Medicare Open Enrollment runs from October 15 to December 7, and the plan a patient selects takes effect on January 1. For practices running Remote Patient Monitoring (RPM) and care management programs, that date is an operational deadline, not a marketing moment.
A patient who moves between Original Medicare and a Medicare Advantage plan, or between two Medicare Advantage plans, may carry a different deductible, different cost sharing, a different network, and different prior authorization requirements into the new year.
The clinical program does not have to stop. The billing pathway behind it can change overnight. This article covers what changes, what does not, and what care teams should verify before the first January claim is submitted.
Oct 15 to Dec 7 Medicare Open Enrollment. Coverage selected here starts January 1. | $283 2026 annual Part B deductible set by CMS. It resets every January 1. | Jan 1 to Mar 31 Medicare Advantage Open Enrollment. Coverage can change a second time. |
What Medicare Open Enrollment Means for RPM Programs
During Medicare Open Enrollment, a beneficiary can join, drop, or switch a Medicare Advantage plan, move between Original Medicare and Medicare Advantage, and add or drop Medicare drug coverage.
According to Medicare.gov, the plan must receive the request by December 7, and the new coverage starts January 1.
RPM and care management services are Part B services. They do not disappear when a patient changes plans. What changes is who pays, under what rules, and with what documentation.
Where the risk concentrates Eligibility files that still show last year’s payer. Device supply periods that straddle the calendar change. Care management time logged under a plan the patient no longer holds. |
Does RPM Continue When a Patient Switches to Medicare Advantage
Yes, in most cases the service continues, but the payer and the rules behind it change. Medicare Advantage plans are required to cover the items and services that Original Medicare covers, so RPM remains a covered benefit category.
Each plan may apply its own network requirements, prior authorization policies, and cost sharing. Those can differ from what the patient had before the switch.
| What to check | Original Medicare | Medicare Advantage |
|---|---|---|
| Who pays the claim | Medicare Administrative Contractor under the Physician Fee Schedule | The plan, under its own payment policy |
| Prior authorization | Not applied to RPM or care management services | May apply to device supply, management time, or the ordering practitioner |
| Patient cost sharing | Part B deductible, then coinsurance | Set by the plan, often a copayment |
| Network rules | Any practitioner who accepts Medicare | In-network status of the ordering practitioner matters |
| Supplemental benefits | Not applicable | May cover related items with separate documentation requirements |
RPM is used to monitor patient physiologic data that the care team reviews on a defined schedule. It is not a substitute for in-person care, and it is not emergency care. Patients are not monitored around the clock.
Setting that expectation clearly at enrollment helps when a patient changes plans and asks what the new card does and does not cover.
Codes That Commonly Appear in a Plan Transition
In the CY 2026 Physician Fee Schedule final rule, the Centers for Medicare & Medicaid Services (CMS) recognized shorter-duration options alongside the established RPM codes.
| Code | Component | Threshold |
|---|---|---|
| CPT 99453 | Setup and patient education | One time per episode of care |
| CPT 99454 | Device supply | 16 or more days in a 30-day period |
| CPT 99445 | Device supply, shorter duration | 2 to 15 days |
| CPT 99457 and 99458 | Treatment management time | First 20 minutes, then each additional 20 minutes |
| CPT 99470 | Treatment management, shorter duration | 10 to 19 minutes |
The shorter-duration codes are useful in a transition month, when a device supply period or a management interval is cut short by a coverage change.
They are also easy to misapply, since the longer and shorter options describe the same service at different thresholds. Documentation of transmission dates and management minutes is what separates a clean claim from a denial.
How Chronic Care Management (CCM) Coverage Changes When Patients Switch Plans
CCM (CCM) is a separate program from RPM, with its own consent, its own time thresholds, and its own codes, including CPT 99490 and the add-on CPT 99439.
RPM and CCM are not interchangeable. They are distinct programs with distinct consent, documentation, and billing requirements. A patient enrolled in one is not enrolled in the other, and a plan change is evaluated separately for each. |
Advanced Primary Care Management (APCM), billed with HCPCS codes G0556, G0557, and G0558, is stratified by patient complexity rather than by logged minutes.
When a patient changes plans, the stratification assumption should be re-checked against the new plan’s eligibility data. The chronic condition count and dual-eligible status that drove the original code selection may be recorded differently by the new payer.
Consent is the item most often overlooked. A patient’s consent to care management is documented in the medical record, and a change of payer does not erase it. What does change is the cost sharing the patient will see, which is a conversation worth having in December rather than in February.
What Happens to Deductibles and Cost Sharing on January 1
Deductibles reset at the start of the calendar year. For 2026, CMS set the annual Part B deductible at $283 and the standard Part B monthly premium at $202.90.
CMS announces the following year’s figures in the fall, so the 2027 amounts should be confirmed against the CMS release rather than carried forward.
For patients in Original Medicare, RPM and care management services apply toward the Part B deductible and then carry coinsurance. For patients in a Medicare Advantage plan, cost sharing is set by the plan and may take the form of a copayment instead.
A January deductible reset is also the most common reason a care management program sees a sudden drop in patient participation. Patients who receive an unexpected statement sometimes disengage before anyone on the care team knows there was a question.
How Prior Authorization and Network Rules Affect Remote Monitoring in 2027
Prior authorization is the operational difference most practices feel first. Original Medicare does not apply prior authorization to RPM or care management services. Medicare Advantage plans may.
The requirement can attach to the device supply component, the management component, or the ordering practitioner’s network status.
Effective January 1, 2027 Medicare’s 2027 guidance for beneficiaries notes that Medicare Advantage plans may process prior authorization requests electronically. Electronic processing can shorten turnaround time. It does not remove the requirement, and the request still has to be submitted before the service is furnished. |
Network status deserves a separate check. A patient who moves to a plan that does not include the ordering practitioner may remain clinically enrolled in a monitoring program while the claims for it fall out of network.
Verifying the practitioner’s participation in the new plan is a faster check than appealing the denials that follow.
What Changes a Patient Can Still Make After December 7
December 7 is not the last opportunity of the year. Medicare.gov describes a Medicare Advantage Open Enrollment Period from January 1 to March 31 for people who are already in a Medicare Advantage plan.
During that window, a patient can switch to a different Medicare Advantage plan or return to Original Medicare and join a separate Medicare drug plan. Coverage starts the first of the month after the plan receives the request.
For a monitoring program, that means coverage can change twice in a single quarter. Special Enrollment Periods, which apply to circumstances such as a move or a change in other coverage, can shift a patient’s plan at other points in the year as well.
Programs that re-verify eligibility monthly rather than annually absorb these changes with far less rework. A quarterly cycle will usually catch a January 1 change in February, after the first claims have already been filed.
What CMS Has Proposed for Remote Monitoring in the CY 2027 Physician Fee Schedule
In the CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P), CMS proposed several changes to remote monitoring policy:
- A separately reportable face-to-face initiating visit for practitioners who report RPM or Remote Therapeutic Monitoring (RTM).
- Limits on billing when the service is furnished by an outside company rather than the practice’s own clinical staff.
- Updated valuations for the device supply codes.
- A request for information on consolidating the remote monitoring code set.
These are proposals. As of this writing, CMS had not released the CY 2027 final rule, and nothing in the proposed rule changes how a practice bills today. |
The reason it belongs in an Open Enrollment discussion is sequencing. A practice re-verifying eligibility and consent this winter is doing the same groundwork it would need if the staffing and initiating-visit provisions are finalized.
What Care Teams Should Verify Before January 1
A short verification pass in December resolves most of what causes January denials. The four items below are the ones that most often change when a patient’s plan changes.
1. Eligibility and plan identification Re-run eligibility in late December and again in the first week of January. Record plan name, plan type, and effective date, not only the member identification number. | 2. Prior authorization requirements For each plan in the panel, confirm whether device supply, treatment management, and care management require authorization, and whether a prior authorization carries over. It usually does not. |
3. Device supply periods that cross the year Identify patients whose 30-day device supply period spans December and January. Document transmission dates precisely so the correct code is selected for each period. | 4. Consent and documentation Confirm consent is documented for each program, that the patient understands the cost sharing structure under the new plan, and that the ordering practitioner participates in it. |
How DrKumo Supports Care Teams Through Coverage Transitions
DrKumo is a healthcare technology company. It does not provide clinical services, make clinical decisions, or determine coverage. DrKumo supports provider-led programs with secure, HIPAA-compliant technology solutions for RPM, using medical devices as defined by the FDA, so that the clinical team retains responsibility for reviewing patient data and deciding what happens next.
During a coverage transition, the work that matters is record keeping: which patient is enrolled in which program, when device data was transmitted, how much management time was logged, and what the patient consented to.
DrKumo’s technology solutions support that documentation for RPM and for CCM as separate programs with separate records, and supports adherence to provider-led Disease Management Protocols. Practices serving rural communities, Federally Qualified Health Centers, and Rural Health Clinics face the same January reset with thinner administrative staffing, which is where organized documentation matters most.
Key Takeaways
| 1 | Medicare Open Enrollment runs October 15 to December 7, and the selected plan takes effect January 1. |
| 2 | RPM and care management remain covered Part B service categories after a plan change, but the payer, cost sharing, network, and prior authorization rules may be different. |
| 3 | RPM and CCM are separate programs with separate consent, documentation, and codes. A plan change affects each on its own terms. |
| 4 | Deductibles reset January 1. CMS set the 2026 Part B deductible at $283. Confirm the 2027 figure against the CMS release. |
| 5 | A patient already in a Medicare Advantage plan can change again between January 1 and March 31, so eligibility should be re-verified monthly. |
| 6 | CMS has proposed changes to remote monitoring policy in the CY 2027 Physician Fee Schedule proposed rule. They are proposals and are not in effect. |
| 7 | DrKumo is a technology provider and is not a clinical entity. RPM supports monitoring only and does not replace in-person or emergency care. |
TALK TO DRKUMO To learn how DrKumo supports secure, HIPAA-compliant RPM and care management documentation through coverage changes, contact us today. Our team is ready to support your organization’s planning for the January 1 transition.
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Frequently Asked Questions
Does RPM stop if a patient changes Medicare plans
No. RPM remains a covered Part B service category, and Medicare Advantage plans must cover the services Original Medicare covers. What changes is the payer, the cost sharing, the network, and whether prior authorization applies. The clinical program can continue while the billing pathway is re-verified.
Do we need new patient consent after a Medicare plan change
Consent for RPM or care management is documented in the medical record and is not erased by a change of payer. The cost sharing the patient will see can change, so practices often re-confirm the patient’s understanding of cost at the start of the new plan year.
What happens to a 30-day device supply period that crosses January 1
The device supply code is selected based on the number of days data was transmitted within the applicable period. CPT 99454 applies to 16 or more days and CPT 99445 applies to 2 to 15 days. Precise transmission dates determine which code fits each period when a coverage change splits it.
Can a Medicare patient change plans again after December 7
Yes. A patient already enrolled in a Medicare Advantage plan may switch plans or return to Original Medicare between January 1 and March 31, with coverage starting the first of the month after the plan receives the request. Special Enrollment Periods can also apply at other times.
Are CCM and RPM affected the same way
No. CCM and RPM are separate programs with separate consent, time thresholds, and codes. A plan change is evaluated separately for each, and enrollment in one program does not imply enrollment in the other.
References
- Centers for Medicare & Medicaid Services. Joining a plan. Medicare.gov.
- Centers for Medicare & Medicaid Services. 2026 Medicare Parts A & B Premiums and Deductibles. CMS Newsroom.
- Centers for Medicare & Medicaid Services. CY 2026 Payment Policies Under the Physician Fee Schedule, 90 Fed. Reg. (Nov. 5, 2025).
- Centers for Medicare & Medicaid Services. CY 2027 Payment Policies Under the Physician Fee Schedule, Proposed Rule (CMS-1848-P), 91 Fed. Reg. (July 16, 2026).
- Centers for Medicare & Medicaid Services. Your Medicare in 2027: What’s New & Changing. Medicare.gov.
Disclaimer: This article is intended for informational purposes only and does not constitute medical, legal, or billing advice. Coverage, coding, and payment rules change, and determinations are made by the applicable payer. Always consult a licensed healthcare provider for guidance on diagnosis, treatment, or medical decisions, and consult qualified billing or legal counsel for coverage and compliance questions. DrKumo is a healthcare technology provider and is not a clinical entity. References to the Centers for Medicare & Medicaid Services (CMS) and the Food and Drug Administration (FDA) do not constitute or imply an endorsement by CMS, the FDA, or the U.S. Government.
