealth collaboration. What sets the collaborative care model apart in integrating behavioral health services is its solid evidence base of positive outcomes, adherence to CCM principles, and focus on accountability and quality improvement.

Additionally, psychiatrists could be reimbursed for virtually consulting with primary care physicians and care managers to improve outcomes for patients with behavioral health conditions. Various mental health advocacy groups and organizations supported the integration in 2016. Specifically, the Psychiatric Substance Abuse and Mental Health Services Administration (SAMHSA) promoted collaborative care for its importance in addressing mental health within the broader context of the evolution of telehealth.

2018 – Virtual Behavioral Health Integration Evolves

Following the collaborative care model, more clinicians began virtually integrating behavioral health integration (BHI) services into primary care. In 2018, Medicare started to make payments for behavioral health integration services under CPT codes 99492, 99493, and 99494. Medicare allowed payment to physicians and non-physician practitioners for BHI services supplied to patients during a calendar month.

The integration and evolution of telebehavioral health received support and guidelines from CMS and SAMHSA. Evidence supports that incorporating behavioral health services into primary care is a key approach to enhancing outcomes for the millions of Americans living with mental or behavioral health issues. Qualifying patients were those with mental, behavioral health, or psychiatric conditions treated by the billing practitioner. It included substance use disorders that warranted BHI services. The diagnoses could be either pre-existing or made by the billing clinician.

2019 – Remote Patient Monitoring Codes Added

In 2019, CMS launched the new remote physiological monitoring (RPM) program and CPT codes that allowed physicians to be reimbursed for time spent monitoring patient key physiological metrics outside clinic settings between visits. RPM opened the door for more advanced virtual telehealth management of chronic and acute care conditions through digitally collected health data and analytics. Moreover, RPM aligns with CMS initiatives promoting value-based care and patient engagement in the evolution of telemedicine.

A 2023 study showed evidence of an uptake in RPM from 2019-2021. After examining Medicare Part B National Summary Data data files from January 2019 to December 2021, researchers found that new patients increased from 20,640 in 2019 to 90,149 in 2020 and 123,476  in 2021.

2020 – Principal Care Management Launches

Principal care management (PCM) codes debuted in 2020. The emphasis on strengthening primary care aligned with CMS’s commitment to promoting patient-centered telehealth care and improving overall healthcare quality. PCM covers disease-specific services in virtual care management for a single, complex chronic condition that puts a patient at risk of hospitalization, physical or cognitive decline, or death.

Qualifying patients must have one chronic high-risk condition expected to last at least three months. In addition, a patient must not be treated for other complex conditions. PCM enables more holistic virtual healthcare and telehealth management encompassing the breadth of a patient’s conditions and services.

2022 – Remote Therapeutic Monitoring Evolves

The paradigm shift in 2022 towards remote therapeutic monitoring was influenced by CMS guidelines and policies encouraging the use of technology to optimize therapeutic telehealth outcomes. Remote therapeutic monitoring (RTM) codes were released, allowing billing for the virtual delivery of physical, occupational, and speech therapies. RTM allowed patients to access more convenient treatments from home, supported by virtual monitoring and engagement in the evolution of telehealth.

Virtual healthcare and telehealth management evolved to provide continuous assessment and personalized interventions, aligning with CMS’s commitment to advancing patient care.

2023 – Chronic Pain Virtual Care Management Emerges

In 2023, chronic pain management CPT codes G3002 and G3003 were introduced to improve access to virtual pain care coordination and telemanagement. CMS developed virtual healthcare and telehealth management strategies for chronic pain to improve care experiences for individuals with chronic pain. In addition, the codes consider the time and resources furnished by clinicians. 

2024 – 2025 Telehealth and RPM Management

In 2024, CMS added Principal Illness Navigation (PIN) incident-to-services to the 2024 Physician Fee Schedule Final Rule by the Centers for Medicare & Medicaid Services (CMS). The 4 new service codes are for the services performed by a physician or billing practitioner under general supervision. Two of the codes are for PIN services and the other two codes for Principal Illness Navigation-Peer Support (PIN-PS) services. PIN services aim to deliver a person-centered approach that prioritizes unique individual needs and goals. Additionally, a key goal of PINS is to empower patients and caregivers to navigate the intricate healthcare landscape effectively for timely access to appropriate care and resources.

For the first time in 2025, FQHCs and RHCs can now bill the RPM CPT codes. This update expands access to remote monitoring services for underserved communities

2026 – 2027 Remote Monitoring Codes Expand for Shorter Episodes of Care

For most of its history, remote monitoring reimbursement rested on two thresholds: 16 days of transmitted data in a 30-day period, and 20 minutes of management time in a calendar month. Patients who improved quickly, used a device for only part of a month, or needed a short check after a medication change often fell below both. The CY 2026 Physician Fee Schedule final rule, effective January 1, 2026, added codes for those patients.

CMS finalized two new RPM codes. CPT 99445 covers device supply with daily recordings or programmed alert transmissions for 2 to 15 days in a 30-day period. CPT 99470 covers treatment management for 10 to 19 minutes in a calendar month, including at least one real-time interactive communication with the patient or caregiver. The existing codes stayed in place, and rates for 99454 and the rest of the family rose slightly with the 2026 conversion factor.

RTM received the same treatment plus a cleanup. Four new codes, 98984, 98985, 98986, and 98979, describe monitoring with fewer than 16 days of transmission and under 20 minutes of interactive communication per month. CMS also revised 98976, 98977, and 98978 to specify 16 to 30 days of data in a 30-day period, which settled a long-standing question about what those codes actually required.

Rural health clinics and federally qualified health centers moved fully into standard billing in 2026. G0511, the general care management code these sites had relied on, sunsetted on September 30, 2025. RHCs and FQHCs now report individual care management codes, and they can report RPM and RTM separately in the same month they report advanced primary care management when a patient receives both. CMS also added behavioral health add-on codes to APCM, extending collaborative care and behavioral health integration into the primary care payment structure that first took shape in 2016.

One more piece of 2026 belongs in any account of the evolution of telehealth. Medicare’s pandemic-era telehealth flexibilities lapsed on September 30, 2025 and again on January 30, 2026 before Congress extended them through December 31, 2027 and covered the gap retroactively. RPM and RTM are not telehealth services under Section 1834(m) of the Social Security Act, so they were never subject to those expiration dates. Programs built on remote monitoring kept billing and kept seeing patients throughout, which is worth weighing when a care team decides where to anchor a virtual care program.

This material is provided for general informational and educational purposes only and does not constitute legal, compliance, billing, coding, or reimbursement advice. CPT® codes, descriptions, and Medicare payment rates referenced here are drawn from publicly available sources, are subject to change, and may vary by payer, locality, and patient circumstances. Tenovi makes no representation or guarantee regarding coverage, payment, or the appropriateness of any code for a particular patient or service, and any presented are illustrative only. Providers are solely responsible for independently determining medical necessity and applicable coding, coverage, documentation, and billing requirements and for submitting accurate claims. Consult applicable payer guidance and qualified billing, coding, compliance, or legal professionals before making billing decisions. CPT® is a registered trademark of the American Medical Association.

What 2027 May Change

CMS published the CY 2027 Physician Fee Schedule proposed rule on July 16, 2026, and CMS proposes requiring a separately reportable initiating visit before monitoring begins, extending the established-patient requirement to RTM, limiting payment to clinical staff directly employed by the billing practice, and lowering practice expense valuations for device supply and management codes. The agency also asked for comment on consolidating the current RPM and RTM code set into four new G-codes.

Understanding the Evolution of Telehealth

As technology and policy enable more advanced and integrated forms of telehealth, possibilities increase for enhancing access, outcomes, patient experience, and clinician collaboration. As virtual care management evolved from transitional care in 2013 to chronic pain telemanagement in 2023, CMS played a crucial role in shaping the evolution of telehealth.

The ongoing collaboration between healthcare providers and regulatory forces is a key driver of innovation in the telehealth space. This collaborative effort has led to the establishment of telehealth accreditation and certification designations, which serve to distinguish qualified healthcare professionals and organizations from non-certified or non-accredited providers. These accreditation and certification programs enhance the reputation and credibility of qualified telehealth providers within the industry, further incentivizing continued innovation and adoption of telehealth technologies and services.

Tenovi provides chronic care, telehealth, and remote patient monitoring software and services companies with hardware and software solutions for real-time access to their patient’s health and billing data. Contact Tenovi today for a free demo and consultation.

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