Key Takeaways
- CMS proposes limiting coverage of RPM and RTM such that the billing practitioner must utilize clinical staff who are direct employees of the practitioner], which could effectively end remote monitoring service models relying out outsourced care management vendors beginning January 1, 2027.
- A new “initiating visit” requirement would require the billing practitioner to assess clinical appropriateness, discuss the remote monitoring service with the patient, and obtain consent before RPM or RTM services may begin.
- CMS is seeking comment on consolidating all 17 existing RPM and RTM codes into just four new G-codes, each requiring delivery of all three service components, including device supply, data transmission, and at least 20 minutes of treatment management with real-time patient interaction.
On July 16, the Centers for Medicare & Medicaid Services (CMS) published its Calendar Year (CY) 2027 Medicare Physician Fee Schedule proposed rule. Among the many proposals in this rulemaking, CMS devotes significant attention to remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM), two code families that were intended by CMS to help close gaps in access to care by accounting for and valuing remote care coordination services performed by physician offices.
RPM and RTM codes allow providers to monitor patients outside traditional clinical settings using connected devices. RPM captures objective physiologic data, such as blood pressure, weight, or blood glucose via medical devices, while RTM tracks non-physiologic therapeutic data, such as musculoskeletal or respiratory system status and medication or therapy adherence. Many physician groups and outpatient providers have made use of these codes by engaging third-party vendors to furnish the care management services, effectively as auxiliary personnel of the billing provider.
In part in response to recommendations from the Department of Health and Human Services (HHS) Office of Inspector General (OIG) reports regarding the proliferation of the use of RPM and RTM codes, CMS is proposing new eligibility requirements, tighter supervision standards, and a potential consolidation of the existing 17 RPM and RTM codes into just four. Comments are due September 14, 2026. The full proposed rule is available on the Federal Register website.
Why Now: OIG Findings Prompt a Policy Response
CMS explains that the proposed changes respond directly to two OIG reports, one published in 2024 and another in 2025, that found significant concerns with how remote monitoring services are being furnished and billed. Among the OIG’s findings: roughly 43% of Medicare beneficiaries receiving remote patient monitoring did not receive all three required service components (setup/education, device supply, and treatment management), raising questions about whether the services were clinically appropriate. The OIG also documented instances of third-party companies “cold calling” beneficiaries to enroll them in the remote monitoring service, sometimes through staff who have no pre-existing relationship with the beneficiary and little to no interaction with the billing practitioner, calling into question the billing provider’s oversight and integration of the remote service into the care plan.
RTM To Be Limited to Established Patients
CMS had previously established a requirement that RPM be furnished and billed only to an established patient of the billing practitioner. CMS now proposes to similarly limit RTM to those with a prior patient relationship, stating that a practitioner with an existing clinical relationship is better positioned to assess whether RTM is appropriate for a given patient, and that limiting RTM to established patients will help curb beneficiary concerns about being “cold-called” to enroll.
A New “Initiating Visit” Must Precede RPM and RTM Services
For both RPM and RTM, CMS proposes that the billing practitioner must furnish a separately reportable initiating visit, either in person or via telehealth, in connection with the start of monitoring services. This visit must be one at which the practitioner actually discusses RPM or RTM with the patient, assesses clinical appropriateness, and obtains the beneficiary’s consent. A routine visit at which remote monitoring is never mentioned would not qualify. The initiating visit itself may be billed separately.
Clinical Staff Must Be Direct Employees
Perhaps the most consequential proposal for digital health vendors and remote monitoring companies is CMS’ proposal that RPM and RTM may only be billed when the clinical staff performing the monitoring and management services are direct employees of the billing practitioner or the practitioner’s practice. The staff need not be physically located at the practice site, and the beneficiary need not be on-site, but the existing “incident to” requirements and general supervision standards must still be met.
CMS seems to be reacting to OIG’s identification of third parties that provide outsourced remote services only via telephone and online contact and have little to no established relationship with the beneficiary or members of the care team. CMS explained that it does not believe that remote monitoring “provided by clinical staff contracted through a third party can ensure the billing practitioner has adequate oversight, management or collaboration to bill RPM or RTM services.”
If finalized, this requirement would effectively foreclose billing arrangements in which physician practices contract with third-party companies to perform remote monitoring on their behalf. CMS has asked stakeholders to comment on how prevalent these arrangements are today and how this restriction might affect beneficiary access to remote monitoring services. If finalized, this provision would take effect January 1, 2027.
Lower Payment Rates Through New Crosswalks
CMS believes several RPM and RTM codes may be overvalued because of a lack of reliable data on the actual devices and costs involved. To address this, the agency proposes to re-crosswalk the practice expense inputs for the setup/education codes to self-measured blood pressure education codes, and to crosswalk device supply codes to either self-measured blood pressure device supply or external ECG event recording codes. For the treatment management codes, CMS proposes to eliminate practice expense inputs altogether, reasoning that the clinical labor costs are already captured in the work RVUs. CMS is seeking comment, including actual invoices and pricing data, on the real-world costs of devices used in RPM and RTM.
On the Horizon: Consolidation into Four New G-Codes
In addition to the formal proposals above, CMS is soliciting comment on a fundamental restructuring to collapse all 17 existing RPM and RTM codes into just four new HCPCS G-codes: two for RPM (one for initial setup/education and one bundled monthly code) and two for RTM, using the same structure. Before the code could be billed, each bundled monthly code would require the practitioner to furnish all three service components, including device supply, at least two days of data transmission, and at least 20 minutes of treatment management including a real-time interactive communication with the patient or caregiver.
CMS emphasizes that this is a comment solicitation only; the agency has not formally proposed to adopt the G-codes at this time and would consider doing so only after reviewing public input. However, it is clear that CMS wants to simplify the code structure while ensuring that billing reflects delivery of complete, clinically meaningful monitoring services.
What This Means for Healthcare Providers and Digital Health Companies
If finalized as proposed, these changes would significantly reshape the remote monitoring landscape. Physician practices that currently outsource monitoring to third-party vendors would need to bring those functions in house or restructure their arrangements. Remote monitoring and digital health companies that bill under a contracted-services model will need to reconsider how they go to market. All stakeholders should prepare for potentially lower reimbursement rates. The comment period closes September 14, 2026, and CMS has specifically invited data and stakeholder perspectives on several of these proposals, making this an important window to shape the final rule.
If you have any questions on how this proposed CMS change to RPM and RTM could impact your business, please contact the authors.