CMS’s Proposed 2027 RPM Changes

On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year 2027 Medicare Physician Fee Schedule proposed rule. For remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM), the rule signals a shift toward stronger safeguards around patient relationships, clinical staffing, provider oversight and payment.

The rule is not final. CMS may revise or decline to adopt any of these policies after reviewing public comments. If finalized as proposed, however, the changes would generally take effect January 1, 2027 and could materially affect how remote monitoring programs are initiated, staffed, documented and financed.

Why CMS Is Reconsidering Remote Monitoring Policy

The proposals follow increased scrutiny from the U.S. Department of Health and Human Services Office of Inspector General (OIG). OIG reported rapid growth in Medicare RPM use and identified program-integrity concerns, including beneficiaries who did not receive all components of RPM, practices billing for patients with little or no prior relationship to the practice, multiple providers billing for the same patient and billing for multiple monitoring devices.

CMS’s response is not a rejection of remote monitoring. It is an effort to ensure that RPM and RTM remain connected to an established clinical relationship, an appropriate treatment plan and meaningful management of the data being collected.

The Central Operational Change: Who Performs the Clinical Work

Since 2020, CMS policy has permitted leased or contracted clinical staff to furnish certain RPM services under the billing practitioner’s general supervision. Many remote monitoring vendors therefore offer a turnkey model in which vendor-employed nurses or other clinical staff review data, contact patients, document time and escalate concerns while the physician practice bills Medicare.

CMS is now proposing to allow payment for RPM and RTM services performed by clinical staff only when those individuals are employed by the billing practitioner or the practitioner’s practice. The proposal does not require those employees to be physically located in the practice; remote employees could still perform the work, subject to the applicable supervision, incident-to and other billing requirements.

If this provision is finalized as written, time spent by vendor-employed or other contracted clinical staff would no longer support Medicare billing for the affected clinical-staff services. The most immediate impact would be on outsourced treatment-management models.

Technology partnerships would remain permissible

The proposal would not prevent practices from purchasing technology and nonclinical support from outside vendors. Healthcare organizations could continue to use third parties for:

• Connected medical devices and cellular connectivity.
• Software platforms, dashboards and patient work queues.
• Device logistics, activation and replacement.
• Technical support and troubleshooting.
• Implementation, training, reporting and integration services.
• Workflow design and operational consulting.

The critical distinction is between a technology partner that enables the provider’s care team and an outsourced service that performs the billable clinical work on the provider’s behalf.

Other Proposed Changes That Require Planning

A separately reportable initiating visit

CMS proposes to require an initiating visit at the onset of both RPM and RTM. The visit would need to be furnished by the billing practitioner, either in person or through an eligible telehealth encounter, and RPM or RTM would need to be meaningfully discussed. The visit could be billed separately when the applicable requirements are met.

An established-patient requirement for RTM

RPM is already generally limited to established patients. CMS proposes extending that requirement to RTM, reinforcing the expectation that remote monitoring be ordered and managed within an existing treatment relationship.

Potentially lower payment rates

CMS proposes to revalue several RPM and RTM services based on its view that devices and related resources may cost less than originally estimated. The final effect will depend on the rates CMS adopts, but provider organizations should anticipate possible pressure on per-patient economics and should model staffing, device and technology costs conservatively for 2027.

Bundled G-codes are under consideration, not yet proposed for adoption

CMS is also requesting public comment on whether the existing RPM and RTM code families should eventually be replaced by four bundled HCPCS G-codes: separate setup-and-education codes for RPM and RTM and separate monthly codes that would combine device supply, minimum data-transmission requirements and at least 20 minutes of treatment management, including real-time interactive communication.

This is a request for feedback rather than a proposal to implement the G-codes for 2027. Organizations should monitor the discussion, but they should not redesign current billing workflows around these hypothetical codes unless CMS later adopts them through rulemaking.

What a Practice-Owned RPM Model Requires

Under the proposed structure, the provider organization would need to own the clinical and operational activities that connect transmitted data to the patient’s treatment plan. Depending on the final rule, state law, scope-of-practice requirements and payer policy, those responsibilities may include:

• Identifying clinically appropriate patients and confirming medical necessity.
• Ensuring the patient is established with the practice and completing the initiating visit.
• Obtaining consent and setting monitoring parameters and treatment goals.
• Employing the clinical staff who perform billable monitoring activities.
• Reviewing readings and trends, conducting patient outreach and documenting time.
• Maintaining protocols that distinguish routine outreach from issues requiring licensed clinical review.
• Escalating significant findings promptly to an RN, advanced practice practitioner or physician.
• Integrating remote monitoring information into the medical record and broader plan of care.
• Validating that all monthly billing requirements have been satisfied before claims are submitted.

Medical assistants, nurses and other appropriately trained employees may be able to support day-to-day monitoring within their permitted scope and clearly defined escalation pathways. The billing physician or qualified healthcare professional would remain responsible for the treatment plan, clinical decision-making and overall direction of the service.

General Supervision Still Requires Meaningful Oversight

The proposed employment requirement should not be confused with a requirement that the billing practitioner personally review every reading or be physically present for each staff activity. RPM treatment-management services may be furnished by clinical staff under general supervision, which permits operational flexibility.

General supervision nevertheless requires overall direction and control. A compliant, clinically meaningful program should establish who sets the care plan, how readings are prioritized, what staff may address under approved protocols, when a licensed clinician must intervene and how the billing practitioner remains informed.

Remote monitoring should not operate as a disconnected call center. The data must be used to support treatment and management of the patient’s condition.

Why Workflow Design Will Matter More Than Ever

Bringing clinical work inside the practice is not simply a hiring exercise. Without a repeatable operating model, internal staffing can create alert fatigue, inconsistent follow-up, documentation gaps and unnecessary burden on physicians.

A scalable workflow should define:

• How eligible patients are identified and presented to the ordering provider.
• Who completes enrollment, consent, education and device activation.
• How incoming readings are filtered, prioritized and assigned.
• Which issues may be managed through approved protocols.
• Which findings require RN, APP or physician review
• How patient outreach, interactive communication, time and escalation are documented.
• How the EHR and RPM platform share relevant information.
• How monthly billing eligibility is reviewed and confirmed.

With the right devices, software and workflow design, employed care coordinators can focus on the patients who need attention while providers retain visibility and clinical control.

The Carematix Approach

Carematix is designed to support practice-owned, clinically integrated remote monitoring programs. Our role is to equip and enable the provider’s care team—not replace the provider’s relationship with the patient.

Carematix supports healthcare organizations with:

• Cellular-connected monitoring devices that transmit without requiring a smartphone or home Wi-Fi.
• Practice-owned enrollment and device-activation workflows.
• Documentation, time-tracking and clinical escalation tools.
• Reporting and integration options.
• Staff training, implementation support and workflow guidance.
• Operational support for building and scaling internal care-coordination teams.

The practice retains ownership of the clinical workflow, employs and supervises the care team and remains responsible for patient management. This structure aligns technology with clinical accountability and gives organizations greater control over quality, staffing and long-term program economics.

The device partner matters

A practice-owned program also depends on reliable, simple devices and responsive support. Medical assistants and care coordinators should spend their time on patient engagement, monitoring and escalation—not troubleshooting connectivity or coordinating multiple vendors.

Because Carematix manufactures and supports its connected devices, practices can work with one partner for the platform, devices, connectivity and troubleshooting. Fewer handoffs can reduce operational burden and help internal care teams remain focused on patient care.

How Organizations Should Prepare for 2027

No organization should assume the final rule will mirror the proposal exactly. CMS may revise the employment test, initiating-visit requirement, valuations or other safeguards after reviewing stakeholder comments. Even so, practices operating or considering RPM should begin a structured readiness review now:

• Map who currently performs every clinical and nonclinical RPM activity and identify each person’s employer.
• Review vendor agreements for transition rights, staffing assumptions, term commitments and pricing changes if outsourced clinical time becomes nonbillable.
• Confirm that initiating visits, established-patient status, consent and medical necessity can be documented reliably.
• Assess whether employed MAs, nurses or care coordinators can perform the workflow efficiently within applicable scope-of-practice rules.
• Validate supervision, escalation, documentation and claim-review procedures.
• Evaluate whether the technology platform was built to empower the practice’s staff or depends on the vendor’s clinical workforce.
• Consider submitting operational and cost data to CMS before the September 14, 2026 comment deadline.

Remote Monitoring Should Strengthen the Care Team

The CY 2027 proposal has started an important discussion about what clinically meaningful remote monitoring should look like. Connected devices can make physiologic information available between visits, but that information creates value only when it is incorporated into the patient’s care.

The strongest RPM programs combine reliable devices with practice-owned workflows, trained care coordinators, timely escalation and meaningful provider oversight. Whatever CMS ultimately finalizes, organizations built around those principles will be better positioned to deliver sustainable, high-quality remote care.

Carematix will continue monitoring the rulemaking and helping healthcare organizations evaluate staffing, workflow and technology options for 2027.

Sources and further reading

• CMS: CY 2027 Medicare Physician Fee Schedule Proposed Rule fact sheet.
• Federal Register: CY 2027 PFS Proposed Rule (CMS-1848-P).
• HHS OIG: Additional Oversight of Remote Patient Monitoring in Medicare Is Needed (2024).
• HHS OIG: Billing for Remote Patient Monitoring in Medicare (2025).
• McDermott Will & Schulte: Remote monitoring at a crossroads.