On July 14, 2026, CMS released the CY2027 Physician Fee Schedule proposed rule. Inside it is a set of changes to remote patient monitoring (RPM) and remote therapeutic monitoring (RTM). The proposal is not final, and CMS could change it in the final rule.
What CMS proposed
Under the proposed rule, Medicare would pay for RPM and RTM only when the clinical staff furnishing the service are direct employees of the billing practitioner or practice. Services contracted out to third-party companies could not be billed. The staff could still work remotely, under general supervision, as long as the other "incident to" rules are met.
The billing practitioner would also have to start RPM or RTM at a face-to-face visit, in person or by telehealth, where remote monitoring is discussed. That visit could be billed separately. RPM is already limited to established patients, and the proposal would extend that requirement to RTM.
CMS says the goal is to respond to recent OIG reports and keep remote monitoring tied to the practitioner who is accountable for the patient, because it believes outsourcing can fragment care.
Payment values would change too
Device supply is affected, but in a different way. CMS is proposing to lower the value of the RPM device supply codes because it believes they are overvalued. It is also asking for comments on replacing the current RPM and RTM codes with four new bundled G-codes. Each monthly code would include device supply, at least 2 days of data, and at least 20 minutes of treatment management.
The employment requirement applies to the clinical staff time. The proposal does not directly address device vendors that supply and transmit readings.
Who this would affect
- Practices whose clinical monitoring is done by an outside contractor would not be able to bill for that work under the proposal.
- Practices whose own employed staff do the monitoring would meet the staffing requirement, but would still be affected by the initiating visit requirement and the proposed lower payment values.
- The remote monitoring proposals do not change Chronic Care Management billing, and RPM can still be billed in the same month as CCM. The same rule does ask for comments on how care management codes might be restructured in the future.
What to do now
- Know who performs your monitoring today, and whether they are employed by your practice.
- Keep your documentation clean: patient consent, the initiating visit, the established-patient relationship, and the monitoring time.
- The public comment period closed on September 14, 2026. CMS will issue a final rule that may change these proposals, usually in early November.
How SmartOps Health helps
SmartOps Health is the software layer, not the monitor. Device data flows in, we surface what needs attention, and your own team acts on it. Whether the rule is finalized as proposed or revised, we help practices run RPM with their own employed care team, with the documentation the rules require.
Want to see where your practice stands under the proposed 2027 changes? Get a free gap scan.