CMS CY 2027 Proposed Rule: Key RPM Changes on the Table

A year ago, the story of Medicare remote patient monitoring (RPM) was expansion: the CY2026 final rule added short-duration codes and closed the gap for sub-20-minute management sessions. The CY2027 Medicare Physician Fee Schedule (PFS) proposed rule — published July 16, 2026 — swings the other way. Citing program-integrity findings from the HHS Office of Inspector General (OIG), CMS is proposing some of the most restrictive changes RPM has seen since the codes were created.

To be clear up front: this is a proposed rule, not a final one. The public comment period runs through September 14, 2026, and proposals can change substantially before finalization. But the direction CMS is signaling matters — and some of the proposals would reshape how RPM programs are staffed and launched starting January 1, 2027.

Why CMS is tightening: the OIG backdrop

Two OIG reports set the stage. A 2024 report found that roughly 43% of Medicare RPM enrollees didn’t receive all three required service components (setup, device supply, and treatment management), and flagged vendor practices like cold-calling beneficiaries to enroll them. A 2025 follow-up identified billing for patients with no established relationship to the practitioner and billing multiple devices for the same patient in the same month.

CMS’s response targets the arrangements it sees behind those findings: heavily outsourced, vendor-driven monitoring with minimal involvement from the billing practitioner.

Proposal 1: RPM staff must be employed by the billing practice

The headline change. CMS proposes that RPM and RTM services be furnished by clinical staff who are direct employees of the billing practitioner or the practice — payment would no longer be allowed when the monitoring work is performed by third-party contractor staff.

Staff wouldn’t need to sit in the practice’s office — remote work remains fine under general supervision and the usual “incident to” requirements. But the common model where an outside vendor’s nurses do the monitoring and the practice bills for it would no longer be payable under Medicare.

Proposal 2: a required initiating visit

CMS proposes that practitioners must furnish a separately reportable, face-to-face initiating visit — in-person or via telehealth — at the onset of RPM or RTM services. Visit codes without a face-to-face component wouldn’t qualify, and the monitoring service is expected to be discussed with the patient during that visit. This effectively ends “enrollment at a distance” models where monitoring begins without the billing practitioner ever seeing the patient.

Proposal 3: established patients only (now for RTM too)

RPM has long been limited to established patients. CMS proposes extending the same requirement to remote therapeutic monitoring (RTM) — no more furnishing RTM to patients who have no prior relationship with the billing practitioner.

Proposal 4: lower payment for devices and setup

CMS believes monitoring devices now cost less than its original estimates, and proposes revaluing the supply and setup codes by crosswalking them to lower-valued comparators:

• Setup/education (99453, 98975) → crosswalked to the value of 99473
• Device supply (99454 and the new 99445, plus the RTM supply codes) → crosswalked to lower-valued codes such as 99474 and 93270
• Treatment management codes (99457, 99458, 99470 and their RTM counterparts) would keep their current work values but lose their practice-expense inputs

The net effect, if finalized as proposed: meaningfully lower Medicare reimbursement per patient per month, with the device-supply codes taking the largest hit.

Proposal 5 (a request for comment): collapsing 17 codes into 4

CMS is also seeking comment on a bigger structural idea — consolidating the seventeen existing RPM/RTM codes into four bundled G-codes (GRPM1/GRPM2 for RPM, GRTM1/GRTM2 for RTM): one for setup and education, one for a monthly bundle combining device supply, minimum transmission days, and at least 20 minutes of management including real-time communication. That would replace today’s modular billing with an all-or-nothing monthly bundle. It’s only a comment solicitation for now, but it shows where CMS’s thinking is headed.

The Texas Medicaid lens: S9110 is not this rule

As always: the PFS is a Medicare rule. It does not change how Texas Medicaid (TMHP) pays for home telemonitoring under S9110, which has its own codes, prior-authorization process, and reading-day tiers — see our overview of how RPM Medicaid differs from Medicare RPM and the TMHP telemonitoring benefit specifically.

But there are two practical takeaways for Texas agencies:

1. If you bill Medicare or serve dual-eligible patients, these proposals — staffing, initiating visit, and lower device payments — would hit that part of your panel in 2027. Model the revenue impact now, and consider commenting before September 14.
2. The in-house staffing proposal favors the agency model. Home health agencies that monitor patients with their own nurses — the way the Texas Medicaid telemonitoring benefit already works — are exactly the arrangement CMS is not worried about. The programs at risk are the ones built on outsourced monitoring mills. Agencies that own their monitoring workflow, document the initiating relationship, and track every reading day and management minute are positioned well no matter where the final rule lands.

It’s the same lesson as every round of RPM rulemaking: the programs that survive policy swings are the ones whose documentation is airtight as the work happens — not reconstructed when the rules change.

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This is an educational overview of a proposed rule, not billing or legal advice. Proposals may change substantially before finalization, and Texas Medicaid (TMHP) policy differs from Medicare. Always confirm current requirements with authoritative sources and your own compliance team before making program changes.

Sources: CMS CY2027 PFS Proposed Rule fact sheet; Nixon Peabody analysis; McDermott Will & Emery analysis.