CMS proposes major Medicare remote patient monitoring revisions

The Centers for Medicare & Medicaid Services (CMS) is proposing changes to Medicare billing requirements for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) that, if finalized, would disrupt common RPM and RTM arrangements involving outsourced services and add new requirements.  

The Medicare Physician Fee Schedule 2027 Proposed Rule, published in the July 16, 2026 Federal Register, includes three significant proposed changes for remote patient monitoring, in addition to RPM and RTM valuation changes:

• The billing practitioner’s practice would be required to directly employ clinical staff members who perform the monitoring, so outsourced vendor staffing would no longer be allowed.
• The established patient requirement (which currently applies to RPM) would be extended to RTM.
• RPM or RTM services would need to be initiated by the billing practitioner during a face-to-face (in-person or telehealth) visit that includes discussion of the RPM or RTM services.

As reasons for these proposed revisions, CMS cited compliance concerns raised by the HHS Office of Inspector General (OIG) about RPM in 2024 and 2025 reports. CMS expressed particular concern that outsourcing may result in fragmented care and insufficient billing practitioner involvement and oversight, stating:

"Provision of these services by entities having only a loose association with the treating practitioner can detract from longitudinal, patient-centered care. We do not believe that RPM or RTM services provided by clinical staff contracted by a third party can ensure the billing practitioner has adequate oversight, management, or collaboration to bill RPM or RTM services. If there is little oversight by the billing practitioner or a lack of clinical integration between a third-party providing RPM/RTM and the billing practitioner, we do not believe that the full scope of service elements required to bill these codes are being met."

In connection with the RPM/RTM direct employment proposal, CMS is requesting information on the use of outsourcing and on how the proposal could impact access to remote patient monitoring.  

CMS noted that it is considering bundling RPM and RTM billing codes into new codes due to concerns about administrative burdens and OIG findings of RPM patients (approximately 43%, according to the OIG report) who received fewer than all three RPM components. In particular, CMS contemplates the possible creation of four new HCPCS G-codes so that transmission/supply and treatment management (which are currently billed separately) would be billed under a single code for RPM and a single code for RTM. CMS indicated that under this contemplated approach the number of RPM and RTM codes would be reduced from 17 to 4, and that all service elements would need to be satisfied in order to bill RPM or RTM. CMS requested comments on this approach as well as other bundling possibilities.

In addition to the RPM and RTM questions specifically solicited by CMS, commenters may wish to consider suggesting alternative ways (through less disruptive changes) to address the concerns expressed by CMS, including fragmented care, lack of billing practitioner involvement and oversight, cold calling of Medicare beneficiaries, and patients who receive some but not all RPM or RTM components.

Comments can be submitted electronically or by regular, express, or overnight mail by the September 14, 2026 deadline.

For more information on remote patient monitoring, the MPFS 2027 proposed rule or related issues, please contact attorney Rick Hindmand.