The short version
CMS released the final 2027 Medicare Physician Fee Schedule (CMS-1848-F) on November 4, 2026, and it takes effect January 1, 2027. We walked through the whole rule in our guide to the 2027 Physician Fee Schedule final rule. This post zooms in on the 2027 RPM final rule, covering remote patient monitoring (RPM) and remote therapeutic monitoring (RTM), where five things changed.
- New RPM and RTM patients need a face-to-face or telehealth visit before billing can start.
- RTM is now limited to established patients.
- Device and setup codes pay less, though no existing code can lose more than 19 percent of its value in 2027.
- The requirement that monitoring staff be employed by the billing practice starts January 1, 2029, two years later than CMS proposed.
- CCM, PCM, TCM, and the core APCM codes didn't change, and collaborative care now pays more.
The same rules apply to FQHCs and RHCs, and CMS signaled further changes to RPM coding and payment in future years.
2027 RPM and RTM changes at a glance
| Change | Status | Effective date |
|---|---|---|
| Initiating visit for RPM and RTM | Finalized | January 1, 2027 |
| Established-patient requirement for RTM | Finalized | January 1, 2027 |
| Lower device and setup payments | Finalized, phased in | January 1, 2027 |
| Cut to RPM management time | Proposed, not finalized | Not applicable |
| Practice-employed monitoring staff | Finalized, delayed | January 1, 2029 |
Why did CMS tighten the RPM rules?
CMS pointed to program integrity. The final rule cites reports from the HHS Office of Inspector General, including a finding that about 43 percent of Medicare patients who received RPM did not receive all three parts of the service: setup, device supply, and treatment management. CMS also described concerns about companies "cold calling" patients and about care that is split off from the billing clinician. The initiating visit and the 2029 staffing rule are both aimed at keeping the billing clinician at the center of the patient's care.
Where HRS fits. These requirements reward programs that are clinically grounded and run with the care team. That is the kind of program HRS supports, and the new rules give practices a clearer standard to build toward.
What is the RPM initiating visit requirement?
Starting January 1, 2027, the clinician who bills for RPM or RTM has to see the patient first, either in person or by telehealth, and talk about monitoring during that visit. Billing can't begin until the visit has happened.
CMS kept the requirement practical. A colleague of the same specialty in the same group can hold the visit. It doesn't have to be a dedicated RPM appointment, so a routine follow-up works if monitoring comes up. There's no deadline for turning on the device afterward. Patients already being monitored before January 1, 2027 are exempt, and a device swap, a change in condition, or a new billing clinician within the practice doesn't trigger a second visit.
Where HRS fits. The rule puts the billing clinician at the front of every new monitoring relationship, which is how strong programs already run. HRS works with care teams to make that visit a natural part of enrollment, whether it happens in the office or by telehealth, and helps programs keep clean records for the patients who were enrolled before the deadline.
Who counts as an established patient for RTM?
Usually, it's someone the practice or a same-specialty colleague in the group has seen within the past three years. CMS also confirmed that a new patient becomes established once they've had the initiating visit, so new patients can still start RTM.
Where HRS fits. One visit now covers both requirements. HRS helps programs use a single enrollment process for RPM and RTM, so patients can move into whichever program fits once that visit is done.
How do RPM and RTM payments change in 2027?
Device payments go down. Payment for managing patients holds steady.
CMS revalued the device and setup codes, including 99453, 99454, and 99445, downward. The cut is capped at 19 percent of each code's value for 2027, and anything beyond that carries into later years. On top of that, the Medicare conversion factor, the dollar figure used to set every rate, drops 2.31 percent for most clinicians, from $33.4009 to $32.6286. Combined, some device codes could pay about 21 percent less next year, while most other codes move mainly with the 2.31 percent rate cut. The program-by-program breakdown in our final rule guide shows the worst case for each.
The management time codes (99457, 99458, and 99470) are a different story. CMS had proposed cutting them and backed off in the final rule, so they move mainly with the overall rate change.
Where HRS fits. Next year, more of a program's value will come from consistent patient management and less from devices. HRS programs are built around regular monthly engagement with patients, with HRS handling device delivery, setup, and support, including cellular devices, so care teams can spend their time on patients. We're also working with customers to look at what the 2027 rates mean for their own programs.
When does the RPM staffing rule take effect?
January 1, 2029. CMS originally wanted it in place by January 2027, and the delay was the biggest change to the remote monitoring provisions between the proposed and final rules.
Through December 31, 2028, contracted clinical staff can keep supporting RPM and RTM, provided the incident-to and billing rules are met and the billing clinician stays involved. CMS has said it will publish guidance on which staffing arrangements qualify before 2029. It also made clear that practices can keep buying devices, software, connectivity, data hosting, and technical support from outside companies. The 2029 rule governs who performs the billed clinical work. The technology behind it is unaffected.
Where HRS fits. HRS continues to support customer programs under the current rules, with billing clinicians involved in oversight as CMS requires. The two-year delay gives everyone time to plan properly, and HRS is using it to evaluate operating models for 2029, including how best to support teams that practices employ directly. We'll align with CMS guidance as it's released, and we're working with customers one by one on the staffing approach that suits their organization and timeline. The rule keeps technology services like the platform, devices, and technical support HRS provides available to practices in 2029 and after.
What changed for care management and behavioral health?
Very little, and mostly for the better. CMS made no code-specific changes to CCM, PCM, TCM, or the core APCM codes (G0556, G0557, and G0558). The overall rate cut and CMS's new method for calculating practice expense still apply to them. Collaborative care codes rose above what CMS proposed, including the add-ons billed with APCM (G0568 and G0569). CMS also confirmed that collaborative care and RTM can be billed for the same patient when both are needed, as long as the minutes are tracked separately.
Where HRS fits. Monitoring works best inside a broader care program. HRS supports programs that combine RPM with CCM, PCM, or TCM, so patients get steady support between visits. With collaborative care now paying more, HRS is also helping customers consider where APCM and behavioral health integration make sense for their patients.
What do the new rules mean for FQHCs and RHCs?
They apply in the same way. Since January 1, 2025, FQHCs and RHCs bill the individual care coordination codes, including RPM and RTM, and are paid at national non-facility Physician Fee Schedule rates, separate from their all-inclusive rate or prospective payment. CMS restated in the final rule that FQHCs and RHCs must follow the Physician Fee Schedule requirements for each code they bill, so the initiating visit, the RTM established-patient rule, and the 2029 staffing rule all apply.
Where HRS fits. HRS works with FQHCs and RHCs on remote monitoring and care management, and helps these teams fit the new requirements into the way their clinics already run.
What could CMS change next?
The final rule points to more change ahead, so programs should plan with some flexibility.
- A simpler code set. CMS asked for public comment on replacing most RPM and RTM codes with four monthly codes (two for RPM, two for RTM) that would bundle setup, device supply, and treatment management. It did not adopt them for 2027 and said it will consider the comments in future rulemaking.
- New device values. The American Medical Association's RUC, the committee that recommends code values to CMS, plans to review practice expense for all 19 RPM and RTM codes at its January 2027 meeting. That review could inform payment for 2028 and beyond.
- Care management rules. CMS asked for input on how care management services should start, how they should be supervised, and how much of the work the billing clinician should do. No changes were made for 2027.
How does HRS support programs through the transition?
| Timeframe | What the rule requires | How HRS supports programs |
|---|---|---|
| Now through December 2026 | Final rule released; current patients exempt | Updating enrollment workflows and documenting current patients |
| 2027 | Initiating visit and lower device payments in effect | Consistent enrollment, patient management, and program reviews |
| 2027 to 2028 | Contracted staff allowed; CMS guidance expected | Continuity under current rules and planning for 2029 |
| January 1, 2029 onward | Practice-employed monitoring staff required | Technology, devices, and support for practice-employed teams, in line with CMS guidance |
What should RPM programs do now?
- Build the initiating visit into enrollment before January 1, 2027.
- Document the patients who are active before January 1, 2027.
- Review how monitoring is staffed against the 2029 rule, and watch for CMS guidance.
- Update program budgets for the 2.31 percent rate cut and lower device payments.
- Check Medicare Advantage, Medicaid, and commercial payers separately, since their rules may differ.
Frequently asked questions
When does the 2027 RPM final rule take effect?
January 1, 2027. CMS released the rule (CMS-1848-F) on November 4, 2026.
Do current RPM patients need an initiating visit?
No. Patients receiving RPM or RTM before January 1, 2027 don't need an initiating visit, as long as all other billing rules are met.
Can the initiating visit be done by telehealth?
Yes. It can be in person or by telehealth. Under current law, expanded Medicare telehealth rules run through December 31, 2027.
Can contracted monitoring staff still support RPM programs in 2027 and 2028?
Yes. Contracted clinical staff can support RPM and RTM through December 31, 2028, when all incident-to and billing rules are met.
Can practices keep using an RPM technology vendor after 2029?
Yes. CMS confirmed that practices can get devices, software, connectivity, data hosting, and technical support from outside companies. The 2029 rule applies to the clinical staff whose time is billed.
Do the new RPM rules apply to FQHCs and RHCs?
Yes. FQHCs and RHCs bill the individual RPM and RTM codes and must follow the Physician Fee Schedule requirements for each, including the initiating visit and the 2029 staffing rule.
Why did CMS change the RPM rules for 2027?
CMS cited program integrity concerns, including an HHS Office of Inspector General finding that about 43 percent of Medicare RPM patients did not receive all three parts of the service. The new rules keep the billing clinician at the center of care.
Will CMS bundle the RPM and RTM codes?
Not in 2027. CMS asked for comment on replacing most RPM and RTM codes with four bundled monthly codes and said it will consider the feedback in future rulemaking.
Did CMS cut RPM management time payments?
No. CMS proposed reducing payment for 99457, 99458, and 99470 but didn't finalize it. Those codes change mainly with the 2.31 percent conversion factor cut.
Related reading
- 2027 Medicare Physician Fee Schedule Final Rule: What Changes for RPM, CCM and Care Management, covering the conversion factor, each care management program, and six steps to prepare.
Get your program ready for 2027 and 2029
January 1 is close, and the 2029 staffing rule will shape decisions well before it takes effect. HRS works with health systems, physician practices, home health and hospice agencies, FQHCs, and payors on remote monitoring and care management programs. Our team can help you:
- Build the initiating visit into enrollment before January 1
- See what the 2027 rates mean for your program
- Plan monitoring staffing for 2029
Request a demo and a member of our team will follow up to set up a conversation, or call us at (347) 699-6477.
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.
Medicare Physician Fee Schedule payment amounts apply to Medicare fee-for-service. Commercial, Medicare Advantage, and Medicaid payment varies by payer and contract. The 21 percent figure is an HRS estimate based on limits in the final rule.
Sources
- CMS-1848-F final rule, public inspection copy (FR Doc. 2026-22743): program integrity concerns pp. 285, 298; initiating visit pp. 279–284; RTM established patients pp. 278–279; FQHC and RHC billing pp. 283–284; staffing pp. 286–291; device valuation and RUC review pp. 295–297; bundled code comment solicitation pp. 298–301; collaborative care p. 317; care management request for information pp. 514–516; conversion factor p. 1972
- CMS press release: CMS Finalizes CY 2027 Physician Fee Schedule, November 4, 2026
- Federal Register document 2026-22743