I hosted one of our two annual regulatory webinars on July 30, walking through CMS's Calendar Year 2027 Physician Fee Schedule proposed rule and what it means for remote patient monitoring (RPM) and remote therapeutic monitoring (RTM). More than 1,500 people registered, which tells you how much this year's proposal has the industry's attention.
If you missed the program, or want to send it to a colleague, the full recording is available on demand. Here are seven things worth understanding before the comment period closes, plus what I think this all means for where remote care is headed.
1. Abuse CMS Is Responding to Is Real, but Narrow
CMS points to two OIG reports as the basis for several of this year's proposals: a 2024 review and a 2025 data snapshot showing RPM payments reaching $536 million in 2024, up from about $15 million when the code set launched in 2019. That growth got read by some as evidence of a program with a widespread integrity problem.
The underlying data does not support that reading. OIG's own data snapshot looked at more than 10,600 practices that billed RPM regularly in 2024-2025, and out of that group, it flagged just 45 for a disproportionate share of patients, often without a prior clinical relationship. One of those practices had enrolled more than 30,000 patients without the required existing relationships. OIG also noted that 43% of enrollees did not have all three RPM components billed in a given month, while explicitly stating that not all three are required. In other words, the majority of practices are following RPM coding rules, and these codes are working as intended.
Billing without a prior clinical relationship is a legitimate, quantifiable problem, and one existing regulations can address it if they are effectively enforced. What this is not is evidence that the RPM model itself is broken. It is worth keeping that distinction in mind for everything that follows, because the remedies CMS is proposing are broader than the problem it describes.
2. Employment Restriction Does Not Reach the Practices OIG Flagged
In the proposed rule, CMS states plainly: "We are proposing to only allow payment for RPM or RTM services when furnished by clinical staff employed by the practice." The stated concern is that outsourcing "can fragment care, lead to insufficient involvement and oversight of the billing practitioner."
Employment status is a poor stand-in for clinical integration. Think about who the 45 flagged practices actually are: RPM-only operations billing under their own provider number, with clinical staff they hire directly. They would sail through an employment test without changing anything about how they operate. Meanwhile, a practice that brings in contracted clinical staff, but keeps its own physician directing the work and its own billing on the line, would lose the ability to bill at all. CMS is trying to reach the first group and would end up regulating the second one instead.
3. Conduct OIG Flagged Is Already Against the Rules
Since the COVID-19 public health emergency ended in May 2023, RPM has required an established patient relationship before billing. The programs OIG identified, enrolling patients with no prior clinical relationship, were already out of compliance with that requirement, and soliciting beneficiaries for services they do not need already implicates existing medical necessity rules.
OIG identified these patterns using claims data CMS already has. That argues for audit and enforcement against a known set of practices, not a new, broader mandate that reaches practices already operating within the rules. CMS has the tools it needs today, and using them does not require restricting a staffing model that a meaningful share of well-run RPM and RTM programs depend on, including in rural and underserved areas where practices often cannot staff these programs entirely in-house.
4. Device Code Cuts Price RPM on Inaccurate Assumptions
For CPT 99454 and 99445, the codes that pay a practice to supply a connected device and transmit patient readings, CMS is proposing to crosswalk the valuation to the self-measured blood pressure codes (CPT 99473/99474), citing a lack of invoice and pricing data on RPM devices. CMS states in the proposed rule that “the typical device used for these procedures in the physician office setting may not be accurately captured in the data previously used for valuation.”
The comparison does not hold up. The practice does not buy a device to bill the self-measured blood pressure codes; the patient already owns one (or purchases an inexpensive unconnected monitor) and just reports the numbers back. RPM only exists because the practice takes on an ongoing cost the patient would otherwise bear: sourcing a connected device, keeping it transmitting, and supporting the patient using it, month after month, for as long as they are enrolled. Valuing the RPM code as though that cost were zero gets you roughly what CMS landed on: a proposed rate that, by one published estimate, would not even cover the device itself, let alone what it takes to keep it running for a patient. To CMS's credit, the proposed rule also asks directly for real device cost data before finalizing a number, which is an invitation for clinics and practitioners with RPM programs to join with the rest of the industry to respond..
5. Treatment Management Code Proposal Undercuts Its Own Staffing Argument
CMS is also proposing to remove clinical staff practice expense inputs from the RPM and RTM treatment management codes (CPT 99457, 99458, 99470), while keeping the existing work RVUs and time values in place. In its own words, CMS states it does "not believe the typical workflow for these services would involve clinical staff time."
That is difficult to reconcile with the rest of the proposal. The CPT descriptors for these codes explicitly begin with "clinical staff/physician/other qualified health care professional time," and the same proposed rule elsewhere restricts who can serve as that clinical staff, which only makes sense if clinical staff time is, in fact, a meaningful part of delivering the service. CMS cannot simultaneously argue there is no clinical staff time in these codes and propose restricting the clinical staff who perform it. In reality, this work is clinical staff intensive, month over month, for the large majority of enrolled patients.
6. Bundling the Codes Would Undo Flexibility That Was Added on Purpose
CMS is separately seeking comment on collapsing the RPM and RTM code sets into single monthly G-codes covering device supply, data transmission, and a minimum amount of treatment management time together. CMS frames this as a way to ensure "those service elements are always provided."
That framing runs against the reason these codes were unbundled in the first place. Before 2019, RPM was billed as a single bundled code, and adoption was minimal until CMS split it into separately billable components. That flexibility means a stable patient who needs 10 minutes of management one month is not left unpaid because they did not need 20, and a practice that supplies a device and collects readings is not left unpaid because a full month of live communication was not clinically necessary. The two RPM codes CMS added just this year, CPT 99470 and 99445, already make it easier to bill accurately for exactly the scenarios OIG raised concerns about. Bundling would reverse that progress just as it started working, and it would make the utilization data OIG wants harder, not easier, to collect.
7. Nothing Is Final, and CCM and APCM Remain Untouched in the Meantime
None of these proposals apply to chronic care management (CCM) or advanced primary care management (APCM). Contracted staffing stays fully available for both, regardless of how the RPM and RTM provisions land. For practices with RPM patients who also qualify for CCM or APCM, dual enrollment is worth reviewing now, since it preserves meaningful patient contact and care coordination no matter the final rule outcome.
Current RPM and RTM billing rules stay in effect through the end of 2026. A final rule is expected by November 1, with any changes taking effect Jan. 1, 2027 at the earliest. CMS has been unusually direct about wanting cost and clinical workflow data from the practices and organizations actually running these programs, which is a real opening. I would encourage anyone running an RPM or RTM program, in-house or outsourced, to submit a comment before the September 14 deadline, with specifics on program costs, clinical workflow, and patient outcomes.
Even in a worst-case scenario where CMS finalizes the device code cut exactly as proposed, the full reduction would not land all at once. Under the standard PFS phase-in rule, a proposed reduction of 20% or more to an existing code's total RVUs is capped at 19% in the first year, with the remainder phased in over a second year. Applied to the roughly 80% cut proposed for the RPM device codes, that means the worst first-year hit in 2027 would land closer to 19%, not the full amount. The remaining reduction would phase in for 2028, the same year CMS has already committed to revisiting the practice expense data behind these codes. That gives practices more runway than the headline number suggests, and a second chance to get better cost data in front of CMS before any full cut takes hold.
Where Next for Remote Care
This proposal did not arrive in a vacuum, and it is worth understanding it alongside a few other things happening at the same time. CMS also used this rule to issue a broad request for information on how AI-powered tools might support care management going forward, a signal that the agency is thinking about how technology, not just staffing rules, changes the cost of delivering these services. Separately, the full remote monitoring code family is already scheduled for review by the CPT Editorial Panel in January 2028, so valuation was going to be revisited on its own timeline regardless of this year's proposal.
There is also a notable disconnect with what else is happening in Washington. The bipartisan Rural Patient Monitoring Access Act (H.R. 3108), which would set a Medicare payment floor for rural RPM, cleared the House Ways and Means Committee 38-0 in July. Around the same time, the $50 billion Rural Health Transformation Program began distributing funds to all 50 states, with remote monitoring named as one of the priority technology investments states can support. It is an odd moment for CMS to be proposing cuts to RPM reimbursement while Congress and the rest of the federal government are actively investing in expanding it.
We do not expect this proposal to survive to the final rule in its current form, and we will be watching closely and commenting accordingly. To stay up to date with the most recent news in remote care, subscribe to the Prevounce blog and follow us on LinkedIn.
* Disclaimer: The above information 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.