Richardson, TX – August 4, 2026 – Last month, the Centers for Medicare & Medicaid Services released its Calendar Year 2027 Physician Fee Schedule proposed rule, and remote monitoring programs immediately felt the impact. The proposals would reshape how practices bill, staff, and get paid for remote patient monitoring and remote therapeutic monitoring starting next year.
The changes would put an end to the widespread practice of outsourcing clinical monitoring work to outside vendors if they were approved mostly as written. Only clinical staff employed by the billing practitioner or practice could perform the billable portions of these services. Practices could still buy devices, software platforms, connectivity and technical support from outside partners. However, the clinical review, patient outreach, and treatment-management time would need to remain within the practice.
CMS is also proposing a separately reportable initiating visit before RPM or RTM can begin. The service must be discussed during that visit. The federal agency wants to extend the established-patient requirement that already applies to RPM so it covers RTM as well. Both moves aim to tighten the link between remote monitoring and an ongoing clinical relationship.
Payment rates are under pressure too. CMS plans to revalue several device-supply and treatment-management codes. The net result could be lower reimbursement for setup, device supply, and ongoing management. CMS is also asking for public comment on whether the current family of RPM and RTM codes should eventually be replaced by four bundled G-codes. But it has not yet proposed adopting those codes for 2027.
These proposals did not appear out of nowhere. Two recent Office of Inspector General reports documented rapid growth in Medicare RPM spending alongside troubling patterns. They found cases where patients did not receive all the required RPM services and providers billed for patients they had little or no prior relationship with. The report also mentions multiple providers billing the same patient. CMS is responding by trying to keep remote monitoring clinically grounded rather than purely transactional.
The changes will affect practices that built their programs around contracted monitoring companies. Some practices may need to hire or assign their own nurses or care coordinators to manage remote patient monitoring services. They may also need to update their workflows and strengthen documentation to meet Medicare requirements. Those that already employ their monitoring staff and integrate the data into the broader care plan will face less disruption.
Chronic Care Management and Advanced Primary Care Management are left untouched. Practices that run blended care-management programs can continue using contracted staff for those services.
Nothing changes for the rest of 2026. Current billing rules stay in effect. The comment period closes September 14, 2026 and a final rule is expected around November. Any finalized policies would take effect January 1, 2027. Organizations that have feedback or concerns about the proposed changes also have an opportunity to submit comments to CMS before the final rule is issued.
The best approach right now is to prepare instead of panic. Review your current RPM or RTM program to understand who is responsible for each clinical and administrative task and whether those team members are employed by your practice or an outside vendor. Take a close look at your vendor agreements and documentation to ensure everything aligns with current Medicare requirements. It is also a good idea to estimate how potential reimbursement changes could affect your program’s costs and revenue.
Remote monitoring still holds real value when it is tied to an actual care plan and meaningful clinician oversight. The 2027 proposals simply raise the bar on how that connection must be structured and documented.
Note: This article reflects CMS’s CY 2027 PFS proposed rule as of July 2026. Current RPM/RTM rules and payment rates remain in effect until the final rule is issued and takes effect, currently proposed for January 1, 2027.
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