On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) released the calendar year (CY) 2027 Medicare Physician Fee Schedule (MPFS) proposed rule (the Proposed Rule), which includes a series of significant proposed changes to the payment and coverage requirements for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services. The proposed changes are in response to two recent reports from the US Department of Health and Human Services Office of Inspector General (OIG) that raised concerns about the growth, oversight, and appropriate use of remote monitoring services.
Stakeholders that furnish, arrange, or support RPM or RTM services, including physician practices, digital health and health technology companies, and remote monitoring vendors, should review these proposed changes and consider submitting comments for CMS’s consideration on how current program structures, staffing models, and billing practices would need to adjust if these changes are finalized.
CMS has established Medicare payment for two sets of remote monitoring codes. The RPM codes took effect in 2019 and involve the collection, analysis, and interpretation of digitally collected physiologic data (such as weight, blood pressure, and pulse oximetry) followed by the development of a treatment plan and management of the patient under that plan. RTM services were established in 2022 and involve the use of medical devices to monitor a patient’s health or response to treatment using non-physiological devices. RTM can be used, for example, to monitor treatment specific to pain, functional status, and adherence and response to therapy and the RTM codes include distinct device supply codes for monitoring the respiratory system, the musculoskeletal system, and cognitive behavioral therapy.
In September 2024, the American Medical Association’s (AMA) CPT Editorial Panel added and revised several RPM and RTM codes, effective in 2026, including new device supply codes reflecting shorter and longer monitoring increments and new time-based treatment management codes. In the CY 2026 MPFS Final Rule, CMS expanded the RPM and RTM codes eligible for reimbursement, adding the new device supply codes for two to 15 days of monitoring and new 10-minute treatment management codes, along with other revisions and conforming edits to the existing RPM and RTM codes. CMS set payment rates for the broad code family using a variety of approaches that included cross-walking to the relative value units for existing codes with modifications, using Outpatient Prospective Payment System cost data to set practice expense relative value units (RVUs), and relying on Medicare Administrative Contractor pricing.
Against this backdrop, OIG has recently been focused on billing for remote monitoring services and issued two recent reports: Additional Oversight of Remote Patient Monitoring in Medicare Is Needed (2024) and Billing for Remote Patient Monitoring in Medicare (2025). In the 2024 OIG report, the agency emphasized the need for additional oversight of remote patient monitoring services to Medicare beneficiaries. Some issues highlighted by the OIG in 2024 are inherent to the RPM codes established by the AMA and may not have been problematic. Other issues underscore the lack of information CMS has about the types of health data being monitored and the devices used to provide RPM services.
The 2025 OIG report was a data snapshot with the following themes:
Both reports raised concerns about rapid growth in remote monitoring billing, gaps in oversight, and instances in which beneficiaries received some but not all components of RPM services. Many of the concerns raised by OIG are inherent in the codes. By way of example, there are separate codes for the provision of the device, training and education on the use of the device, and treatment management services associated with data transmission. OIG raised concerns with respect to patients who receive a device but do not receive treatment management services related to the monitored data.
in the Proposed Rule, CMS proposed several refinements to RPM and RTM payment policy that are intended to respond to these findings. If finalized, the changes would take effect January 1, 2027.
Since 2020, CMS has permitted clinical staff who are leased or contracted to a provider to furnish RPM services. Healthcare providers typically contract with third-party remote monitoring companies rather than relying on employed clinicians for several interrelated business and operational reasons. First, RPM and RPM requires specialized technology infrastructure – connected devices, data transmission platforms, analytics software, and cybersecurity safeguards – that most provider organizations lack the capital or technical expertise to build and maintain in-house, making it more cost-effective to license or outsource these capabilities to vendors who have already developed and validated them at scale. This typically includes clinical staff who are familiar with the technology and devices. Second, effective RPM and RTM programs depend on monitoring coverage and rapid triage of incoming physiological data, which is difficult for a provider’s existing clinical staff to sustain given competing demands on their time; third-party vendors often maintain dedicated monitoring centers staffed specifically for this continuous surveillance function. Third, specialized vendors can offer economies of scale and trained clinical staff, whereas an individual provider building a proprietary program would bear all staffing costs alone. Finally, engaging a third-party can help providers manage certain compliance safeguards and liability exposures, such as training, education, device management, and quality assurance, by shifting certain operational responsibility (though not necessarily all legal risk) to a partner whose core business is built around meeting those regulatory and quality standards.
In the Proposed Rule, CMS observed that RPM and RTM services are sometimes outsourced to third-party companies whose staff have little or no established relationship with the beneficiary, the billing practitioner, or the care team and whose interactions with patients occur only by phone or online. Citing OIG’s findings regarding “cold calling” beneficiaries to solicit unneeded remote monitoring and concerns about the transparency of “incident to” billing in this context, CMS believes this outsourcing model can fragment care, reduce the billing practitioner’s oversight, and result in services that do not reflect all required elements of RPM or RTM.
CMS proposed to permit payment for RPM and RTM services only when furnished by clinical staff who are direct employees of the billing practitioner or the practitioner’s practice, effectively eliminating third-party staffing arrangements for Medicare billing purposes beginning January 1, 2027, if finalized. Clinical staff would still need to act under the billing practitioner’s general supervision and satisfy the other “incident to” requirements under 42 C.F.R. § 410.26. Notably, clinical staff would not need to be physically located within the practice.
The proposed changes to supervision would not impact the ability of providers to purchase software and technical services from third-party vendors. However, practically speaking, many providers purchase software, devices, and related clinical support services from third parties, making this a potentially seismic change in the way RPM services are delivered in the market (if CMS finalizes the changes as proposed).CMS is seeking comments on how frequently third-party billing arrangements currently occur and how this proposal could affect beneficiary access to remote monitoring services.
CMS proposed to revalue several RPM and RTM codes, effectively reducing the reimbursement rate for the codes, citing a lack of reliable invoice and pricing data on the devices actually used for remote monitoring and voicing concern that current valuations may be overstated. Specifically, CMS proposes to:
CMS is seeking comments on typical device costs, invoicing practices, and clinical workflows to help inform the final valuations.
Although CMS is not proposing to modify or change the RPM and RTM codes at this time, the agency is soliciting comments on the creation of new Healthcare Common Procedure Coding System (HCPCS) codes that would potentially replace the current RPM and RTM codes.
CMS also flagged the administrative burden associated with the growing number of separate RPM and RTM codes (17 codes in total) and noted OIG’s finding that roughly 43% of enrollees receiving RPM did not receive all three components of the service (education and set-up, device supply, and treatment management), raising questions about whether remote monitoring is being used as intended. CMS is soliciting comments on potentially replacing the current 17 RPM and RTM codes with four new bundled HCPCS G-codes: GRPM1 and GRTM1 (initial set-up and education for RPM and RTM, respectively) and GRPM2 and GRTM2 (bundled monthly codes each combining device supply; a minimum number of days of data transmission; and at least 20 minutes of treatment management, including at least one real-time interactive communication with the patient).
Under this approach, all service elements described in a given G-code would need to be furnished every calendar month for the code to be billed, and the G-codes would incorporate the established patient, initiating visit, and staffing/supervision proposals described above, if finalized, along with the other existing conditions of payment for RPM and RTM. CMS believes bundling could reduce administrative burden and better ensure that beneficiaries actually receive treatment management services, consistent with OIG’s findings. CMS is also seeking comments on applying these G-codes in rural health clinics and federally qualified health centers, as well as on possible valuation approaches for the new codes. Importantly, CMS has not proposed to adopt the G-codes at this time and is soliciting general public feedback on remote monitoring payment policy more broadly.
RPM services have long been required to be furnished only to an established patient – a requirement CMS reinstated after the end of the COVID-19 public health emergency. CMS now proposes extending this established patient requirement to RTM services as well. CMS reasons that a practitioner with an existing relationship with the patient will already have collected the relevant history and, as appropriate, conducted a physical examination, giving the practitioner the information needed to appropriately order and use RTM data to manage the patient’s treatment or therapy plan. CMS states that this proposal is intended to help address OIG’s finding that some practices billed for remote monitoring services without a prior relationship with the patient.
CMS proposed to require a separately reportable initiating visit for both RPM and RTM services, which is intended to ensure adequate care coordination, allow the billing practitioner to assess clinical appropriateness, and obtain the required beneficiary consent. The initiating visit would need to be a face-to-face visit, furnished in person or via telehealth, by the billing practitioner. Visit codes that do not involve a face-to-face encounter with the billing practitioner, or that are not otherwise separately payable under Medicare, could not serve as the initiating visit. A visit at which RPM or RTM is not actually discussed with the patient likewise would not qualify. The initiating visit could be billed separately from the remote monitoring services.
The proposal to require an initiating visit prior to the onset of RPM or RTM services is somewhat consistent with an approach that CMS has taken with other care management services (e.g., chronic care management services). Of note, CMS only requires an initiating visit for chronic care management services for new patients or patients not seen within the year prior to commencement of the services.
This proposal appears aimed at addressing one of the concerns highlighted by OIG – namely, practices that bill for a high proportion of Medicare beneficiaries with no prior history with the practice.
The Proposed Rule signals that CMS intends to meaningfully respond to OIG’s recent scrutiny of remote monitoring services, and stakeholders should begin preparing now for a more restrictive regulatory environment.
In particular, stakeholders should:
Comments to the Proposed Rule are due by September 14, 2026. Given the breadth of the proposals (spanning conditions of payment, employment/staffing structure, valuation methodology, and potential wholesale code restructuring), stakeholders should begin preparing comments and consult legal counsel before submission.
We will continue to monitor developments related to this rulemaking, including the final rule that will be published later this year. Please contact the authors of this article with any questions.
