Since Medicare established reimbursement for remote patient monitoring (RPM), the program has helped clinicians extend care beyond the clinic, monitoring and supporting patients between office visits with the goal of improving outcomes and reducing time to goal. The fee-for-service framework made this model feasible for patients outside ACOs and capitated medical groups. Now, in the CY 2027 Physician Fee Schedule proposed rule, CMS is signaling that RPM’s next phase should be defined by stronger guardrails, clearer accountability, and a sharper focus on value — most notably by eliminating reimbursement for RPM and Remote Therapeutic Monitoring (RTM) services performed by contracted third-party clinical staff.
The direction to focus on outcomes is the right one. RPM success should not be judged by clinical staff time logged or claims volume. It should be judged by whether patients with hypertension achieve better blood pressure control, whether people with diabetes improve A1c, whether heart failure patients avoid preventable exacerbations, and whether care teams have actionable data in time to intervene.
CMS is also right to address fraud, waste, and abuse. Recent oversight concerns have made clear that remote monitoring cannot become a detached, transactional service in which patients receive devices without meaningful clinical integration or ongoing care-team engagement. If a program does not connect back to the treating provider, support medical decision-making, or document patient benefit, Medicare should not reward it. But third-party clinical monitoring is not inherently the problem; poor program design, execution, and outcomes are what should be identified and addressed. Seven years of experience have made best practices clear: integrate RPM data into the EMR, select patients by risk and gaps to guidelines, and build explicit escalation pathways.
What CMS Is Proposing
The proposed changes are significant. As mentioned, CMS would generally require RPM and RTM clinical staff services to be performed by direct employees of the billing practitioner or practice rather than by contracted third-party staff. It would require a separately billable initiating visit — in person or via telehealth — during which the service is discussed and consent obtained. CMS would align RTM more closely with RPM by limiting it to established patients. Lastly, it proposes valuation changes that could reduce payment for certain remote monitoring services, while seeking comment on consolidating existing RPM and RTM codes into a smaller set of bundled G-codes.
The Risk of Moving Too Fast
The goals are sound, but the market cannot absorb these changes on the proposed timeline. RPM programs are operationally complex, and many medical groups rely on both operational and clinical support from third parties to offer proactive care, especially amid ongoing staffing shortages. Many successful programs were built through partnerships that combine the clinical authority of the practice with specialized infrastructure from external organizations. It’s simply not feasible for these programs to transition to a fully in-house model in a matter of months without disrupting services that are currently benefiting patients.
A Better Path: Require Better Data
A better path would be to pair stronger accountability with better data. CMS could introduce modifier codes to gather data on the type of device used and the staffing model supporting the program to identify more precisely which programs and care delivery models are most effective. CMS could also consider requiring submission of baseline and discharge outcomes data, such as blood pressure for hypertension programs, A1c for diabetes programs, weight or symptom trends for heart failure, or other clinically relevant measures to measure the efficacy of these programs and to begin to align them to outcomes-based payment models like the ACCESS program.
That data would allow CMS to make evidence-based adjustments over time. If certain staffing models consistently produce strong outcomes and appropriate utilization, policy should recognize that. If certain arrangements show weak engagement, limited clinical improvement, or signs of abuse, CMS should act. The program should not rely on assumptions about what models work based on anecdotal evidence; it should use the data generated by RPM itself to determine which approaches improve care and provide a roadmap to new reimbursement frameworks.
This approach would also advance RPM’s evolution from a fee-for-service bridge to a value-based care capability. Remote monitoring is not merely a technology category. Done well, it is a care delivery model that helps clinicians manage chronic disease proactively, personalize interventions, and get patients to goal faster.
CMS should move forward with a framework that demands transparency, measures outcomes, and distinguishes between models based on performance. Health systems, medical groups, and vendors with RPM experience can all contribute feedback and data through the PFS public comment process between now and September 14. Reach out to the Health Recovery Solutions team with questions about structuring your RPM program around outcomes and navigating future CPT changes. HRS will be submitting commentary to CMS and would love to hear from you.
The CY 2027 proposed rule raises important questions, and CMS deserves credit for asking them. Program integrity matters. Patient outcomes matter even more. The challenge now is to avoid solving real problems with changes so abrupt that they undermine the programs already delivering value.
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