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CMS ACCESS Model and Remote Patient Monitoring

ACCESS and Remote Patient Monitoring (RPM) both involve device-based, technology-supported care — but they are billed under entirely different mechanisms and shouldn't be conflated.

How Remote Monitoring May Fit Into ACCESS

CMS's description of ACCESS technology-supported care explicitly includes "use or monitoring of Food and Drug Administration (FDA)-authorized devices, including devices or software, or devices that are subject to FDA enforcement discretion." A participating ACCESS organization may use connected devices and patient-generated data as one component of the broader chronic-care activity tied to its Outcome-Aligned Payment.

The Difference Between the ACCESS Payment Model and RPM Billing

RPM is billed under specific CPT codes (99453/99454/99457/99458) tied to device setup, 16-day data transmission, and monitoring time, and can be billed by any qualifying practice furnishing that monitoring. ACCESS is a separate, broader outcome-based payment to a participating organization, tied to achieving measurable health outcomes across its technology-supported care as a whole — not to specific monitoring minutes or data-transmission days. A practice should not assume ACCESS participation changes how RPM itself is billed, or that RPM billing alone satisfies ACCESS's outcome requirements.

Connected Devices

CMS gives wearable devices that "continuously monitor sleep, heart rate, movement, blood sugar and other functions" as an example of the kind of technology ACCESS organizations may use — consistent with, but not identical to, devices used for separately-billed RPM.

Patient-Generated Data

Data from connected devices or patient-reported outcome measures can inform whether a patient is meeting the outcome targets tied to ACCESS's Outcome-Aligned Payments (e.g., biomarkers like blood pressure or HbA1c, or validated PROMs of pain, mood, and function).

Alerts

CMS's published ACCESS materials describe care escalation as one of three key update points shared with primary care (alongside initiation and completion) when a patient's clinical needs change — the specific alerting mechanics are determined by each participating organization's own technology, not standardized by CMS in the pages reviewed for this guide.

Outcomes

Under ACCESS, payment is tied to the share of patients meeting defined outcome targets — a fundamentally different accountability structure than RPM's per-code billing for monitoring activity performed.

Frequently Asked Questions

The CMS materials reviewed for this guide don't address this specific combination — confirm current same-period billing rules with CMS or your coding advisor before billing both for the same patient.

No. ACCESS is an outcome-based payment model for participating organizations; RPM has its own separate CPT billing codes. They are not interchangeable.

CMS describes FDA-authorized devices or software as one example of technology-supported care activity, without mandating a specific device or vendor.

Official Resources

Medicare rules and reimbursement may change. This page was last reviewed on September 30, 2026.

This tool and page are provided for educational and planning purposes only and do not constitute legal, coding, billing, financial, or medical advice. Medicare and payer requirements can change. Practices should verify current requirements and reimbursement with CMS, their Medicare Administrative Contractor, payer, coding advisor, or compliance professional.

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