Provider Comment Letter

All comments are due September 14 by 11:59 pm ET. Please use this letter only as a starting point and personalize as you see fit. Feel free to attach supporting documentation, such as invoices.

Instructions for how to file are included.

Template

Dear Administrator,

I am [name, credentials], [role] at [practice or organization] in [city, state]. We care for [number] Medicare patients, including [number] who [currently benefit/could benefit] from remote patient monitoring for conditions such as high blood pressure, heart failure, and diabetes.

I am writing to urge CMS to withdraw or modify four provisions in the proposed rule: the requirement that remote monitoring be performed only by clinical staff employed directly by the billing practice; the mandatory face-to-face initiating visit; the downward revaluation of the device-supply codes; and the bundling of the distinct monitoring codes.

Our practice [relies on/would rely on] a contracted clinical team to deliver monitoring under our general supervision, a model CMS authorized in the CY2021 Physician Fee Schedule. We [order/would order] the service, establish the patient relationship, review the data, and certify each claim. We [remain/would remain] fully accountable for our patients. The contracted team [is/would be] how we make this care possible, not a substitute for our clinical judgment.

If these provisions take effect, we would [describe the concrete impact: reduce or end monitoring for X patients, etc.]. The patients affected are [describe, for example older adults in a rural area with limited transportation]. In our experience, monitoring has [describe a specific, non-identifying outcome, for example helped us catch rising blood pressure early and avoid a hospital admission].

If CMS is concerned about improper billing, the right response is enforcement, not structural cuts: audit enrollment mills, recover payment for devices that never transmit data, and prosecute those who bill for patients they never treated. CMS can also protect integrity through the established-patient requirement, the 16-day data requirement, the FDA-cleared device requirement, consent, and documentation. These protect patients. The four provisions above do not. They remove access.

Thank you for considering this comment. Please help us keep this care connected for our patients.

Respectfully, [name, credentials, organization]

How to file

Go to the docket at Regulations.gov (https://www.regulations.gov/docket/CMS-2026-2377), file code CMS-1848-P, for the CY2027 Physician Fee Schedule.
Select the "Comment" option on the docket landing page.
Enter your comment directly or upload a Word or PDF document. For data-rich submissions, an attachment is preferred. Make sure the header cites CMS-1848-P and specifies opposition to the revaluation of CPT 99454 to CPT 99474.
Complete the required fields, indicate whether you are commenting as an individual or organization, and keep the tracking number for your records. Submit before 11:59 p.m. ET on September 14, 2026.

Electronic submission is recommended to guarantee a verifiable record. Written correspondence is also accepted via the addresses in the Federal Register.