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Frequently Asked Questions: Remote Patient Monitoring Changes in the 2027 PFS Proposed Rule

Since the Centers for Medicare & Medicaid Services (CMS) issued the 2027 Medicare Physician Fee Schedule Proposed Rule on July 14, practices, providers, and technology organizations have formulated dozens of questions about what the provisions might mean. 

We’ve provided answers to some of those questions, using the rule text, the regulations CMS cites, public data, and our internal data as a care management and remote patient monitoring organization. Find answers to your questions before Sep. 14, the last day to leave comments on the provisions.

The CMS Provisions

1. What changes is CMS proposing for Remote Patient Monitoring? 

The Proposed Rule contains three provisions that would impact Remote Patient Monitoring, plus a request for comment on a fourth. 

1. A contracted-staffing restriction: Medicare would pay for RPM only when the clinical staff furnishing the service are employed by the billing practice, forbidding contracted staff from third-party organizations. 
2. A mandatory initiating visit: a separately billed, face-to-face encounter where monitoring is discussed, required before monitoring can begin.
3. Dramatically reduced reimbursements for device supply and treatment management codes, set by crosswalking them to the self-measured blood pressure codes.
4. CMS also solicits comments on collapsing seventeen remote monitoring codes into four bundled G-codes, which can only be billed when all requirements of the bundled code are met. 

2. When would the changes take effect? 

If finalized, the changes would take effect January 1, 2027. The comment period on the Proposed Rule closes September 14, 2026, and the Final Rule typically comes out in early November.

3. What does the contracted-staffing restriction change?

Currently, remote patient monitoring services can be provided by auxiliary staff, defined by CMS as "any individual who is acting under the supervision of a physician (or other practitioner), regardless of whether the individual is an employee, leased employee, or independent contractor of the physician” (42 C.F.R. 410.26(a)(1)). Under the existing model, the billing provider orders the service, establishes the patient relationship, provides general supervision, and performs medical decision-making. Contracted staff are allowed to reach out to RPM patients the provider has approved to ask if they want to enroll, to review the remote data patients submit, and to provide care management based on that data, under the provider’s general supervision.

Currently, around 60-70% of practices use contracted staff for RPM, according to the American Telemedicine Association. If the provision passes, all practices offering RPM would have to switch to using in-house staff within two months or end their programs. 

4. What is a mandatory initiating visit?

RPM already requires an established relationship between the provider and the patient. The patient must also consent to join RPM, and that consent must be documented. The Proposed Rule adds an additional, separately billed visit where the provider must specifically discuss remote monitoring with the patient.

With roughly one million Medicare enrollees receiving RPM annually, according to the HHS Office of the Inspector General, requiring an additional evaluation and management visit would add tens of millions of dollars in new Medicare spending, plus an additional cost for patients, most of whom must pay 20% coinsurance. It would also require providers to take time away from practicing medicine to explain coinsurance and compliance requirements, an area many providers rarely discuss.

5. How much would payments change?

The Proposed Rule suggests crosswalking the current RPM CPT codes, 99453, 99454, and 99445, to CPT codes 99473 and 99474, the self-measured blood pressure codes. Those codes involve a cuff the patient buys themselves. They don’t account for shipping a device to the patient, cellular or Bluetooth connectivity, a software platform, or support with broken or damaged devices. 

Code	2026 national rate	Proposed change
99453 setup and education	about $22	Crosswalk to 99473, about $15
99454 device supply, 16 to 30 days (must choose between 99454 and 99445)	about $52	Crosswalk to 99474, about $18
99445 device supply, 2 to 15 days (must choose between 99454 and 99445)	about $52	Crosswalk to 99474, about $18

All code reimbursements are available at https://www.cms.gov/medicare/physician-fee-schedule/search. The crosswalk proposals are presented on pages 43893-43894 of the Proposed Rule. Because 99453 is not reimbursed every month, the per-patient, per-month reimbursement for 2026 comes out to an average of around $52,* according to John Jepsen, Executive Vice-President of Finance for ChartSpan. Under the proposed changes, payments in 2027 would drop by 65%, rendering running an RPM program too expensive for many practices.

*Results may vary by provider. 

6. What would bundling the RPM codes mean? 

Though this concept will not take effect in 2027, CMS is seeking comments on bundling RPM codes into one monthly code, billable only when a practice delivers all of the following in the same calendar month: device supply, data transmission, at least 20 minutes of treatment management, and at least one real-time interactive communication.

The challenge here is that practices would lose reimbursement if a patient doesn’t choose to engage by phone or video call, even if they collected, reviewed, and acted on all of the patient’s clinical data. This puts pressure on the practice to disenroll patients who don’t engage one month. But the patients most likely to miss a month of contact are those with limited phone or Internet access, meaning low-income patients could be disproportionately unenrolled from the program. 

What These Provisions Would Mean for Practices and Patients

7. What happens to practices who use contractors or third parties for remote monitoring on January 1, 2027?

If the Final Rule adopts all of these proposed provisions, practices would have to bring their programs in house between when the Final Rule comes out (usually early November) and January 1. If they don’t have the staff or technology infrastructure to bring the program in-house, they’ll be forced to shut it down, causing patients to lose access to RPM. 

8. How would these proposed provisions impact rural and safety-net providers?

Rural Health Clinics, Federally Qualified Health Centers, and rural independent practices are unlikely to have enough staff to bring monitoring in-house and run initiating visits. They would also be dramatically impacted by the reimbursement cuts, since many of them have thin operating margins. This would force many FQHCs, RHCs and rural practices to end their RPM program or avoid launching one, cutting off access to RPM for low-income and rural patients. 

9. Does remote patient monitoring, as it is now, impact patient health outcomes?

Yes. In a 2023 study, patients with hypertension who enrolled in Remote Patient Monitoring saw higher rates of medication refills and fewer acute care encounters. Validic, now part of ChartSpan, completed a case study that saw well-controlled hypertension rates rise from 46% to 55.3% when FQHC patients were provided with blood pressure cuffs and remote monitoring.

A separate remote monitoring program saw a 0.9-point HbA1c reduction across 6,463 diabetic patients and improved ejection fraction in 66% of monitored heart failure patients with follow-up data. RPM is helping patients better manage conditions like hypertension, diabetes and heart failure and reduce their risk of hospitalization.

Why CMS Is Proposing Changes

10. Why does CMS want to reform Remote Patient Monitoring? 

CMS cites two reports from the HHS OIG in the Proposed Rule: "Additional Oversight of Remote Patient Monitoring in Medicare Is Needed" (OEI-02-23-00260, September 2024) and the data snapshot "Billing for Remote Patient Monitoring in Medicare" (OEI-02-23-00261, August 2025). The reports found that RPM had grown rapidly, with more than one million beneficiaries, and that 43% did not receive all the components of remote monitoring the same month. These findings led to a push for reform. 

11. Did the OIG report find fraud in remote monitoring?

No. The 2025 snapshot’s Limitations section states that OIG’s findings "do not confirm that a particular medical practice is engaging in fraudulent or abusive practices or does not meet Medicare billing requirements for remote patient monitoring."

The 43% finding justifies more in-depth record review, as do the findings that there were practices with no documented relationship to patients or multiple practices billing for one patient. However, none of these alone are proof of widespread fraud. 

12. Why did 43% of patients not receive all three components of remote monitoring? 

The 2024 report found that 43% of patients enrolled in RPM did not have all three claims for RPM: device supply, transmission of data, and RPM care management. However, in some cases this may be because providers were using the codes correctly.

CPT code 99453 is billable only once per patient and device, so a patient enrolled in RPM in 2024 would correctly show zero setup claims in 2025. Even for patients who are new to the program, many practices do not bill 99453 because the reimbursement is so low.

Practices are not able to bill the care management codes, such as 99457 and 99458, if they did not have a real-time, interactive engagement with the patient in a month. Many patients submit device data without engaging in a phone or video call each month, and the practice didn’t bill for care that was not provided. This is proof of compliance, not fraud.

Finally, when the report was written in 2024, 99454 could only be billed if the patient transmitted for 16 or more days out of the month. Many patients submitted data for 15 or fewer days, missing this threshold and stopping their provider from billing the code. CMS tried to fix this problem by adding code 99445 in 2026, showing that the organization recognizes practices could offer legitimate RPM but not be able to bill 99454.

13. Is change needed based on the OIG reports’ findings? 

Yes, there are several areas where RPM could improve. For example, if there are concerns about the relationship between a provider and patient, CMS could require a documented provider order for each patient enrolled in RPM. Remote Patient Monitoring organizations could also be given an identification number that must be included on claims.

CMS also noted that they have little data around how much device hardware, connectivity, and software costs. RPM organizations and practices could assist by providing this data to CMS, if they put out a request for information.

What providers, practice staff, and patients can do

14. What can I do if I’m concerned about the Proposed Rule?

Two of the most powerful things you can do are to join a coalition of those who share your concerns and to leave a comment for CMS. ChartSpan leads the Save Remote Patient Monitoring Coalition, which you can sign up for here: saveremotepatientmonitoring.com. You can also sign the Alliance for Connected Care letter.

15. How do I submit a comment to CMS? 

Comments are due by September 14, 2026, on the Federal Register website. We encourage you to make your comments as specific as possible. If you already offer Remote Patient Monitoring, discuss how it has impacted your patients and how your program would be affected if the provisions pass. If you don’t offer it yet, share whether the provisions would stop you from doing so. If you have data cost information or invoices, share them with CMS. More information will help them make the best possible decision. 

Sources

• CY 2027 Medicare Physician Fee Schedule Proposed Rule (CMS-1848-P), Remote Monitoring section, issued July 14, 2026 and published in the Federal Register July 16, 2026. 
• CMS CY 2027 PFS fact sheet, cms.gov/newsroom/fact-sheets/calendar-year-cy-2027-medicare-physician-fee-schedule-proposed-rule.
• Comment portal: regulations.gov, docket CMS-2026-2377.
• 42 C.F.R. 410.26(a)(1), definitions of auxiliary personnel, independent contractor, and leased employment.
• HHS-OIG, "Additional Oversight of Remote Patient Monitoring in Medicare Is Needed," OEI-02-23-00260, September 2024.
• HHS-OIG, "Billing for Remote Patient Monitoring in Medicare," OEI-02-23-00261, August 2025.
• Becker's Hospital Review analysis of the CY 2027 proposed rule, https://www.beckershospitalreview.com/healthcare-information-technology/telehealth/health-systems-trade-groups-oppose-cms-proposed-remote-patient-monitoring-ban/. 
• Validic, now part of ChartSpan, clinical outcomes data, at validic.com/case-studies/. 
• Save Remote Patient Monitoring Coalition, saveremotepatientmonitoring.com.