Get ahead of Medicare's proposed 2027 changes to remote care management, and learn how to keep your RPM program compliant no matter how the rule shakes out. Register for our educational webinar, "Understanding Medicare's 2027 Proposed Changes to Remote Care Management," on July 30, 2026, at 2:00 PM ET / 11:00 AM PT.
Key takeaways
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CMS's 2027 Physician Fee Schedule proposed rule would bar practices from billing for RPM and RTM work performed by contracted clinical staff, limiting billable work to staff employed directly by the practice.
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This is a proposed rule, not a final one, and CMS is accepting public comments through September 14, 2026.
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Current RPM rules and reimbursement don't change before Jan. 1, 2027, and only if these provisions survive to the final rule.
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RPM and RTM would both require an initiating visit and an established patient relationship before enrollment.
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CCM and APCM are untouched by this proposal, and contracted staffing stays allowed for both.
On July 14, 2026, CMS released the Calendar Year 2027 Physician Fee Schedule (PFS) proposed rule (CMS-1848-P). For remote patient monitoring (RPM), it proposes new restrictions on who can deliver billable services, new visit and enrollment requirements, changes to how certain codes are valued, and a request for comment on a bigger structural change to the code set. That is a different direction than last year's rule, which greatly expanded RPM billing.
Nothing has changed yet. This is a proposed rule, not a final one, and current RPM billing rules stay in effect through the end of 2026 no matter what happens next. CMS incorporates public comments into its final rules, so the comment period is a real opportunity to shape the outcome. But the proposal is specific, it is significant, and it's open now.
What CMS Is Proposing for RPM and RTM in 2027
CMS-1848-P includes four provisions that would directly affect RPM and remote therapeutic monitoring (RTM) billing if finalized, plus a request for comment on a bigger structural change:
- Employed clinical staff only. RPM and RTM services would be payable only when performed by clinical staff employed by the billing practice. Services delivered by contracted partners would no longer qualify.
- A required initiating visit. Practitioners would need to furnish a separately reportable visit at the onset of RPM or RTM services before billing for either.
- Established patient requirement extended to RTM. RTM would require an established patient relationship, matching the rule that already applies to RPM.
- Revalued device and treatment management codes. CMS is proposing to revalue the device supply codes based on its belief that RPM devices may be available at a lower cost than its original estimates, and to remove the clinical staff practice expense inputs from the treatment management codes. The existing work RVUs and time values for those codes would stay in place.
- A request for comment on code bundling. CMS is also seeking input on collapsing the RPM and RTM CPT codes into four new HCPCS G-codes describing remote monitoring services more broadly. More on what that could look like below.
CMS explains its reasoning for the employment restriction directly in the proposed rule:
"We do not believe that RPM or RTM services provided by clinical staff contracted by a third party can ensure the billing practitioner has adequate oversight, management, or collaboration to bill RPM or RTM services. If there is little oversight by the billing practitioner or a lack of clinical integration between a third-party providing RPM/RTM and the billing practitioner, we do not believe that the full scope of service elements required to bill these codes are being met. We are proposing to only allow payment for RPM or RTM services when furnished by clinical staff employed by the practice."
That provision is generating the most attention across the industry, since it would eliminate billing for a staffing model that a meaningful share of current RPM and RTM programs rely on.
A Quick History: From Direct Supervision to Outsourced RPM Staff
CMS has revisited this same staffing question before. When CPT 99457 took effect in January 2019, CMS required clinical staff performing RPM treatment management to work under the billing practitioner's direct supervision, meaning the clinical staff had to be physically present with the practitioner. Medical practices told CMS this made RPM difficult to staff, since their existing clinical staff already had full workloads and direct supervision ruled out working with a remote or outsourced partner.
CMS responded the following year. The CY 2020 PFS final rule allowed RPM treatment management services to be furnished under general supervision instead, meaning the billing practitioner had to be available to assist but no longer needed to be in the same location. That change opened the door to the outsourced clinical staff model many RPM and RTM programs have used since, in which contracted staff monitor patients and escalate issues to the practice, and it is widely credited with helping RPM and RTM programs scale and reducing unnecessary office visits and avoidable ER admissions. If finalized, the 2027 proposal would close most of that door.
The OIG Reports Behind the Proposal
CMS cites two OIG reports on RPM billing as part of the basis for these changes, both of which we've covered in detail: A September 2024 review that found 43% of RPM enrollees did not receive all three components of the service, and an August 2025 data snapshot showing RPM payments reached $536 million in 2024, up 31% from the prior year.
As we noted when that second report came out, the underlying data showed the large majority of practices billing RPM in compliance, with a smaller number of specific problematic billing patterns, like a high share of patients with no prior relationship to the practice, flagged for closer review. That is a narrower finding than the scope of the proposed employment restriction, which would apply to every practice using contracted clinical staff regardless of its billing history.
What's Not Changing: CCM and APCM
These proposals apply only to RPM and RTM. Chronic care management (CCM) and advanced primary care management (APCM) are not affected. Contracted staffing arrangements for CCM and APCM would continue to be permitted under general supervision regardless of how the RPM provisions are finalized. For a practice running a blended program, that is a meaningful piece of the care management model that sits entirely outside the scope of this proposal.
Current vs. Proposed RPM and RTM Rules for 2027
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Provision |
Current Rule |
2027 Proposed Rule |
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Who can deliver billable services |
Performed by clinical staff under general supervision, including contracted staff. |
Limited to clinical staff directly employed by the billing practice. Contracted partners would no longer qualify. |
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Enrollment requirements |
No separately reportable initiating visit required for RPM. RTM does not require an established patient relationship. |
A separately reportable initiating visit required for RPM and RTM. RTM would require an established patient relationship, matching RPM. |
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Device supply code valuation |
Valued based on CMS's original cost estimates for RPM devices. |
Would be revalued based on CMS's belief that devices may cost less than originally estimated. |
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Treatment management code inputs |
Includes clinical staff practice expense inputs. |
Clinical staff practice expense inputs removed. Work RVUs and time values unchanged. |
The RPM Code Bundling Question, Again
CMS is also asking a bigger structural question, one specific enough to come with draft code descriptions attached. The agency is seeking comment on collapsing the RPM and RTM code sets into four new HCPCS G-codes:
- GRPM1: RPM initial setup and patient education
- GRPM2: Remote monitoring of physiologic parameters per calendar month, combining device supply, at least two days of data transmission, and treatment management requiring at least one real-time interactive communication totaling at least 20 minutes
- GRTM1: RTM initial setup and patient education
- GRTM2: The RTM equivalent of GRPM2, covering therapeutic rather than physiologic parameters
This is a request for information (RFI), not a formal proposal, and these appear to be working labels attached to the RFI rather than finalized codes. GRPM2 would bundle device supply, data transmission, and treatment management into one all-or-nothing monthly code, so a practice that collects a full month of readings but falls short of 20 minutes of live conversation would be paid nothing for any of it, a stricter outcome than today's rules, where CPT 99454, which covers the monthly supply of an FDA-approved device and the transmission of patient-generated health data, can still be billed on its own.
The 2026 flexibility would disappear, and codes would move back toward pre-2019 levels, a structure providers roundly criticized at the time and that prompted most of the changes CMS has made since.
Under this structure, a practice could bill the same 20 minutes of contracted staff time for CCM or principal care management (PCM) at a higher rate than RPM would pay, without needing a device or an interactive communication requirement to get paid.
Why These Restrictions May Not Survive the Final Rule
CMS frames much of the restrictions it's considering as a starting point rather than a finished policy. In my statement on the proposed rule, I flag something unusual about that framing: CMS is explicit about lacking the cost and clinical workflow data it says it needs to finalize some of these provisions. That posture is atypical for CMS, which typically relies on RUC-recommended cost data or its own analysis rather than asking the industry to supply it directly through the comment process. The proposal functions, in effect, as a request for that missing data. CMS has a track record of narrowing or withdrawing aggressive proposals after a comment period, and that track record, combined with how unusual this request for data is, is a big part of why we expect significant pieces of this proposal will not survive to the final rule.
The comment period on the 2027 PFS proposed rule closes Sept. 14, 2026, with a final rule expected around Nov. 1, 2026, and any finalized changes effective Jan. 1, 2027. We believe there is a strong case that key parts of this proposal get revised before then, and we are actively making that case, including the clinical and financial arguments against the employment restriction and the device revaluation, laid out in full above.
What RPM Programs Should Do Before the Final Rule
Current RPM billing rules and reimbursement rates are unaffected through the end of 2026, no matter how the final rule turns out in November. The comment period is open, and CMS has said directly it wants operational and cost data from the practices and organizations running these programs, exactly the kind of input that can shape a final rule. This proposal also lands on top of an already tighter fee schedule: the temporary conversion factor increase that offset costs in 2026 expires for 2027, and current law requires a modest reduction to next year's conversion factor regardless of what happens with RPM specifically.
Want the full breakdown, including how to build a compliant, sustainable RPM program whichever of these provisions get finalized? I will cover that, plus other proposed changes affecting remote care and telehealth more broadly, on July 30 at 2:00 PM ET/11:00 AM PT in our webinar, "Understanding Medicare's 2027 Proposed Changes to Remote Care Management." Register here.
Frequently Asked Questions About the 2027 RPM Proposed Rule
Has CMS finalized the 2027 RPM outsourcing restrictions, or could they still change?
Given the wording CMS used in the proposed rule, we would be surprised if the final rule didn't include at least some significant changes. A final rule is expected around Nov. 1, 2026, and any changes would take effect Jan. 1, 2027, at the earliest. Comments submitted during the open comment period could still shape what ultimately gets finalized.
Will providers still be able to bill for outsourced RPM services?
Under the proposal as written, RPM and RTM services would be payable only when performed by clinical staff employed by the billing practice. Services delivered by contracted or outsourced clinical staff would no longer qualify for payment if this provision is finalized as proposed. This provision has already been met with widespread criticism from provider organizations and industry thought leaders alike and will yield significant feedback during the comment period.
Does the 2027 proposal affect CCM or APCM?
No. The proposed changes apply specifically to RPM and RTM. CCM and APCM are unaffected, including the ability to deliver those services with contracted staff under general supervision.
Will RPM billing change before 2027?
No. Current RPM billing rules and reimbursement rates remain in effect through the end of 2026 regardless of the proposal's outcome. Any finalized changes would take effect Jan. 1, 2027 at the earliest.
When is the deadline to comment on the 2027 RPM proposed rule?
The comment period for CMS-1848-P closes Sept. 14, 2026. Comments can be submitted at regulations.gov under file code CMS-1848-P.
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