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Why We Are Launching a Coalition to Save Remote Monitoring

By Christine Hawkins, Chief Executive Officer, ChartSpan

Remote patient monitoring is one of the clearest wins in modern preventive care. It lets a clinician see a patient's blood pressure, weight, or blood sugar change day to day, and act before a small problem becomes a hospitalization. For millions of Medicare patients managing chronic conditions at home, that daily line of sight is the difference between staying well and ending up in an emergency room.

That is why the Calendar Year 2027 Physician Fee Schedule proposed rule concerns me so deeply, and why ChartSpan is helping to launch Save Remote Monitoring, a coalition of providers and remote monitoring companies committed to protecting this benefit. We are organizing under one banner: #SaveRemoteMonitoring.

Let me be clear about what this coalition is and is not. We are not here to defend bad actors or to resist accountability. We will stand with CMS on real enforcement. We are here to stop good policy intentions from being executed with a blunt instrument that will hurt patients and the responsible organizations that serve them. The rule contains four provisions that do exactly that, and we oppose all four.

What CMS is proposing, and why you should oppose it

The proposed rule, released in July 2026 with comments due September 14, 2026, would make four consequential changes to remote patient monitoring and remote therapeutic monitoring. Here is each one, and why it is wrong.

1. A ban on contracted clinical staff

The change that keeps me up at night is a prohibition on paying for monitoring performed by contracted clinical staff, limiting payment to staff employed directly by the billing practice. It reverses a position CMS took deliberately. In the CY 2021 Physician Fee Schedule, CMS confirmed that the clinical staff furnishing remote monitoring may be employees of a third party working under the billing practitioner's general supervision. Thousands of practices built compliant programs on that guidance. A rural clinic with two physicians and no capacity to hire, train, and manage a monitoring team can still offer monitoring today because a partner provides that clinical staff under the practice's direction. Take that away, and those patients simply lose access. No fraud is prevented. Care is removed.

2. A mandatory face to face initiating visit

CMS would require a separately reportable initiating visit before monitoring can begin. I understand the instinct, but this is the wrong tool. It puts a barrier in front of the patients who need monitoring most: the homebound, the rural, the mobility limited, and the frail. These are exactly the people for whom getting to an office is hardest, and exactly the people remote monitoring was built to reach. A physician's order and documented patient consent already establish that the service is medically necessary. Forcing an extra in person visit on top of that delays care for some patients and denies it to others. That is not a safeguard. It is an access barrier.

3. A crosswalk revaluation that cuts reimbursement

CMS proposes to revalue the device supply codes downward, reasoning that the devices now cost less. But the crosswalk behind the cut does not reflect what it actually takes to deliver monitoring: FDA cleared connected devices, cellular connectivity, secure logistics to get a device into a patient's home, and a clinical team reviewing data every single day. When you set payment below the cost of the service, programs do not get leaner. They close. Cutting the rate does not remove waste. It removes access, and it does so for the patients least able to absorb the loss.

4. Bundling the remote monitoring codes

CMS is also weighing collapsing the distinct monitoring codes into a handful of new bundled G-codes. Setup, device supply, and monthly treatment management are genuinely different services, performed at different times, requiring different work and different documentation. Bundling them hides that work, destabilizes the economics of every compliant program, and forces practices to rebuild billing systems they spent years getting right. It solves no problem anyone has documented. It simply trades a transparent, well understood code set for a blunt one. 

A closer look at the OIG data

CMS has justified these changes by pointing to oversight work from the HHS Office of Inspector General. I have read that work closely, and it does not support what is being built on top of it.

The most quoted statistic is that roughly 43 percent of remote monitoring enrollees did not receive all three components of the service. That figure has been characterized by some as evidence of widespread abuse. In the coalition's view, the data does not support that conclusion.

That number simply measures whether education and setup, device supply, and treatment management all showed up together in the claims data during a fixed study period. Patients enroll partway through a period. Patients get better and stop. Some patients clinically need only part of the service. OIG offered the figure to raise questions worth studying. It never concluded that 43 percent of this care was improper, and treating it that way is a serious misreading.

The same is true of the finding that Medicare often could not identify the ordering provider. That is a limitation in the data fields Medicare collects, not evidence that no one ordered the care. And the alarm over rapid growth, from tens of thousands of enrollees to hundreds of thousands in a few years, describes exactly what happens when a valuable benefit reaches the aging, chronically ill population it was designed for. We should not mistake adoption for abuse.

Enforcement, yes. This rule, no.

If real problems exist, let’s surface the data that supports those problems, and fix them.. If enrollment mills sign up patients who have no relationship with the billing provider, then audit and prosecute those entities. If operators bill for devices that never transmit meaningful data then those practices should be stopped.  This coalition will support CMS every step of the way on genuine enforcement: audits, recoveries, and prosecutions aimed at the bad actors.

But none of the four provisions in this rule is enforcement. Each one targets the compliant majority, the at risk patient, or the honest economics of delivering care. You do not need to force a frail patient into an office, cut payment below cost, outlaw a staffing model CMS itself approved, or bundle away the detail that keeps billing honest in order to catch fraud. Those are separate problems, and the rule confuses them.

What we are asking

Save Remote Monitoring is asking CMS to withdraw all four provisions and to replace them with the enforcement the data actually calls for. Protect a benefit that is keeping Medicare patients healthier at home, and go after the people abusing it.

If you are a provider organization or a remote monitoring company, we want you with us. Join the coalition and find model comment language, data, and updates at the Save Remote Monitoring landing page. Then file your own comment through Regulations.gov under file code CMS-1848-P before September 14, 2026. The public record is how this rule gets fixed, and every voice on it counts.

This benefit was hard won. Let's not lose it to a well intentioned mistake. #SaveRemoteMonitoring

Formal participation and submission of public comments

To ensure your voice is documented before the September 14, 2026, deadline at 5:00 p.m. ET, clinicians and stakeholders are encouraged to utilize electronic filing for immediate confirmation:

1. Navigate to the formal regulatory docket at Regulations.gov referencing file code CMS-1848-P for the CY 2027 Physician Fee Schedule.
2. Locate and select the "Comment" option prominently displayed on the docket landing page.
3. Input your testimony directly or upload a comprehensive Word or PDF document. For evidence-based, data-rich submissions, a formal attachment is preferred. Ensure the header of your submission clearly cites CMS-1848-P and identifies the specific provision(s) of the proposed rule you oppose. 
4. Finalize the required fields, indicating your status as an individual or organizational representative, and retain the provided tracking number for your records.

While written correspondence is accepted via mail at the addresses specified in the Federal Register, the coalition recommends electronic submission to guarantee a verifiable record of your advocacy.

Effective advocacy depends on specificity; CMS prioritizes submissions that provide tangible operating costs and sourced labor figures over subjective feedback. We urge practices to attach relevant invoices and economic data to substantiate their position.

About ChartSpan

ChartSpan is one of the largest managed service providers of Remote Patient Monitoring, Chronic Care Management, and preventive care programs in the United States. Through its national clinical team, available 24/7/365 with a 30 second average response time, ChartSpan helps provider organizations improve outcomes, drive care gap closure, and build durable care management revenue.