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Last Chance to Make a Difference: Comments on the 2027 Proposals, That Would Harm Remote Monitoring, Close September 14

The 2027 Medicare Physician Fee Schedule Proposed Rule would bring dramatic changes to remote monitoring: cutting reimbursements, removing the option to have third-party staff support RPM, and adding an extra, in-person visit for Medicare patients before they can receive services. 

If these additions would negatively impact your practices’ ability to offer your patients RPM, now or in the future, you have until September 14, 2026, at 11:59 p.m. ET to submit comments. After that date, CMS will review comments and determine whether these damaging provisions will be finalized. 

Here’s why practices who believe in Remote Patient Monitoring should take action before September 14.

What the three provisions (and one request for feedback) would do

Each of the three provisions impacting RPM would make the service harder to offer. But together, they would render the program impossible to run for most practices, especially smaller, rural or independent clinics.

1. Restrict who may furnish the service. 

Currently, contracted clinical teams working under general supervision of the provider offer 60-70% of all Remote Patient Monitoring services. This is in keeping with CMS guidance, which states that RPM can be provided by “auxiliary personnel” under the “general supervision of the billing practitioner.”  Federal regulations define auxiliary personnel as “an employee, leased employee, or independent contractor” (42 C.F.R. 410.26(a)(1)).

Removing independent contractors and insisting that all staff offering RPM be direct employees of the billing practice is a major shift. Large health systems may be able to weather the cost of hiring and training new employees to bring RPM in-house. But many U.S. practices, especially those in rural areas, face nursing shortages. With a projected 24% shortage of nurses in rural areas in 2028, practices won’t be able to hire enough staff to offer RPM in-house. Without third-party support, they will have to stop offering RPM to patients.

2. Require a separately billed initiating visit. 

The Proposed Rule suggests requiring a face-to-face visit where remote monitoring is explicitly discussed before monitoring can begin. This would result in additional costs for Medicare and for patients, who may have cost-sharing on this additional visit.

The requirement would also add work for providers, who would have to conduct the visit and explain remote monitoring’s compliance requirements and cost-sharing estimates: an area many providers are not trained in, since it is administrative and financial work rather than medicine.

Finally, this requirement places an additional burden on patients. For many Medicare beneficiaries, especially those who live in rural areas, can’t drive, or have disabilities, attending their scheduled appointments is already challenging. Adding an extra appointment may discourage the patient from joining or continuing remote monitoring, depriving them of an in-home device and a care manager to help them manage their chronic health conditions.

3. Reduce the value of device supply codes. 

Because of a lack of data on how much RPM devices cost, CMS proposes to re-price the RPM device supply and setup codes by crosswalking them to the self-measured blood pressure codes. The problem is that self-measured blood pressure codes involve a patient-owned cuff. The practice does not have to procure, ship, and troubleshoot the device, provide Bluetooth and cellular connectivity, or assist when devices need to be fixed or replaced. 

The blood pressure codes also don’t account for the cost of software to allow data to be transmitted from the device directly to the practice. But RPM requires this software to allow data transmission, as well as for the practice to support patients with their devices. 

According to ChartSpan data, device supply, logistics and software costs roughly $68 per patient, per month, already exceeding the current device supply reimbursement of $52.11 per patient, per month (99454, 99445). If the proposed crosswalk is finalized, device supply reimbursements would drop to $18.37 (99474) per patient, per month: covering less than a third of the cost of monitoring. Many practices can’t continue to offer monitoring at such a low reimbursement rate.

This change hurts patients who now can’t join the program to monitor their blood pressure, blood sugar, blood oxygen level, or weight at home. But it especially hurts patients already in RPM, who have grown used to tracking their health data with their care team’s support and who will no longer have that option.

4. Potentially bundling codes for even more reductions.

CMS floats collapsing the current remote monitoring code set into four monthly G-codes. Under the bundled design, a practice would be paid only if device supply, data transmission, treatment management time, and a real-time interactive communication all occur in the same calendar month.

This presents a challenge for practices. Even if clinical staff ensure the device is working, monitor the data, and reach out to patients proactively about their data, they could lose all reimbursement if the patient doesn’t answer the phone one month.

Some patients may simply not have time to answer or be traveling, while others, especially low-income patients, may temporarily lose access to phone or Internet. Practices won’t be able to afford offering RPM to those patients if they can receive no reimbursement, and this change would negatively impact patient health, especially for the low-income patients who most need support.

Why practice comments carry weight

CMS says in the rule text that they have “received very little invoice or pricing information from interested parties for the specific devices used in RTM and RPM services,” and asks for comment on “how often third-party billing currently occurs and how this policy, if finalized, could impact access to remote monitoring services.”

By providing real operational and cost data and sharing patient experiences, practices and providers have an opportunity to shape how remote monitoring will function. 

Some of the valuable information you could share if you already offer RPM includes: 

• How many of your patients are monitored today, and for which conditions
• Who furnishes the monitoring, and whether that team is employed or contracted under general supervision of the provider
• What your practice pays to supply, ship, and replace devices
• What you would do on January 1, 2027, if each provision were finalized, including whether you would continue the program
• Which patients would be affected first

If you don’t yet have a remote monitoring program, sharing how many patients you have that might benefit from such a program in the future could also be helpful. We’ve provided a comment letter template if you would like help getting started. Please customize it as much as you like.

Comments are due on Regulations.gov by September 14, 2026, at 11:59 p.m. ET.