Overview

On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) announced the CY 2027 Medicare Physician Fee Schedule proposed rule,¹ which would materially change how remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services are reimbursed. Among other changes, CMS proposes to limit RPM and RTM to established patients, require a qualifying initiating visit before monitoring services begin, and restrict billable monitoring activities to clinical staff employed by the billing practitioner or practice. CMS also proposes revisions to the practice expense assumptions underlying payment for setup, device supply, and treatment management services, which could affect reimbursement levels. In addition, CMS seeks feedback on a broader coding reform that could replace the current 17 RPM and RTM codes with four bundled codes. If finalized, these changes may force RTM and RPM vendors and providers to revisit existing care delivery and contracting models before the requirements take effect on January 1, 2027. Comments are due September 14, 2026.

How RPM and RTM Work Today

RPM uses medical devices to collect and automatically transmit physiologic data, such as weight, blood pressure, pulse oximetry, and respiratory flow rate, for review and treatment management by a billing practitioner.² RTM, on the other hand, involves the collection and monitoring of non-physiologic data related to a patient’s therapeutic response or adherence to treatment, including information regarding a patient’s musculoskeletal or respiratory system, treatment adherence (e.g., medication compliance), and treatment response (e.g., pain management).³ Importantly, while RPM and RTM data may both be transmitted electronically, only RTM data can be self-reported by the patient using the device.

Although RPM and RTM monitor different types of patient data, both code families are structured around three core service components:

• Setup and education: Initial training on the equipment, including setup, calibration, and patient education.
• Device supply and data: For RPM, connected-device recordings or alerts and data transmission. For RTM, device supply for access to or transmission of therapy data. RTM categories include respiratory, musculoskeletal, and cognitive behavioral therapy monitoring.
• Treatment management: The practitioner or qualified health professional reviews the data, develops or adjusts a treatment or therapy plan, and manages the patient. Time-based codes include required patient or caregiver interaction where specified.

Medicare does not require a practice to bill all three components for every patient. RPM and RTM may also be billed concurrently with chronic care management (CCM) and certain other care-management services, so long as practitioners do not double count time. RPM and RTM, however, generally may not be billed concurrently for the same patient.

Proposed Changes

CMS’s proposal appears to reflect concerns raised in recent Office of Inspector General (OIG) reports regarding the growth of RPM, including inconsistent documentation of service components, limited patient-practice relationships in some monitoring programs, and Medicare’s lack of visibility into key aspects of RPM service delivery. OIG characterized these findings as indicators for further oversight rather than proof of fraud or noncompliance, but they help explain the agency’s proposed approach. Specifically, the proposed rule includes the following:

1. Clinical Visit Before Monitoring

During the COVID-19 public health emergency, CMS allowed RPM services to be initiated for new patients. After the emergency ended, CMS reinstated the established patient requirement while treating patients already receiving remote monitoring during the emergency as established patients. The CY 2027 proposal would extend a similar established patient requirement to RTM and would require a qualifying initiating visit for both RPM and RTM before monitoring services begin. CMS reasons that a practitioner with an existing relationship would have had the opportunity to gather relevant history, conduct an exam when appropriate, and develop the baseline clinical picture needed to order monitoring and manage a patient under a treatment or therapy plan.

In addition, CMS would require that both services be initiated during a separately reportable face-to-face visit, in person or by telehealth, conducted by the billing practitioner. In other words, that face-to-face visit needs to be separately payable under Medicare and RPM or RTM must be discussed at the visit; a visit that does not address RPM or RTM would not satisfy the requirement.

The practical effect is that many patients would need to see the billing practitioner before RPM or RTM services could begin. Models that rely on outreach, enroll patients remotely, and ship or activate monitoring devices before a qualifying visit may no longer satisfy Medicare’s billing requirements. As a result, practices and vendors may need to redesign enrollment workflows, add appointment capacity, and account for delays between patient identification and the start of monitoring services.

2. Direct Employment of Clinical Staff

Today, many practices furnish RPM and RTM through third-party vendors, including vendors whose clinical staff may have no prior relationship with the patient, care team, or billing practitioner. CMS believes these arrangements can fragment care, weaken practitioner oversight, and create compliance risks. To address those concerns, CMS proposes limiting billable RPM and RTM services to clinical staff who are employed by the billing practitioner or practice and who otherwise satisfy Medicare’s "incident to" requirements.⁴ The proposal does not prevent practices from purchasing devices, software, or technology services from vendors. Rather, it restricts who may perform the clinical work that generates Medicare reimbursement.

The practical consequence is that some vendor-supported monitoring models may need substantial restructuring. A practice could continue using a vendor’s technology platform while shifting patient monitoring and treatment management activities to its own employed clinical staff. By contrast, models that rely on vendor-employed nurses or other clinical personnel to perform the billable monitoring work may no longer qualify for Medicare reimbursement in their current form.

CMS specifically seeks comment on how practices currently staff RPM and RTM programs and whether a direct employment requirement could affect patient access to monitoring services. That request suggests the agency is still evaluating the operational and access implications of the proposal.

3. Value of Existing Codes

Within the proposed rule, CMS proposes to revise the practice expense (PE) inputs for each of the three service components, applying crosswalks to existing codes for setup and device supply. PE is the portion of Medicare payment intended to reimburse the costs of furnishing a service, including clinical staff time, equipment, and supplies. When CMS believes an existing code provides a reasonable benchmark for those costs, it may "crosswalk" to that code’s practice expense inputs rather than develop entirely new assumptions. In other words, if CMS crosswalks an RPM code to a blood-pressure calibration code, it is using that code as a proxy for estimating costs.

Specifically, CMS proposes the following:

Component	Affected codes	Proposed approach
Initial setup and education	RPM 99453; RTM 98975	Crosswalk direct PE inputs from 99473, a self-measured blood-pressure setup and training code
Device supply and data	RPM 99445 and 99454; RTM 98976-98978 and 98984-98986	Crosswalk RPM to 99474 (self-measured blood-pressure data and reporting); RTM to 93270 (external cardiac event recording)
Treatment management	RPM 99470, 99457, and 99458; RTM 98979-98981	Remove separate PE inputs; retain current work RVUs and work times

The reference codes CMS selected are not new clinical requirements and are instead pricing benchmarks CMS believes more accurately reflect what it actually costs to furnish each component. CMS acknowledges that it has received limited information about the actual costs of remote monitoring devices and believes current payment rates may overstate the resources required to furnish these services. As a result, the proposal puts downward pressure on payment for setup and device-supply codes.

CMS is specifically seeking information on the types of devices commonly used, the prices providers actually pay after discounts, whether those prices reflect hardware, software, or both, and the clinical workflow associated with device setup and patient education. The ultimate valuation of these codes will depend heavily on the record developed during the comment process. Companies and providers with real-world data on pricing, staffing, and workflow should consider submitting it, as that information could directly influence future Medicare payment rates.

4. Replacement of 17 Codes with 4 Codes

CMS is considering a fundamental redesign of Medicare’s RPM and RTM coding structure. Rather than maintaining 17 separate codes for different service components, CMS is seeking comment on replacing them with four bundled Medicare G-codes. The agency’s goal is to simplify billing, reduce administrative complexity, and better ensure that patients receiving remote monitoring also receive active clinical management.

Under the current framework, providers can bill individual service components separately. For example, a practice may bill a device supply code even if it does not bill treatment-management services during the same month. The proposed G-codes would move away from that approach. Instead, device supply, data collection and transmission, and treatment-management activities would be bundled into a single monthly service. As a result, providers generally would need to furnish all required elements of the bundled service before billing the monthly code. Specifically, CMS proposes the following:

Code	Function	Required elements
GRPM1	RPM setup	Initial setup and patient education
GRPM2	Monthly RPM	Device supply with daily recordings or programmed alerts; at least 2 days of data transmission; at least 20 minutes of treatment management; at least one real-time interaction with the patient or caregiver
GRTM1	RTM setup	Initial setup and patient education
GRTM2	Monthly RTM	Device supply for data access or transmission; at least 2 days of data transmission; at least 20 minutes of treatment management; at least one real-time interaction with the patient or caregiver

That shift could have significant implications for vendor and provider business models. Companies that provide only one part of the remote-monitoring ecosystem (e.g., devices, data transmission services, or a discrete clinical function) may find it more difficult to fit within a Medicare billing pathway built around a comprehensive monthly service. Likewise, practices that currently rely on billing selected RPM or RTM components may need to rethink their workflows if separate payment for partial monthly services is no longer available.

Importantly, this proposal would apply only to Medicare Physician Fee Schedule payment. It would not eliminate the underlying CPT codes, require commercial insurers to adopt the four-code structure, or change how non-Medicare payers choose to cover and reimburse remote-monitoring services. For that reason, companies could find themselves operating under one coding framework for Medicare and a different framework for commercial payers.

What Companies Should Know

CMS repeatedly acknowledges that it lacks detailed information about the costs and operational realities of RPM and RTM services. As a result, the agency is actively seeking data from providers, technology companies, and remote-monitoring vendors on both payment and staffing issues.

In particular, CMS is requesting information on:

• The types of devices typically used to furnish RPM and RTM services.
• The amounts providers actually pay for those devices.
• Common pricing arrangements, including discounts and other purchasing terms.
• Whether device pricing reflects hardware only, software only, or a bundled hardware and software offering.
• Operational data regarding the resources needed to furnish remote monitoring services.
• Evidence on the likely impact of the proposed direct employment requirement for clinical staff.

CMS has indicated that the final payment rates and operational requirements will depend in part on the evidence developed during the comment process. Providers, device manufacturers, software companies, and remote-monitoring vendors with data on pricing, staffing models, workflows, or access impacts therefore have a meaningful opportunity to shape the final rule.

To better understand how these proposals may affect your business or for assistance in addressing these regulatory proposals, please contact Wilson Sonsini attorneys Jodi Daniel, Ty Kayam, Andrea Linna, Seamus Taylor, or any member of Wilson Sonsini’s Healthcare and FDA Regulatory practice.

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[1] Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program, 91 Fed. Reg. 43842 (proposed July 16, 2026)

[2] Centers for Medicare & Medicaid Services, Remote Patient Monitoring, available at https://www.cms.gov/medicare/coverage/telehealth/remote-patient-monitoring (last visited Aug. 3, 2026).

[3] U.S. Department of Health & Human Services, Billing for Remote Patient Monitoring, Telehealth.HHS.gov, available at https://telehealth.hhs.gov/providers/best-practice-guides/telehealth-and-remote-patient-monitoring/billing-remote-patient (last visited Aug. 3, 2026).

[4] Medicare’s "incident to" requirements are the billing rules that allow non-physician practitioners (NPPs), such as physician assistants or nurse practitioners, to bill outpatient services under a supervising physician’s name.