The 2027 Medicare Physician Fee Schedule Proposed Rule: A Remote Care Preview

** Upcoming Webinar: Join Daniel Tashnek, JD, on July 30 at 2 PM ET for a live breakdown of the 2027 PFS Proposed Rule, its impact on care management, and a chance to have your questions answered live. Reserve your seat here  → **

Every July, CMS releases its proposed rule for the coming year's Medicare Physician Fee Schedule (PFS). For organizations running remote care management programs, it's required reading. This year's release is expected within weeks. 

No one knows what's in it. But the 2026 final rule left behind a clear paper trail — open questions, formal comment solicitations, and unfinished policy work. Here's where we're focused. 

Will CMS Expand APCM Billing Codes and Scope in the 2027 Physician Fee Schedule?

Advanced primary care management (APCM) launched in 2025, and CMS has added to it every year since. The 2026 final rule introduced three optional behavioral health integration (BHI) add-on codes — G0568, G0569, and G0570 — allowing FQHCs to bill APCM and BHI services for the same patient in the same month.

For 2027, the more telling signal is an RFI CMS included in the 2026 rule on APCM and prevention. The agency asked how APCM should interact with preventive services, what participation barriers it could address, and what structural refinements would extend the program's reach. The National Academies of Sciences, Engineering, and Medicine responded with formal recommendations, which suggests the conversation has moved beyond the exploratory stage.

Based on that RFI and CMS's established pattern with this program, 2027 is a reasonable year to expect further structural additions: additional add-on codes, adjustments to complexity tier definitions, or changes to billing requirements that lower the administrative bar for participation. The behavioral health integration model CMS used in 2026 — optional add-ons rather than bundled requirements — may be the template for what comes next.

The Annual Wellness Visit: Toward a Better Integration With APCM?

The Medicare annual wellness visit (AWV) is a covered, no-cost-sharing benefit with persistently low utilization. CMS acknowledged this in the 2026 rule and asked whether AWV components should be unbundled into optional add-ons, letting providers spend less time on elements that don't apply and more on what's relevant to the patient in front of them.

More relevant for care management practices: CMS asked whether the AWV should more explicitly function as an on-ramp to APCM enrollment. The AWV already qualifies as an initiating visit for APCM, but the RFI suggests CMS is considering whether that relationship should be reinforced through payment design rather than simply permitted by policy.

In practical terms, this could mean payment mechanisms that reward practices for using the AWV as an entry point into ongoing care management, or structural changes that make the AWV-to-APCM pathway more visible and administratively straightforward. If 2027 brings movement here, practices that have already built out APCM programs are better positioned to benefit, and practices that haven't may find the AWV a useful starting point.

RPM and RTM Reimbursement: Expect Continued Refinement

Remote physiologic monitoring (RPM, commonly called remote patient monitoring) and remote therapeutic monitoring (RTM) saw meaningful change in 2026. CMS introduced CPT 99445, a new short-duration RPM code billable when 2–15 days of device data have been transmitted in a 30-day period. It adjusted the initial management time threshold from 20 minutes to 10 minutes with the introduction of CPT 99470. It also shifted the valuation methodology for device supply codes from practice expense invoices to outpatient prospective payment system (OPPS) cost data.

That last change is the one to watch for 2027. OPPS-based valuation for RPM and RTM supply codes is new, and the methodology will require refinement as it encounters the realities of how these programs operate outside hospital outpatient settings. CMS included a formal comment solicitation on RPM and RTM valuation in the 2026 final rule, which is a direct invitation for input on where the codes go next.

New codes are possible — CMS surprised us with CPT 99445 — but incremental refinement is more probable. The more substantive question for 2027 is whether CMS addresses the tension between the new short-duration flexibility (99445 covers 2–15 days) and program structures that have been built around the 16-day transmission threshold. How CMS resolves that in valuation terms will affect how practices design monitoring programs going forward.

CCM: Participation Obstacles and the Overlap with APCM

Chronic care management (CCM) is the most established remote care management program in Medicare, and the 2026 final rule left it largely untouched. That's been the pattern — CCM is well-defined, well-understood, and not generating significant new policy activity.

What CMS hasn't done is address the program's persistent participation gap. CCM covers a large share of Medicare beneficiaries, but enrollment has never reflected that. Initiating visit requirements, the volume of documentation required, and consent processes continue to limit adoption in practices without dedicated care management infrastructure, and CMS has not moved to address any of them.

For 2027, the more pressing question may be how CMS handles the CCM-APCM relationship. As APCM matures, practices running both programs need clarity on how they interact, when one is preferable to the other, and whether CMS has any intention of eventually sunsetting or consolidating the older codes.

CCM and the OIG: An Audit Backdrop for 2027

The 2027 rule arrives against a new compliance backdrop. The Office of Inspector General (OIG) recently added CCM to its Work Plan, outlining a multi-year audit of Medicare Part B payments for CCM services. The audit's primary focus is eligibility — specifically, whether patients billed for CCM meet the requirement for multiple chronic conditions. The review will examine payment patterns across several recent years and is expected to continue through the latter part of the decade.

This matters for how practices should read whatever CMS does — or doesn't do — with CCM in 2027. If the rule continues to leave CCM largely untouched while the OIG is actively auditing it, that's a signal that the compliance bar is being enforced through oversight rather than revised through policy.

The audit also reinforces what the 2027 rule may eventually need to address. The areas OIG is probing — eligibility validation, documentation, and consistent workflows — are the same factors that have kept physician participation in CCM lower than its eligible patient population would suggest.

What New Remote Care Management and Preventive Services Is CMS Introducing?

Remote care management sits within a wider set of services CMS has been adding to the fee schedule. In 2024, the agency introduced community health integration (CHI) and principal illness navigation (PIN) services, social determinants of health (SDOH) risk assessments as an optional AWV component, and caregiver training services. These are aimed at creating reimbursable infrastructure around the upstream factors that drive chronic disease. CMS issued an RFI on CHI, PIN, and SDOH in the 2025 proposed rule, asking how these programs could be refined and better utilized in rural settings.

The 2027 rule may bring adjustments to those programs — eligibility criteria, auxiliary personnel requirements, billing rules — particularly given the rural utilization question CMS raised. The 2026 rule included a notably broad RFI on chronic disease prevention, asking about partnerships between health care entities, aging organizations, and community care hubs — a program architecture question, not a billing one. It suggests CMS is thinking about what comes after the current set of care management codes.

The ambulatory specialty model (ASM), launching January 2027, is a recent example of CMS constructing an entirely new framework when it decides the policy case is there. A comparable initiative in primary care and chronic disease management is speculative, but the groundwork CMS has been laying through successive RFIs makes it less surprising than it would have been a few years ago.

FQHCs and RHCs: What 2026 Changed and What 2027 Might Settle

Federally qualified health centers (FQHCs) and rural health clinics (RHCs) operate under a distinct payment framework, and recent rule cycles have been active for these settings.

In 2026, CMS finalized that FQHCs and RHCs can use the APCM behavioral health add-on codes when providing advanced primary care. It also finalized policy to pay for PFS-designated care coordination services — including CCM, APCM, and related programs — as care coordination services for purposes of separate payment in these settings, an alignment intended to reduce billing uncertainty. On the telehealth side, CMS permanently adopted a definition of direct supervision allowing supervising practitioners to meet that requirement via real-time audio-visual telecommunications, which has real operational significance for FQHCs and RHCs managing care across multiple sites.

For 2027, the most relevant questions involve the telehealth framework. Several provisions for these settings — including billing under HCPCS code G2025 for non-behavioral health visits furnished via telecommunications technology — have been moving through the rulemaking process on temporary extensions. At some point these policies will need permanent resolution — though that will largely depend on Congress, not CMS. The 2027 proposed rule may reflect whatever legislative direction emerges, and how that plays out will affect how FQHCs and RHCs structure care management and telehealth delivery going forward.

The Conversion Factor: A Structural Shift Worth Understanding

Two structural changes in the 2026 rule matter for care management practices. CMS applied an efficiency adjustment to work RVUs for non-time-based services, reducing valuations on the theory that procedural services generate efficiency gains over time. It also split the conversion factor for the first time, with separate rates for qualifying alternative payment model (APM) participants and all other practitioners.

Time-based codes — including care management, behavioral health, and evaluation and management services — are explicitly exempt from the efficiency adjustment. CMS's reasoning is that services defined by clinical time don't compress the way procedural services do. That exemption is meaningful for practices built around CCM, APCM, and RPM management codes.

For 2027, the question is whether CMS maintains that structure or begins applying downward pressure to time-based codes through other mechanisms. Budget neutrality requirements create constant pressure to offset increases somewhere with reductions elsewhere. Care management codes have been relatively protected, but as the code set grows and reimbursement amounts accumulate, that could change.

When the 2027 PFS Proposed Rule Drops…

The proposed rule is expected within weeks, and Medicare compliance expert, Daniel Tashnek, JD, will be covering the most pertinent changes in a webinar planned for 2 PM ET / 11 AM PT on July 30, 2026. If you want a practical breakdown of what the rule means for your care management programs — and time to ask questions — the webinar is the place for that. Reserve your seat today.

* Disclaimer: The above information is speculation and we have no internal knowledge of CMS plans. The above is for informational purposes only and does not constitute legal or other professional advice. Billing and coding requirements — especially in the telehealth space — can change and be reinterpreted often. You should always consult an attorney and/or medical billing professional prior to submitting claims for services to ensure that all requirements are met.