CMS proposes limiting Medicare RPM and RTM payment to services performed by practice-employed clinical staff. What practices should audit before 2027.
CMS has proposed several changes to remote patient monitoring and remote therapeutic monitoring in the CY 2027 Medicare Physician Fee Schedule. The proposal would require a separately reportable initiating visit and would allow payment only when RPM or RTM services are performed by clinical staff employed by the billing practice, rather than contractors. RTM would also be limited to established patients. The rule is proposed, not final, and comments are due September 14, 2026.
What CMS is proposing
CMS says the changes are intended to improve care coordination and strengthen the connection between the billing practitioner and the patient. The agency is also considering replacing existing remote-monitoring CPT reporting with four bundled G-codes, although the staffing and initiating-visit conditions are the immediate operational issues for many practices.
These proposals would apply to Medicare payment if finalized. They should not be treated as current billing rules, and they should not be extended to commercial or Medicaid plans without payer-specific guidance.
The vendor contract may become a billing issue
Many practices buy a remote-monitoring platform together with clinical support from an outside vendor. Technology, devices, and data transmission are only part of the workflow. When vendor contractors perform monitoring, patient communication, or treatment-management work, the employment relationship may become a payment condition under the proposal.
Azeem's operational view: the contract should describe more than service levels and technology fees. It should make clear who performs each billable activity, who employs that person, where the work is documented, and how the billing practitioner supervises and uses the information.
Audit the operating model, not only the code
Map every RPM and RTM step: the initiating visit, patient consent, device setup, data collection, clinical review, interactive communication, treatment decisions, and claim submission. For each step, record the person responsible, employment relationship, documentation location, and code or payer rule that supports the charge.
Then model the revenue that depends on contractor activity. Separate Medicare fee-for-service claims from other payers, and test what happens if contractor-delivered clinical work no longer qualifies. This creates a fact base for vendor discussions without prematurely changing compliant billing.
Prepare without treating the proposal as final
Share the proposal with clinical leadership, compliance, finance, and the vendor owner. Ask vendors to document their staffing model and identify work performed by contractors versus practice employees. Practices with material exposure can review CMS's supporting files and submit comments before the deadline.
Continue following current rules until CMS issues the final CY 2027 fee schedule. Once the final rule is published, compare the final language with the workflow map and update contracts, staffing, documentation, and billing controls only where required.
Practical takeaway
Label the staffing and initiating-visit requirements as proposed.
Map each RPM and RTM task to the person performing it and their employment relationship.
Verify the initiating visit, interactive communication, and supporting documentation.
Model Medicare revenue that depends on contractor-delivered clinical work.
Wait for the final rule before changing current billing.