2027 Medicare Fee Schedule Final Rule: RPM & CCM Changes

A plain-language guide to CMS-1848-F: the new RPM initiating visit, lower device payments, the 2029 staffing rule, higher collaborative care payment, and how to prepare.

Published November 4, 2026 by Health Recovery Solutions (HRS)

Key takeaways

• The rule: CMS released the final 2027 Medicare Physician Fee Schedule (CMS-1848-F) on November 4, 2026. It takes effect January 1, 2027.
• Lower rates overall: The Medicare conversion factor drops 2.31 percent for most clinicians, from $33.4009 to $32.6286.
• New RPM and RTM visit: From January 1, 2027, a face-to-face or telehealth visit is required before RPM or RTM can be billed for a new patient.
• Lower device payments: RPM and RTM device and setup codes could pay up to about 21 percent less in 2027.
• Staffing rule in 2029: From January 1, 2029, RPM and RTM monitoring staff must be employed by the billing practice.
• Higher collaborative care payment: Collaborative care codes (99492, 99493, 99494) rise sharply.
• No code changes for CCM, PCM, TCM or the main APCM codes.

What is the 2027 Medicare Physician Fee Schedule final rule?

The Medicare Physician Fee Schedule (PFS) is the annual rule that sets how much traditional Medicare pays clinicians for each service. The Centers for Medicare & Medicaid Services (CMS) released the final 2027 rule, CMS-1848-F, on November 4, 2026.

The rule is scheduled for Federal Register publication on November 9, 2026. It takes effect January 1, 2027.

For remote monitoring and care management programs, the rule does four main things:

1. Requires a visit before RPM or RTM billing starts.
2. Lowers payment for RPM and RTM devices and setup.
3. Requires practice-employed monitoring staff starting in 2029.
4. Raises payment for collaborative behavioral health care.

2027 changes at a glance

Payment ranges are HRS estimates based on limits in the final rule. Exact rates will be confirmed when CMS posts its 2027 rate files.

Changes that affect every program

Medicare rates drop 2.31 percent

Medicare uses one dollar amount, the conversion factor, to set the payment for every service.

• Most clinicians: drops from $33.4009 to $32.6286 (down 2.31 percent).
• Clinicians in qualifying advanced payment models: drops from $33.5675 to $32.9548 (down 1.83 percent).

CMS says the main reason is that a one-time 2.5 percent increase for 2026 has ended.

Practice expense is calculated a new way

Practice expense is the part of each payment that covers clinical staff time, equipment, supplies, and overhead. CMS changed how it spreads these costs across services and will phase the change in over two years.

For most services, CMS also added a limit. The practice expense part cannot rise or fall more than 5 percent in a year.

Telehealth rules continue through 2027

Expanded Medicare telehealth rules run through December 31, 2027, under current law. Starting January 1, 2027, two new claim modifiers, BB and BC, are required on certain telehealth claims. They do not change payment.

These Medicare rates apply to traditional Medicare fee-for-service. Medicare Advantage, Medicaid, and commercial payment depends on each payer and contract.

Remote patient monitoring (RPM) changes in 2027

RPM sees the biggest changes in the 2027 rule.

What is the RPM initiating visit requirement?

From January 1, 2027, the clinician who bills for RPM must first hold a face-to-face visit with the patient, in person or by telehealth, and discuss RPM during that visit.

• Other topics are fine. RPM does not need to be the only reason for the visit.
• Who can hold it: the billing clinician, or a colleague of the same specialty in the same group practice.
• Timing: billing cannot start until after the visit. There is no deadline for turning on the device afterward.
• What does not count: a service that is not face-to-face with the billing clinician, or one Medicare does not pay for separately.
• Current patients are exempt: patients already in RPM before January 1, 2027 do not need the visit, if all other rules are met. CMS warned against rushing enrollments before that date.
• One visit at the start: a new visit is not needed for a new device, a change in condition, or a new billing clinician in the same practice.

RPM device and setup payments go down

Medicare will pay less for RPM device supply (99454 and 99445) and setup (99453). Each code can lose no more than 19 percent of its value in 2027. Any remaining cut carries into later years.

With the lower conversion factor added, these codes could pay up to about 21 percent less in 2027.

RPM management time payments hold steady

CMS had proposed cutting payment for RPM treatment management (99457, 99458, and 99470). It did not finalize that cut. These codes change mainly with the 2.31 percent rate cut, with a worst case of about 5 percent.

RPM staff must be practice employees starting in 2029

• Through December 31, 2028: practices can keep using contracted clinical staff from outside companies, if all current billing rules are met and the billing clinician stays involved.
• Starting January 1, 2029: Medicare will pay for RPM only when monitoring staff are direct employees of the billing clinician or practice.
• Vendors are still allowed: practices can keep buying devices, software, connectivity, data hosting, and technical support from outside companies.

CMS plans to publish guidance on which staffing arrangements qualify.

What this means for RPM programs: Device revenue per patient falls, so consistent management time becomes a larger share of RPM payment. Every new patient needs a documented visit. Staffing plans need a path to the 2029 rule.

Chronic care management (CCM) in 2027

CCM codes 99490, 99439, 99487, 99489, 99491, and 99437 did not change. Payment moves mainly with the 2.31 percent rate cut, with a worst case of about 5 percent.

CMS asked for public input on future care management rules. Topics included what should start care management, how supervision should work, and how much work the billing clinician should do.

What this means for CCM programs: CCM is stable for 2027. Keep clear records of how each patient started CCM and who did the work, since CMS may add rules later.

Principal care management (PCM) in 2027

PCM codes 99424 through 99427 did not change. Payment moves mainly with the rate cut, with a worst case of about 5 percent.

What this means for PCM programs: PCM remains available for patients with one serious chronic condition, including RPM patients. No new requirements apply in 2027.

Transitional care management (TCM) in 2027

TCM codes 99495 and 99496 did not change. Payment moves mainly with the rate cut, with a worst case of about 5 percent.

What this means for TCM programs: The TCM visit after a hospital discharge is a face-to-face visit with the billing clinician. If RPM or RTM is discussed, that visit can also serve as the RPM initiating visit. Confirm this approach with your compliance team.

Advanced primary care management (APCM) in 2027

The main APCM codes, G0556, G0557, and G0558, did not change. The collaborative care add-ons billed with APCM rose:

• G0568: from 1.88 to 3.25 work units
• G0569: from 2.05 to 2.56 work units

APCM billers still need to report the primary care quality measure set. CMS also confirmed that care for alcohol use disorder can count under the APCM behavioral health add-ons.

What this means for APCM programs: Adding collaborative care to APCM earns more per patient in 2027. CMS said early APCM use was lower than expected and asked how to simplify it, so APCM may change in future years.

Behavioral health integration (BHI) and collaborative care in 2027

Collaborative care received the largest increase in the 2027 rule. CMS raised values more than it proposed:

• 99492 (first month): 1.88 to 3.25 work units
• 99493 (later months): 2.05 to 2.56 work units
• 99494 and G2214 (added time): to 1.28 work units
• Device and setup codes: lower, on the same pattern as RPM.
• Behavioral therapy devices (98978 and 98986): one national rate, equal to musculoskeletal devices.
• Management time (98979, 98980, 98981): not cut.

The behavioral health care manager pay rate rises from $0.57 to $0.70 per minute. General BHI codes 99484 and G0323 did not change.

Collaborative care and RTM can be billed for the same patient when both are needed, as long as no minutes are counted twice.

What this means for BHI programs: Collaborative care pays noticeably more per patient in 2027. It still requires a behavioral health care manager and a psychiatric consultant working under the treating clinician.

Remote therapeutic monitoring (RTM) in 2027

RTM follows the same rules as RPM: the initiating visit, the exemption for current patients, and the 2029 staffing rule.

RTM is also limited to established patients. That usually means patients the practice has seen in the past three years. CMS clarified that a new patient counts as established once they have had the initiating visit.

What this means for RTM programs: RTM needs the same sign-up and staffing updates as RPM. Behavioral therapy RTM becomes more predictable to bill.

How to prepare for the 2027 Physician Fee Schedule

We recommend program, compliance, and revenue cycle leaders take these six steps before January 1, 2027:

1. Build the initiating visit into sign-up. Decide which visits will start RPM or RTM. Record the visit date and billing clinician before the first claim.
2. List current monitoring patients. Document every patient in RPM or RTM before January 1, 2027, so their exempt status is clear.
3. Review monitoring staff. Compare every RPM and RTM staffing arrangement with the 2029 employment rule. Watch for CMS guidance.
4. Update financial models. Plan for the 2.31 percent rate cut, device cuts of up to about 21 percent, and higher collaborative care payment.
5. Look at collaborative care. Consider whether collaborative care, alone or with APCM, fits your patients.
6. Check other payers. Medicare Advantage, Medicaid, and commercial plans may follow different rules.

Frequently asked questions

When does the 2027 Medicare Physician Fee Schedule take effect?

The final rule takes effect January 1, 2027. CMS released it on November 4, 2026.

What is the 2027 Medicare conversion factor?

For most clinicians, the 2027 conversion factor is $32.6286, down 2.31 percent from $33.4009. For clinicians in qualifying advanced payment models, it is $32.9548, down 1.83 percent.

Do current RPM patients need an initiating visit in 2027?

No. Patients already receiving RPM or RTM before January 1, 2027 do not need an initiating visit, as long as all other billing rules are met.

Can the RPM initiating visit be done by telehealth?

Yes. The visit can be in person or by telehealth. Telehealth flexibilities run through December 31, 2027, unless Congress extends them.

Can practices still use outside companies for RPM?

Yes, with limits. Contracted monitoring staff can continue through December 31, 2028. From January 1, 2029, monitoring staff must be practice employees. Vendors that supply devices, software, and technical support are still allowed.

Is Medicare cutting all codes by 19 percent?

No. The 19 percent figure is a cap on how much any single code can lose in one year. It matters mainly for RPM and RTM device and setup codes. Most other codes change mainly with the 2.31 percent rate cut.

Did CCM, PCM, or TCM change in 2027?

No. CCM, PCM, and TCM codes did not change. Their payment moves mainly with the overall rate cut.

Can new patients receive RTM?

Yes. RTM is limited to established patients, but CMS clarified that a new patient counts as established after the initiating visit.

Talk with HRS

HRS supports health systems, physician practices, home health and hospice agencies, FQHCs, and payors with RPM, care management, and behavioral health programs. Our team is helping customers prepare for the initiating visit and the 2029 staffing rule. We would welcome the chance to review your program with you.

This material summarizes publicly available CMS rule text for informational purposes and is not legal or billing advice. Confirm requirements with your compliance and revenue cycle teams.

Sources

• CMS-1848-F final rule, public inspection copy (FR Doc. 2026-22743)
• CMS fact sheet: CY 2027 Medicare Physician Fee Schedule Final Rule
• CMS press release: CMS Finalizes CY 2027 Physician Fee Schedule, November 4, 2026
• Federal Register document 2026-22743