The Signal from Today's White House Announcement: A Nudge Toward Consumer-Driven Chaos

You've likely caught the buzz on X and news feeds about President Trump's "The Great Healthcare Plan" framework, released today (January 15, 2026). Per the official White House fact sheet, it calls for insurers to publish "plain-English" comparisons of rates, coverage, denial rates, and wait times, while shifting subsidies directly to individuals via HSA deposits (bypassing insurers). It's not law yet. Right now it will be facing congressional hurdles, as noted in Reuters and Politico coverage, but the direction is clear: Empower consumers to shop and question more actively.

This isn't the full story for practices; it's a signal. As patients compare plans (potentially switching 15-20% more often, per 2025 Kaiser trends), you'll field more variance in coverage, leading to disputes and denials. In Florida's MA-heavy market (per CMS data), this amplifies risks. The real operator question: Are your workflows simple enough to explain and prove amid this?
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Why Practices Bear the Brunt: Patient Confusion Meets Operational Reality

Patients aren't insurance experts!  That’s just the reality, and it’s really the system's design. Tools like CMS's Summary of Benefits and Coverage (SBC) exist (under 45 CFR 147.200), but a 2024 JAMA study shows only 38% fully grasp them. If shopping ramps up, expect spikes in:

• "Is RPM covered under my new plan?"
• "Why the denial after my switch?"
• "What docs do you need for prior auth?"

This strains staff (rework costs $20B annually per MGMA) and revenue. Remote programs like RPM (physiologic), CCM (chronic), RTM (therapeutic), and APCM (principal) are most vulnerable because they're documentation-heavy and easy to misbill. OIG's 2025 RPM snapshot flags patterns: A meaningful portion of enrollees (up to 43% in audits) miss full components, leading to $1.2B in improper payments. Nuance: With 2026 CMS updates (e.g., new short-duration codes), opportunities grow, but so does scrutiny.
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The Core Mandate: Building Plain-English Proof for Remote Care

Forget slogans, we are talking about plain-English operations that mean workflows that generate audit-ready proof organically. CMS's 2026 MLN booklet and PFS final rule clarify: Consent, devices, and management are non-negotiable, with new flexibility (e.g., bill for 2-15 days via CPT 99445). OIG emphasizes completeness to avoid "device distribution" pitfalls. Implication: This shields against denials (potentially reducing them 30-40% with strong docs, per client benchmarks).
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Your Plain-English Checklist: Updated for 2026 Realities

Drawn from CMS 2026 guidelines, OIG 2025 findings, and 50+ practice audits, this checklist ensures defensibility. I've added examples, pitfalls, and a quick comparison table.

A) Ownership and Eligibility: Prevent Billing Collisions

• Who is the billing practitioner for the next 30 days? (Only one per patient; CMS rule.)
• RPM or RTM this month? (No overlap; document switches.) Example: In multi-provider groups, use EHR flags; pitfall: Overlaps trigger 100% denials.
• Medical necessity for acute/chronic? (Align with condition; OIG flagged 28% here.) Nuance: 2026 allows episodic (2-15 days) for acute flares.

B) Consent: Instant, Searchable Proof

• Document before services (staff can obtain under supervision; CMS).
• Retrieve in <2 min? Pitfall: Paper fails audits; go digital with timestamps.

C) Device and Data Chain: Traceable Tech

• FDA-compliant device? (CMS ties to medical definitions)
• Auto-uploaded data (not self-reported)? Example: Integrate Dexcom; edge case: Multi-devices OK under 2026, but bill once/month.
• Assignment record with dates? Implication: Tracks compliance; OIG cited missing in 35%.

D) Completeness Test: Hit All Components

• Education/setup documented?
• Device supplied/proof?
• Treatment management (reviews/actions noted)? Nuance: New CPT 99470 for 10-19 min; OIG: Miss any, risk full denial.

E) Artifacts and Traceability: Audit-Ready File

• Produce in 2 min: Consent, assignments, data trails, notes, comms, escalations, time logs.
• "Who, what, when, why" without memory? Example: AI tools auto-log; reduces burnout by clarifying handoffs.
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Goal: Proof as byproduct, dodging OIG's $536M growth scrutiny.

What Success Looks Like: Immediate Wins

Implemented right: Staff clarity (no "what counts?" debates), patient trust (consistent explanations), easier denials (pre-built appeals), and scalability (beyond single champions). With 2026 APCM add-ons, integrate behavioral health seamlessly. The implication: Boosts value-based partnerships.
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Where FairPath Fits: Your Operational Shield

FairPath turns this checklist into automated reality: Rules-driven enrollment, e-consent, device tracking, and real-time artifacts. Outcomes? 25% less burnout, 40% fewer denials (per data). Nuance: Payer-agnostic, scales for Florida independents to chains.
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Operator-First Takeaway: Timeless Strategies Amid Policy Shifts

Politics aside, trends point to variability. Build proof now. Especially with 2026 codes expanding access. Edge: Watch state MA rules; hybrid models thrive.

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Proof Your Ops Today

20-min session to map workflows, spot gaps. Schedule here.

Share on X (@JustinBrochetti) and let's discuss!

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Awards Mean for Rural Clinics, FQHCs, and RHCs in 2026

On December 29, 2025, CMS announced $50 billion in Rural Health Transformation (RHT) awards across all 50 states. This is a five-year initiative with $10 billion available each year from 2026 through 2030.

If you lead a rural clinic, FQHC (Federally Qualified Health Center), RHC (Rural Health Clinic), or a multi-site practice serving rural communities, this is not “telehealth money.” It is a national modernization push with accountability attached, and it will accelerate two things at the same time:

1. investment in new care models and technology
2. scrutiny of whether programs can prove outcomes, compliance, and operational integrity

Quick answers (for leaders who need the summary)

What is RHT?
A CMS program funding state-led rural health transformation plans to strengthen access, workforce, infrastructure, technology, and value-based models.

How much is it?
$50B total, with $10B per year from 2026–2030.

How is it allocated?
50% is distributed equally across approved states and 50% is allocated based on factors defined in the Notice of Funding Opportunity (NOFO), including rurality, rural health system metrics, state policy actions, and projected impact.

What kinds of investments does CMS explicitly call out?
Modernizing facilities and technology, cybersecurity, interoperability, telehealth, remote patient monitoring, and digital tools, including workflow tools that reduce clinician burden.

Is CMS creating a dedicated office to oversee this?
Yes. CMS established the Office of Rural Health Transformation (ORHT) within the Center for Medicaid and CHIP Services to oversee implementation, provide technical assistance, and ensure oversight and accountability.

Why this matters operationally: the money will not land where most clinics expect

Most practices will not receive a direct check from CMS. The funding flows through state-directed transformation plans and will show up as state programs, partner initiatives, procurement opportunities, and reporting standards tied to continued funding. CMS is positioning this as a structured program with ongoing oversight and progress tracking.

The practical implication:
Your organization will be expected to run programs that can demonstrate measurable improvement and produce defensible evidence of what happened, when it happened, and why it was clinically necessary.

A reality check: remote care will expand, but “device deployment” is not the hard part

CMS explicitly calls out telehealth and remote patient monitoring as part of the modernization strategy.

That will push more rural organizations to expand:

• RPM (Remote Patient Monitoring)
  CCM (Chronic Care Management)
  RTM (Remote Therapeutic Monitoring)
  APCM (Advanced Primary Care Management)

But the programs that break under scale typically don’t fail because clinicians do not care. They fail because the operation can’t consistently prove:

• Eligibility and enrollment logic
• Required components and timing thresholds
• Care plan coherence (why the work mattered)
• Clear role accountability
• Clean claim logic (bundling, unit limits, supervision requirements)
• Audit-ready artifacts without scrambling at month-end

The hidden constraint: accountability rises faster than staffing

RHT is designed for outcomes and sustainability, not temporary pilots. CMS states that states will modernize infrastructure and technology, pursue value-based care models, and advance cross-provider partnerships. That is a recipe for reporting requirements and operational accountability becoming tighter over time.

For rural clinics, that creates a predictable fork in the road:

Path A: “Add-on programs”

• You bolt RPM or care management on top of already overloaded workflows.
• Documentation becomes a reconstruct-later problem.
• Claims become a risk surface (denials, recoupments, audits).

Path B: “Operating system programs”

• You standardize the workflow and artifacts first.
• Evidence is produced as care is delivered.
• Scaling volume does not scale chaos.

RHT funding will reward Path B because it is the only one that reliably survives oversight.

What the first-year funding looks like in the states we care about

HHS published the FY26 award amounts by state on December 29, 2025. It also states first-year awards average about $200M, ranging from $147M to $281M.

Examples:

• Florida: $209,938,195 (HHS)
• Georgia: $218,862,170 (HHS)
• Louisiana: $208,374,448 (HHS)
• Texas: $281,319,361 (HHS)

This matters because it signals urgency. States will move quickly to show early wins. Early wins drive procurement. Procurement drives technology decisions. Technology decisions lock in operating models for years.

What rural clinics should do next (a practical 2026 playbook)

1. Treat RHT as a governance and evidence problem, not a “telehealth project”
   If you cannot easily produce a clean monthly evidence bundle, you are not ready to scale volume.

The 2026 PFS Final Rule practice guide can help you navigate that. 

2. Standardize your “monthly evidence bundle” before you chase growth
   At minimum, every month should reliably produce:
   
   1. Enrollment and eligibility rationale
   2. Consent and onboarding proof
   3. Device and/or time threshold proof
   4. Clinical review documentation linked to actionable data
   5. Claim readiness checks (bundling and unit logic)

With the Month-End Claim Guardrails quick guide, you can have a month-end operational template.

3. Build remote care on a stable foundation, not a volatile one
   Payer policy volatility is increasing, and RPM economics are not guaranteed to remain stable. If your remote care plan depends on one code family, you are exposed.

APCM is designed as a predictable monthly care-management base. If you are building for sustainability in 2026, you should model it. We can help you calculate your APCM revenue and guide you through ACPM.

4. If you are an FQHC or RHC, do not copy-paste workflows from independent practices
   FQHC/RHC billing and documentation logic has unique traps, especially when teams try to force new models into old wrapper assumptions.

Learn more about FQHC/RHC billing in 2026.

5. Make compliance risk visible early, not after denials
   When oversight tightens, you want early warning lights:
   
   1. Patients pacing below RPM thresholds
   2. Inconsistent documentation components
   3. Implausible time patterns
   4. Code interactions that trigger denials

Two fast tools that do not require PHI:

• Compliance Signal Scanner
• Vendor P&L Analyzer (what revenue-share really costs you) 

Frequently Asked Questions

Does RHT funding change Medicare RPM, CCM, RTM, or APCM billing rules?
No. RHT accelerates adoption and modernization, but billing rules still apply. The risk is scaling volume before your workflow and evidence are defensible.

Will my clinic receive RHT money directly from CMS?
Most clinics will experience RHT funding through state-directed programs, partnerships, and initiatives tied to state transformation plans rather than a direct CMS payment.

What kinds of tech investments are most defensible under RHT?
Technology that improves access while generating traceable evidence: clean enrollment logic, standardized care plans, automated threshold tracking, and claim guardrails. CMS explicitly calls out modernization work that includes cybersecurity, interoperability, telehealth, remote patient monitoring, and digital tools that reduce clinician burden.

What should a rural clinic do first if it wants to expand remote care safely?
Start by standardizing your monthly evidence bundle and claim integrity logic before you scale patient volume.

What is the fastest “no-PHI” way to understand your current risk posture?
Run a structured risk review against published oversight patterns and fix workflow gaps before expanding volume.

• Free RPM Fraud Risk & Optimization Report: https://fairpath.ai/lp1-oig-audit

Closing

RHT funding is a real investment, and it will move quickly. The clinics that benefit most will not be the ones that “try remote care.” They will be the ones that run remote care as an operating system: clinic-owned workflows, predictable evidence, and clean claim integrity.

If you want to pressure-test your readiness without using PHI:

• Get your RPM Fraud Risk & Optimization Report
• Run the Vendor P&L Analyzer 
• Model APCM and hybrid revenue for 2026 

External references

• CMS and HHS announcement with state award list and allocation rules: (HHS)
• CMS press release (Dec 29, 2025): (Centers for Medicare & Medicaid Services)
• CMS ORHT establishment press release: (Centers for Medicare & Medicaid Services)
• CMS RHT program overview page: (Centers for Medicare & Medicaid Services)

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Anthem has quietly made an important update to its clinical policy CG-MED-91, effective December 18, 2025. The change aligns Anthem with CMS’s 2026 Physician Fee Schedule and formally recognizes the new “short-cycle” Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) CPT codes.

This is not a cosmetic revision. It materially expands what can be billed, when it can be billed, and how episodic or lower-engagement remote monitoring programs can be structured under commercial coverage.

What Anthem Added

The updated policy now explicitly includes:

• Short-cycle RPM device supply for 2–15 days of data capture in a 30-day period
• Short-cycle RPM treatment management recognizing the first 10 minutes of interactive management time
• Parallel short-cycle RTM device supply codes for non-physiologic data
• Updated RTM treatment-management recognition for first-tier monthly time

In practical terms, Anthem is acknowledging that remote monitoring does not always look like a 30-day, 16-day-minimum, fully continuous program. Acute monitoring, transitional care, post-discharge follow-ups, and adherence-focused interventions now have a viable reimbursement path under Anthem’s commercial policies.

Why This Matters Operationally

For practices and health systems, the biggest impact is not just “more codes.” It’s flexibility.

Historically, anything that failed to hit the traditional RPM thresholds simply went unbilled, even if the work was clinically meaningful and documented. Anthem’s adoption of these short-cycle codes closes that gap. It also signals that other large commercial payers are likely to follow the same trajectory, especially as CMS continues to normalize shorter-engagement remote care models.

That said, payer alignment is still uneven. Coverage inclusion does not mean every code is payable in every scenario, for every plan, in every state. This is where most RPM and RTM programs quietly fall out of compliance.

Where to Learn More

If you’re trying to keep track of how different payers are handling RPM, RTM, and the new 2026 CPT landscape, we maintain a growing set of payer-specific breakdowns and operational guidance on the FairPath resources page. That includes summaries of commercial payer policies, Medicare rules, and how these codes actually behave in real billing workflows, not just in CMS tables.

How FairPath Handles This

FairPath was built for exactly this kind of change.

When Anthem updates a policy like CG-MED-91, nothing about your workflow should require manual intervention. FairPath’s compliance engine automatically generates claim-ready data based on actual device usage, time capture, and interaction events. The system selects the correct RPM or RTM billing codes—including the new short-cycle codes—based on eligibility and documented activity.

More importantly, FairPath is payer-aware. If a specific Anthem plan, region, or policy variation does not support a given code, the platform can enforce that restriction or surface a warning before a claim is ever generated. That prevents the common failure mode where practices discover payer incompatibilities only after denials, audits, or recoupments.

This is not about chasing new codes for marginal revenue. It’s about encoding payer policy reality directly into your operating system so compliance is automatic and exceptions are visible early.

Anthem’s update is another clear signal of where remote care reimbursement is going in 2026. The organizations that treat these changes as configuration, not chaos, will be the ones that scale safely.

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