Medicare 2026 Update: Key CMS Rule Changes Impacting Cardiac and Pulmonary Rehabilitation

CMS’s final rules for 2026 introduce several important updates that directly impact Cardiac Rehabilitation (CR), Intensive Cardiac Rehabilitation (ICR), and Pulmonary Rehabilitation (PR). These changes present both new opportunities and ongoing challenges for providers nationwide.

Permanent Virtual Supervision: A Major Step Forward

One of the most impactful updates is CMS’s decision to permanently allow virtual direct supervision of CR, ICR, and PR services by physicians and qualified non-physician practitioners. This applies to both hospital outpatient provider departments (HOPDs) and physician office-based programs. Programs may now use virtual supervision for in-person care delivery, and physician office-based programs may also deliver services via telehealth.

This change provides long-term flexibility for staffing and program operations—something many rehab programs have advocated for since the pandemic. From LSI’s perspective, permanent virtual supervision helps programs maintain continuity of care while adapting to workforce shortages and evolving care models.

Telehealth Coverage Expanded—With Limits

CMS also permanently added CR, ICR, and PR codes to the Medicare telehealth services list. However, this expansion applies only to physician office-based programs. These programs must use real-time, continuous audio-visual technology; phone-only or audio-only communication is not permitted.

Hospital outpatient departments are still not allowed to provide CR, ICR, or PR virtually under current statute. A legislative fix would be required to extend virtual delivery to HOPD programs—an issue LSI and industry partners continue to monitor closely.

Reimbursement Updates for 2026

CMS has implemented a small reimbursement increase across most service lines and locations for 2026. The exception is ORS Code G0239, which will see a slight decrease across all settings. While modest, these changes highlight the continued need for advocacy around fair and sustainable reimbursement, especially as programs face rising operational costs.

Clarifying the Role of Non-Physician Practitioners

The final rules reaffirm that non-physician practitioners—including nurse practitioners, physician assistants, and clinical nurse specialists—may provide direct supervision of CR, ICR, SET PAD, and PR services. However, they cannot order services, sign treatment plans, or serve as medical directors. CMS maintains that only physicians may establish, review, and sign individualized treatment plans, based on statutory language.

This distinction remains a key operational consideration for rehab programs, particularly those seeking to maximize clinical resources.

Key Differences Between CR and PR Billing

CMS continues to maintain notable distinctions between CR and PR billing. PR is limited to two Medicare-covered diagnoses: COPD and post-COVID-19. PR also carries a 72-session lifetime limit, in contrast to CR, which has no lifetime cap and allows up to 72 sessions per referral if medically necessary. Both CR and PR permit up to two billed sessions per day, with specific exercise requirements differing between the two.

Advocacy Remains Essential

Industry leaders, including AACVPR, are actively pushing for reforms such as allowing non-physician practitioners to order rehab services, restoring virtual delivery for hospital-based programs, eliminating PR’s lifetime session limit, and addressing reimbursement disparities.

At LSI, we believe these efforts are vital to expanding patient access and strengthening the future of cardiac and pulmonary rehabilitation. As regulations evolve, we remain committed to equipping rehab programs with the technology, education, and support they need to deliver life-changing care—today and into 2026 and beyond.