CMS Proposes Changes to Medicare Physician Fee Schedule for RPM and RTM
On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) unveiled a proposed rule concerning the CY 2027 Medicare Physician Fee Schedule. This proposal aims to amend reimbursement guidelines for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM). Notable changes include confining RPM and RTM to existing patients and requiring a qualifying visit before monitoring begins. There's also a stipulation that billable services be provided by clinical staff directly employed by the billing practitioner or practice, with proposed adjustments to practice expense assumptions potentially affecting payment rates.
The proposal suggests replacing the current 17 RPM and RTM codes with four bundled codes. This change could prompt RPM and RTM vendors and providers to re-evaluate their care delivery and contractual agreements before January 1, 2027. Stakeholders have until September 14, 2026, to submit comments on these proposed changes.
At present, RPM and RTM systems utilize devices or self-reported data to monitor patient health metrics, which are reviewed by a billing practitioner for treatment management. Although these services handle different data types, Medicare allows concurrent billing with other management services, provided there is no time duplication in billing.
The CMS proposal is largely a response to issues flagged by the Office of Inspector General (OIG), such as insufficient documentation and weak patient-practitioner relationships in certain programs. Consequently, CMS proposes an initiating visit requirement for RPM and RTM to ensure practitioners can gather necessary patient histories and establish effective monitoring plans before starting services.
Furthermore, CMS suggests limiting RPM and RTM billing to clinical staff employed by the billing entity, underscoring practitioner oversight and care continuity. While vendors providing technology resources could maintain their roles, those supplying clinical personnel might need to restructure under these rules.
The proposal also includes adjusting practice expense inputs to better align reimbursement with actual service costs. CMS invites practitioners and vendors to submit data detailing their pricing and operational structures, influencing potential payment valuations.
Finally, the agency is contemplating a shift to four bundled Medicare G-codes for RPM and RTM services, aiming to streamline administration and ensure comprehensive care delivery. This could require strategic adjustments from providers and vendors managing separate service components. However, these changes pertain solely to Medicare payments, preserving commercial insurers' autonomy in their coding practices. Overall, CMS's proposed changes offer stakeholders a chance to shape the Medicare payment framework, signaling a notable shift in the administration and reimbursement of remote monitoring services.