After a year of expansion for Remote Patient Monitoring (RPM), the 2027 Medicare Physician Fee Schedule proposed rule signals a sharp change in direction. In 2026, The Centers for Medicare and Medicaid Services (CMS) expanded the RPM code family, including new device supply codes for shorter monitoring periods and new treatment management options.
Now, CMS is proposing a move in the opposite direction: new conditions of payments designed to address concerns about waste, fraud, and abuse in remote monitoring programs. Specifically, CMS is proposing to eliminate reimbursement for RPM and Remote Therapeutic Monitoring (RTM) services performed by contracted third-party clinical staff. If finalized, the proposed changes would materially affect how providers structure, staff, and bill for RPM services beginning January 1, 2027.
What CMS Is Proposing for RPM in 2027
While the proposed rule includes several remote monitoring provisions, the RPM-related changes providers should watch most closely include:
- Limiting billable RPM services to clinical staff employed by the billing practice. CMS proposes to allow Medicare payment for RPM and RTM services only when furnished by clinical staff who are a 'direct employee of the practitioner or the practitioner's practice.' Under the proposal, services performed by contracted third-party clinical staff would no longer qualify for billing. Notably, the proposal does not require clinical staff to be physically located at the practice, and the existing general supervision rules would continue to apply.
- Requiring stronger provider-patient relationships. CMS proposes that RPM and RTM services be initiated by the billing practitioner during a face-to-face visit (in-person or telehealth) in which remote monitoring is discussed with the patient. The initiating visit would be separately billable. CMS also proposes that RTM services be furnished only to established patients, matching the standard that already applies to RPM.
- Repricing device supply and treatment management codes. CMS proposes to revalue the RPM setup and device supply codes by crosswalking their practice expense inputs to self-measured blood pressure codes, and to remove practice expense inputs from the treatment management codes entirely, stating that it does not believe the typical workflow for those services involves clinical staff time. If finalized, both changes would meaningfully reduce payment for remote monitoring services.
- Seeking comment on bundling the code family. CMS is seeking feedback on replacing the 17 RPM and RTM codes with four new bundled G-codes, each combining device supply, data transmission, and treatment management into a single monthly payment. CMS has indicated it could finalize payment for these codes after reviewing public comments, so this restructuring could take effect as soon as January 1, 2027.
Why CMS Is Taking a Closer Look at RPM
The proposed changes follow heightened scrutiny from the U.S. Department of Health and Human Services Office of Inspector General (OIG). In its September 2024 report, OIG found that RPM use in Medicare increased dramatically from 2019 to 2022 and that approximately 43% of Medicare enrollees who received RPM did not receive all three components of the service. OIG also noted that Medicare lacked key information needed for oversight, including who ordered monitoring for an enrollee. A 2025 OIG follow-up report on RPM billing reinforced those findings.
CMS’s 2027 proposal appears to respond directly to those concerns. The agency’s goal is to ensure that RPM is used appropriately, billed accurately, and integrated into a provider-led care plan rather than operating as a disconnected service.
Important Caveat: This Is Still a Proposed Rule
Providers should remember that these changes are not final. CMS is accepting public comments on the proposed rule through September 14, 2026, and the final rule may include modifications based on stakeholder feedback. A final rule is expected in the fall, with any finalized changes taking effect January 1, 2027. Until a final rule is issued, current RPM billing requirements remain in place.
HRS’s Perspective: RPM Should Improve Patient Outcomes
At HRS, we believe the goal of RPM is clear: improve patient outcomes by helping providers identify risk earlier, support patients between visits, and intervene before avoidable utilization occurs. In fact, the majority of our customers use HRS to support value-based initiatives, and they tell us the greatest value HRS brings as a partner is not just reimbursement support, but helping them operationalize and optimize their entire care-at-home strategy.
That said, we believe RPM programs can be successful with outsourced monitoring teams when they are built around appropriate patient selection (e.g., enrolling patients with hard-to-control hypertension, not just a hypertension diagnosis), meaningful provider involvement, and a workflow that keeps clinicians connected to the care plan. Third-party clinical support can play an important role when it extends provider capacity while preserving clinical accountability and patient-centered care.
We also believe the proposed implementation timeline is unrealistic. A final rule issued in late fall with changes effective January 1, 2027 would give providers roughly 60 days to restructure staffing models that took years to build. If finalized as written, these changes would disrupt established programs, create operational challenges for providers, and interrupt care for patients who depend on remote monitoring. CMS itself has asked for comment on how this policy could affect access to remote monitoring services, and we intend to answer that question with data. HRS is actively engaged in the comment process, both through coordinated industry efforts with the Connected Health Initiative and ATA Action and through our own comments to CMS.
How HRS Can Support Providers Preparing for What Comes Next
Regardless of how the final rule evolves, HRS is equipped to support providers as they evaluate the best model for their organization. The HRS platform supports every staffing structure a final rule could require: fully in-house programs, hybrid models, and supported programs. Providers do not need to lock into a single program design while the rule is pending.
We are also ready to share what we have learned from customers who have successfully operated in-house programs, including the staffing models, operational processes, escalation pathways, and provider engagement strategies that help programs succeed.
As the comment period continues, providers should assess their current RPM structure, understand how the proposed requirements could affect staffing and billing, and consider submitting comments to CMS before the September 14 deadline. HRS will continue monitoring the rulemaking process and supporting providers as they prepare for potential changes.
Contact us today to speak with our Digital Health Advocates about the proposed changes, and how our flexible models can support your program’s sustainability.