On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) released its Calendar Year 2027 Physician Fee Schedule (PFS) Proposed Rule (CMS-1848-P). The proposal contemplates significant changes to how remote physiologic monitoring (RPM) services are delivered and valued.
We will detail what has actually been proposed, why we believe key elements of it are both clinically and financially misguided, and what we are doing about it alongside others in the industry.
The central point to keep in mind is that this is a proposed rule, not final policy. Nothing changes today. There is a defined comment process ahead, and a clear opportunity to influence what is actually codified in the final rule.
Proposed Changes to RPM Delivery and Valuation
Relating to RPM, CMS-1848-P proposes:
- Limiting reimbursement to RPM services delivered by clinical staff employed by the practice, excluding contracted partners.
- Requiring a dedicated initiating visit prior to RPM program enrollment.
- Reducing the valuation of the RPM device supply codes, on the stated basis that they suspect devices may be available at a lower cost than previously estimated.
- Eliminating the clinical staff practice expense inputs for the treatment management codes, on the stated assumption that these services do not involve clinical staff time.
Throughout the relevant sections, CMS explicitly states that it lacks appropriate cost and clinical workflow data to finalize these policies, and that it is actively soliciting that information. The proposed rule represents a request for that data, not a final determination.
Proposed Changes Do Not Impact CCM and APCM
The aforementioned proposals in CMS-1848-P are specific to RPM. They do not change the valuation of chronic care management (CCM) or advanced primary care management (APCM) services. The ability to deliver CCM and APCM with third-party staffing support is not under review and those programs will be furnishable by contractors under general supervision moving forward regardless of the outcome of this final rule.
In short, a meaningful part of the care management model sits entirely outside the scope of these proposals.
This Is a Proposal, Not a Final Rule
We want to be clear and specific about what these RPM proposals mean operationally:
- Current rates and rules remain fully in effect. There would be no change to reimbursement or program operations before January 1, 2027.
- A 60-day public comment period is now open, closing on September 14, 2026. A final rule is expected around November 1, 2026, with any finalized provisions effective January 1, 2027.
- CMS regularly revises, narrows, or withdraws proposals in response to well-evidenced comments prior to final rule codification. The comment window is the formal mechanism for that.
CMS has said, in its own words, that it lacks the cost and clinical workflow data needed to value these services accurately. We have that data. The proposal is, in effect, an invitation to supply it.
Why the RPM Proposals Are Clinically Misguided
The proposal to exclude partner-delivered services overlooks clinical reality. Many provider organizations do not have the resources to build and staff a continuous monitoring operation internally. Partnering with organizations like ours is what makes consistent, high-quality monitoring possible for their patients at all. Removing that option does not move care "in-house"; it removes care.
It is worth understanding where this proposed restriction on partner-delivered monitoring comes from, because the origin reveals the flaw. It follows Office of Inspector General (OIG) findings documenting abuse of the RPM benefit: practices billing for patients that they had no prior clinical relationship with and arrangements where a distant vendor performed essentially all of the work. Those are real problems, and we share the goal of rooting them out. But the proposed employment requirement is an overly blunt instrument. By conditioning payment solely on whether clinical staff are employed by the billing practice, CMS would penalize precisely the clinically integrated, good-faith partnerships it should want to preserve – those built on genuine cooperation and established patient relationships. The right response to bad actors is to target them directly, not to dismantle the partnership model that legitimate programs rely on to deliver coordinated, high-quality care.
The proposal to remove clinical staff inputs from reimbursement calculation rests on the assumption that these services do not typically involve clinical staff time. That assumption does not match how remote monitoring is actually delivered. Reviewing patient transmissions, triaging alerts, escalating clinical deterioration, and conducting timely outreach is real, time-consuming work performed by clinical staff under physician oversight. It is the core of the service.
The clinical stakes are real. Overwhelming clinical evidence proves that remote monitoring supports earlier detection of deterioration, fewer avoidable hospitalizations and emergency visits, and better day-to-day management of chronic conditions such as hypertension, heart failure, COPD, and diabetes.
Why the RPM Proposals Are Financially Misguided
The device code revaluation proposal rests on an incomplete picture of what RPM technology actually costs. Reimbursement, in reality, covers a one-time device cost plus ongoing software connectivity, data transmission, logistics, and support. Proposed reimbursement would, at best, cover a small fraction of the upfront device cost.
The likely result of underpricing these services below sustainable cost is that providers exit remote monitoring. They will exit first in precisely the underserved markets CMS most wants to reach. Reduced monitoring would drive more of the avoidable acute care that costs Medicare far more than the monitoring itself.
These proposals also arrive on top of broader downward pressure on the fee schedule. With the one-year 2026 conversion factor increase expiring, current law already requires a reduction in the 2027 conversion factor. Layering targeted RPM cuts on top of that compounds the strain on providers and runs counter to CMS's own multi-year effort to expand access to remote monitoring.
What We Are Doing
Our response is already underway. We are actively:
- Submitting a formal comment to CMS with the cost composition data CMS has explicitly requested.
- Documenting the real clinical workflow to rebut the suggestion that these services do not involve clinical staff, as well as cannot be delivered valuably by contracted partners.
- Partnering with our clients by providing comment templates and supporting providers who wish to submit their own comments. The volume and authenticity of the provider voice matters to CMS, and we will help amplify it.
- Coordinating across the industry with peer organizations to deliver a unified, evidence-based response.
CMS asked for better data; our aim is to give the agency the information it needs to enact policies grounded in clinical and financial realities.
What Comes Next
Prevounce is built for exactly this moment. We deliver outsourced care management, equip practices to run their own RPM programs in-house with our software and connected devices, and support a hybrid model that blends both. That flexibility matters here: should the proposal limiting reimbursement to employed clinical staff be finalized, our outsourced clients can transition to a software-driven, in-house program with limited interruption to the care their patients receive. Continuity is not contingent on the outcome of this rule.
That said, we are confident that a thoughtful, coordinated response from providers, interest groups, and RPM partners like us will lead to a walkback of these proposals and a return to a status quo on RPM delivery and valuation. In the meantime, our clients’ RPM programs and reimbursement continue unchanged. We are steadfastly committed to supporting our clients through this comment period and beyond.
We believe the clinical and economic case for remote monitoring is strong and that the response we are leading is grounded in real data. We are confident in our path forward and in the value these services deliver to patients, providers, and the Medicare program.