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On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) released the 2027 Medicare Physician Fee Schedule (PFS) proposed rule, and it carries the most substantial changes to remote patient monitoring (RPM) since Medicare began paying for it in 2019. If finalized, the rule would reshape how practices enroll patients, staff their programs, and bill for RPM and remote therapeutic monitoring (RTM).
We recently broke down these provisions in a webinar and received many more questions than we could answer during the program. Below, we address the questions that matter most to those planning a remote care strategy for 2027. One caveat largely applies throughout this piece: The provisions discussed are proposed, not final, and we do not expect all of them to reach the final rule as written.
If you weren't able to attend the live webinar, you can now watch the on-demand recording of "On-Demand Webinar: Understanding Medicare's 2027 Proposed Changes to Remote Care."
What Is CMS Proposing to Change for RPM in 2027?
The 2027 PFS proposed rule proposes four changes to RPM and RTM: 1) a separately reportable initiating visit at the onset of services, 2) an established-patient requirement extended to RTM, 3) a direct-employment requirement that ends outsourced staffing, and 4) lower valuations for device and treatment management codes. CMS frames these changes as a response to Office of Inspector General (OIG) findings on RPM program integrity. The regulatory backdrop is the OIG report Additional Oversight of Remote Patient Monitoring in Medicare Is Needed (OEI-02-23-00260, September 2024), which documented RPM growth from roughly 55,000 enrollees in 2019 to 570,000 in 2022, and found that the vast majority of practices were billing appropriately. CMS is also seeking comment on consolidating the current code set into four new HCPCS G-codes.
Based on how these policies are drafted and the industry pushback already underway, we doubt they will be finalized as written.
Proposed Enrollment Rules and Initiating Visit Requirement
Q: What is the RPM initiating visit requirement in the 2027 proposed rule?
A: The proposed rule would require a separately reportable initiating visit before RPM or RTM services begin. As written, that visit must satisfy CMS’s “face-to-face” requirement, furnished either in person or via telehealth by the billing practitioner, and RPM or RTM must be explicitly discussed with the patient, with consent obtained. CMS notes this requirement mirrors the existing initiating-visit standard for chronic care management (CCM). The initiating visit can be part of another encounter, so it does not have to be a standalone appointment, but the face-to-face and consent conditions still must be met.
Q: What codes/visits can be counted as an RPM initiating visit?
A: CMS has not named specific codes that qualify as an initiating visit. The 2027 proposed rule stipulates only that the visit be face-to-face, in person or via telehealth, and that RPM initiation be explicitly discussed. As long as those conditions are satisfied, many visit types could count. Since CMS left the qualifying visit types open, practices should watch for further specificity in the final rule.
Q: How does an RPM initiating visit change the enrollment workflow?
A: For practices already running compliant workflows, an initiating visit adds an administrative step rather than a structural overhaul. The key shift is who does the work: Clinical staff would no longer be able to enroll patients on their own, because the billing provider must satisfy the initiating visit and document consent first. Practices that lean on staff-driven enrollment today would need to route patients through a provider touchpoint before onboarding. These provisions remain proposed, and we expect material changes in the final rule.
Proposed Restrictions on Outsourcing RPM Services
Q: Would the 2027 proposed rule ban outsourced RPM services?
A: Yes, under the proposed rule, Medicare would pay for RPM and RTM only when the services are furnished by clinical staff who are direct employees of the billing practitioner or practice, not when they are delivered by third-party contractors. CMS argues that contracted arrangements do not provide adequate oversight, management, or collaboration to support RPM or RTM billing. The proposal targets clinical staffing specifically. It would not bar practices from purchasing software, connected devices, or data platforms from third-party vendors. This is the provision we consider least likely to survive the final rule intact, given its potential negative impact on patient access and outcomes, as well as the volume of comments it is drawing.
Q: Does the employment requirement mean staff must be on-site or under direct supervision?
A: The proposal keeps the current general supervision standard and does not move RPM or RTM to direct supervision. CMS states that employed clinical staff do not need to be physically located within the practice, and that the beneficiary does not need to be on-site for remote monitoring. The only new constraint is the employment relationship itself: To count their time, clinical staff would need to be direct employees of the billing practitioner or practice rather than contracted through a third party, while still operating under general supervision and the "incident to" requirements in §410.26. Remote staff and remote patients remain workable under the proposal. What changes is whether that staff can be contracted out.
Q: Does the billing provider have to be employed by the practice billing for RPM, or just clinical staff?
A: CMS did not address the question of physician employment in the proposal. If the physician was contracted, he or she would effectively be "contracting" with your employed staff and vice versa. This is one of many questions CMS would need to address explicitly if some version of the proposal is finalized.
Q: Can a third party complete an initiating visit without an established patient relationship?
A: Under the proposed rule, any provider delivering RPM services would need to establish the patient relationship and complete an initiating visit. That applies to the patient's primary care physician and to any other physician. Once the patient is established and the initiating visit is complete, that physician is free to deliver and bill for RPM services.
Q: How stringent are the W2 qualifiers for staffing RPM programs currently in the proposal? Can RPM care services be provided by employees hired as 1099 contractors?
A: CMS's proposal did not offer any guidance beyond distinguishing between "employed" and "contracted" staff. There are many practices and health systems that use contracted staff for a wide range of services, not just RPM. If CMS does move forward with its employment requirement for RPM, the agency will need to clarify a great deal for the rule to be understandable and enforceable. As we discussed in the webinar, we are not anticipating that the proposal will make it into the final rule as written.
Q: Would commercial payers mirror the outsourcing change if finalized?
A: Commercial payers often follow Medicare, but no requirement obligates them to adopt specific changes if finalized. Whether they mirror the outsourcing restriction is something to watch once the final rule lands and the industry responds. Practices with significant commercial RPM volume should not assume alignment in either direction until payers signal their position.
Q: Do CCM and APCM face the same staffing limits?
A: No, CMS has not proposed limiting staffing for care management programs like CCM or advanced primary care management (APCM). Third parties can still deliver CCM and APCM services on behalf of practices regardless of how the RPM proposals resolve. The employment restriction in this proposal is specific to RPM and RTM. In fact, in the unlikely case that the RPM outsourcing provisions are finalized in the final rule, practices may turn to comprehensive remote care: integrating RPM with CCM or APCM.
Q: Is CMS trying to eliminate the RPM outsourcing model entirely?
A: CMS seems most intent on eliminating fraud and abuse, which they argue is best achieved through mandating direct employment. The OIG report uncovered vendors with a billing physician on-staff billing for RPM under their NPI. We believe that CMS is targeting this practice. However, this model passes the employment test and restricts well-structured good-faith RPM programs that have a real impact on patient outcomes.
If CMS’s ultimate goal is to address abuse and ensure clinical integration, we believe that meaningful clinical integration and meaningful patient outcomes can be achieved in outsourcing arrangements/ We are hopeful that CMS will reverse course after reading well-reasoned comments.
Q: For organizations starting a new RPM program and considering outsourcing, do you suggest holding off for now until the final ruling?
A: The final ruling is expected by Nov. 1, and if passed, the proposals would take effect Jan. 1, 2027. If you are currently outsourcing an RPM program, we advise no changes at this time. There is a high likelihood that these proposals are modified or outright reversed in the final rule. Abandoning or overhauling a successful RPM program would mean having to ramp back up should changes not go through as proposed. If you have yet to start a program, we would suggest picking an RPM partner who offers both in-house and outsourcing optionality to give you flexibility should some version of the proposed changes go into effect.
Proposed Reimbursement Cuts Would Hit Device and Service Codes
Q: Is CMS proposing a revaluation of device codes, service codes, or both?
A: Under the proposal, device codes and treatment management codes would be affected. CMS proposes to lower device code valuations on the view that the devices may be available at a reduced cost compared to its initial estimates. Separately, CMS proposes to remove practice expense (PE) inputs from the treatment management codes, on the assumption that clinical staff do not contribute to that work. If finalized as written, the treatment management codes would effectively be priced to cover physician time only, whereas today they are priced to cover physician and clinical staff time.
|
Code group |
How it is valued today |
What CMS proposes |
CMS's stated rationale |
|
Device and setup codes |
Include practice expense inputs for the device and setup |
Lower valuation via crosswalks to lower-cost comparators |
Devices may cost less than initial estimates |
|
Treatment management codes |
Priced to cover physician and clinical staff time |
Remove practice expense inputs, pricing to physician time |
Assumption that clinical staff do not contribute to the work |
Both proposals are couched in a request for comments and cost data, which signals CMS is not committed to the specific values it floated. CMS itself admits that it lacks the data to properly price these codes. Well-supported comments on real device pricing and the role clinical staff play in monitoring could prompt higher rates in the final rule, and we expect the proposed cuts to be softened rather than adopted as drafted.
Q: Does the proposal affect RTM as well as RPM?
A: CMS proposes equivalent reductions to RTM codes built on the same assumptions: that devices cost less than originally estimated and that clinical staff do not contribute to treatment management time. As with RPM, CMS couches the RTM changes in a request for comments and underlying cost data.
How and When to Comment on the 2027 PFS Proposed Rule
Q: When is the comment deadline and where can I submit a comment to CMS?
A: Comments on the 2027 PFS proposed rule can be submitted on the proposed rule's dedicated page on the Federal Register here. All comment submissions are visible to the public, and the submission window ends Sept. 14, 2026.
Q: How should I structure my comment to ensure that all important points are addressed?
A: CMS does not mandate a particular format for comments, and we believe that they will be most impactful if each is unique to some degree. As a general rule of thumb, a strong comment addresses some combination of the following:
- How work is divided in contracted, clinically integrated scenarios
- How an employment mandate would impact patient access
- How clinical staff is involved in RPM workflows
- One-time and recurring costs tied to RPM technology and connectivity
- How bundling RPM codes would impact patient access
Q: Should practices change their RPM programs now?
A: No. In the unlikely chance the proposals are finalized as is, they would take effect Jan. 1, 2027. There is a strong likelihood they will be modified or reversed before then. Dismantling a working program now would mean rebuilding it later if the final rule diverges from the proposal, which is the outcome we expect for the majority of these provisions.
Did You Miss Our PFS Proposed Rule Webinar? Watch It On-Demand Now
The 2027 Medicare PFS proposed rule introduces potential changes that could affect your remote care programs. Medicare compliance expert and Prevounce CEO, Daniel Tashnek, JD, covers what to expect from these proposed changes in the on-demand webinar "Understanding Medicare's 2027 Changes to Remote Care Management."
Schedule a consultation to learn how to develop a remote care strategy that will prepare your organization for 2027. 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.