CMS's 2027 Proposed Rule and RPM: The Biggest Change Since 2019

On July 14, 2026, CMS released the CY2027 Medicare Physician Fee Schedule proposed rule. For remote patient monitoring, it is the most significant rulemaking since Medicare first started paying for RPM in 2019 — and one that will likely shape how CMS treats Chronic Care Management (CCM) and the rest of its care-management code family going forward.

The rule pulls in the opposite direction from last year’s. CY2026 expanded RPM with new short-duration device codes and a shorter management code. The 2027 proposal adds guardrails instead: who is allowed to perform the billable work, what has to happen before a patient is enrolled, and how much the device codes are worth.

This post is for practices, health systems, and care teams that already run an RPM or RTM program or are weighing one. Everything here is proposed. Comments are due by September 14, 2026, CMS expects a final rule around November 1, and the changes would take effect January 1, 2027 if finalized. That leaves a real window to plan and to comment.

Key Takeaways

• The proposed rule would only let Medicare pay for RPM and RTM treatment management when a practice’s own employed clinical staff perform it — not a contractor or vendor’s staff.
• A separate, billable initiating visit would be required before RPM or RTM monitoring begins, and RTM would be limited to established patients only.
• Device supply codes would be revalued downward, and the 2027 conversion factor drops to $32.84 (non-APM) or $33.17 (qualifying APM participants).
• Everything is proposed, not final. Comments are due September 14, 2026, with a final rule expected around November 1 and an effective date of January 1, 2027.
• Practices already running RPM with their own employed staff are close to compliant. Practices leaning on a vendor’s clinical staff for monitoring should get a written migration plan now.

What CMS Is Proposing for RPM and RTM

Four provisions carry the weight for remote monitoring.

• Billable care management must be done by your own employed clinical staff. This is the headline. As proposed, Medicare would pay for RPM and RTM treatment management only when the practice’s employed clinical staff perform it, not when a contractor does. It goes straight at the arrangement where an outside vendor’s nurses log the monthly monitoring minutes and the practice bills for that time.
• A separately reportable initiating visit would be required. Before RPM or RTM services begin, the billing practitioner would have to furnish a separate, billable initiating visit tied to the start of monitoring.
• RTM would be limited to established patients. RPM already expects an existing patient relationship. The rule extends the same established-patient requirement to RTM, closing a gap that let some RTM programs enroll patients with no prior relationship to the billing provider.
• The device supply codes would be revalued downward. CMS says the monitoring devices appear to cost less than its original estimates and proposes to lower the code values to match. The rule does not publish specific RPM rate tables yet; those arrive with the full rule text and the annual rate files.

CMS is also asking a bigger question. In a request for information, it floats bundling the current RPM and RTM CPT codes into four new HCPCS G-codes — the same code-family structure CMS already uses for programs like Principal Illness Navigation (PIN). That is a request for comment, not a proposal, but it signals where the agency’s thinking is headed: it does not believe the current code structure can fix the problems the OIG has flagged. Our post on the AMA’s CPT Editorial Panel review of RPM coding covers the earlier stage of that same conversation.

Why CMS Is Tightening the Rules

None of this is arbitrary. It follows a run of OIG scrutiny.

An OIG report in September 2024 found that about 43% of Medicare RPM enrollees did not receive all three components of the service, and that CMS could not identify the ordering provider for 44% of enrollees. A follow-up in August 2025 put Medicare RPM payments at $536 million in 2024, up 31% in a single year, and named practices billing RPM for large patient panels they had no prior relationship with.

Each 2027 proposal lines up with one of those findings. The initiating-visit and established-patient rules target enrollment mills. The employed-staff requirement targets turnkey arrangements where a distant vendor runs everything and the practice collects the payment. The device revaluation targets costs CMS believes are inflated. Put together, CMS is not trying to end RPM. It is trying to end one way of doing it.

The Money: Conversion Factor and Device Values

Two things pull RPM revenue down in 2027.

First, the conversion factor. Since CY2026, Medicare has used two of them. CMS proposes a 2027 conversion factor of $33.17 for qualifying APM participants and $32.84 for everyone else. Part of the drop is mechanical: the one-year 2.50% increase that the Working Families Tax Cut law gave physicians for 2026 expires, which resets payment about 2.50% lower before other adjustments.

Second, the device revaluation. Because CMS thinks the monitoring hardware costs less than assumed, the device supply codes would be worth less. Between the two, per-patient monthly RPM economics will likely compress in 2027. How much depends on the rate tables, which were not part of the July fact sheet. It is worth waiting for the final numbers before rebaselining a program budget.

If You Run RPM With Your Own Staff

If your organization owns the patient relationship, your ordering providers write the orders, and your employed nurses do the treatment management, you are already close to what CMS is proposing. Two things still need work: building the initiating visit into your enrollment flow, and tightening documentation so each billed month clearly shows the device data, the time spent, and the clinical decision-making behind it.

There is an upside here. Guardrails raise the cost of entry for low-quality operators and shrink the audit cloud over the whole category. Programs that have been doing RPM properly stop competing against arrangements that arguably should not have been billable in the first place.

If you are also evaluating or upgrading the platform behind your program, our roundup of the 10 Best Chronic Care Management Software Platforms in 2026 compares options built for this employed-staff, audit-ready model — including HealthArc, which unifies RPM, CCM, RTM, and other care-management programs on one patient record so a single care team can run and document all of them.

If You Outsource Monitoring to a Vendor

Read this part closely before you sign anything in 2026.

A large share of the RPM vendor market runs on a clinical-services model: the vendor supplies the devices, the software, and the nurses who perform the monthly monitoring minutes, and the practice bills for that time. Under the rule as written, that time would not be billable, because the people doing it are not the practice’s employed clinical staff.

If you are evaluating a vendor, ask three questions and get the answers in writing. Whose payroll are the monitoring nurses on? What happens to your billing if the employed-staff requirement is finalized as proposed? And what is the migration plan if you need to bring monitoring in-house partway through the contract? A vendor cannot contract away a Medicare billing rule. If there is no written answer to that risk, the risk is yours.

The industry will argue for flexibility during the comment period, and some of those arguments may land. Supervised staffing and rural-access concerns are real. But a signed multi-year agreement with no answer to this proposal is a different thing from a considered bet that the proposal will soften.

Other 2027 Proposals Worth a Look

RPM is not the only part of the rule that touches care teams.

• E/M on the same day as a procedure. When a separately identifiable office visit happens the same day as a 0-, 10-, or 90-day global procedure by the same practice, CMS would pay the most expensive service at 100% and the rest at 50%.
• G2211 becomes a modifier. The E/M complexity add-on would shift from a flat add-on to a modifier that raises the base E/M payment by 16%, with a separate modifier adding 32% for longitudinal care by certain ACO practitioners. See our G2211 CPT code guide for how the add-on works today.
• Shared medical appointments. CMS proposes separate coding and payment for group visits, which have no dedicated code today.
• Behavioral health. The Psychiatric Collaborative Care Model and related behavioral health integration codes would get higher work RVUs, and the timed behavioral health increase would extend to tobacco cessation and SBIRT services.
• Advance care planning. Two new codes would cover ACP delivered by clinical staff under direct supervision, with 99497 and 99498 reserved for the practitioner’s own time.
• Practice expense methodology. CMS would phase out the Indirect Practice Cost Index over two years and cap any single code’s practice-expense RVU change at 5% per year to limit swings.
• AI. Software-as-a-Service codes would be renamed Software as a Medical Service, and CMS proposes a new incentive for clinicians who use AI tools under documented governance.

One clarification, since it comes up: the Contract Year 2027 rule for Medicare Advantage and Part D that published in the Federal Register in April 2026 is a separate rule. It governs how MA and Part D plans operate, not the Physician Fee Schedule, and it does not change RPM billing.

What to Do Before September 14

The comment period is the practical part. A few moves make sense now.

Model your 2027 RPM economics with headroom for the conversion-factor cut and the device revaluation, and wait for the rate tables before locking a budget. Review any vendor contract against the employed-staff proposal and ask for a written migration path. Start designing the initiating-visit step into enrollment now, since it is a workflow change no matter how the rates land. And if the rule would hurt a program that is doing RPM well, say so. Comments go through Regulations.gov under file code CMS-1848-P and are due by September 14, 2026. CMS has softened aggressive proposals before, and operational and cost data from real programs is the kind of input that moves a final rule.

HealthArc will keep tracking this rule through the comment period and break down the final rate tables when they publish in November. Whether you run RPM with your own employed clinical staff or use a mix of in-house and managed support, our team can help you model your 2027 economics and check your program against the proposed employed-staff and initiating-visit requirements. Talk to our team.

Common Questions About the CY2027 Rule and RPM

When was the CY2027 Medicare Physician Fee Schedule proposed rule released, and when would it take effect?

CMS released it on July 14, 2026. If finalized, the changes take effect January 1, 2027. Comments are due by September 14, 2026, and CMS expects a final rule around November 1, 2026.

What is the biggest change to RPM in the 2027 proposed rule?

The proposal to pay for RPM and RTM treatment management only when the practice’s own employed clinical staff perform it. Time logged by a contractor or a third-party vendor’s staff would not be billable as written.

Can I still work with a third-party RPM vendor in 2027?

You can still buy devices, software, and logistics from a vendor. What changes, as proposed, is that the billable monitoring minutes would have to be performed by your employed clinical staff rather than the vendor’s. If your current arrangement depends on vendor nurses doing that work, ask for a written migration plan. This is still a proposal and could change after comments.

Does the rule require an initiating visit before RPM?

Yes. As proposed, the billing practitioner must furnish a separately reportable initiating visit at the onset of RPM or RTM services.

What changes for RTM specifically?

RTM would be limited to established patients, would require the same initiating visit as RPM, and would be subject to the same employed-staff requirement and downward device revaluation.

Are RPM payment rates going down in 2027?

Likely. CMS proposes to revalue the device supply codes downward, and the conversion factor is set to drop. CMS did not publish specific RPM rate tables with the July fact sheet, so the exact per-code amounts come with the full rule and the annual rate files.

What is the proposed 2027 conversion factor?

$33.17 for qualifying APM participants, down from $33.57, and $32.84 for all other physicians, down from $33.40. The 2.50% increase that applied for 2026 under the Working Families Tax Cut law expires for 2027.

Why is CMS tightening RPM rules?

OIG scrutiny. A September 2024 report found about 43% of RPM enrollees did not receive all three service components, and no ordering provider could be identified for 44% of them. An August 2025 follow-up put 2024 RPM payments at $536 million, up 31% year over year, and flagged billing for patients with no prior provider relationship.

Are there new RPM or RTM codes in the rule?

Not yet. CMS included a request for information about bundling the current RPM and RTM CPT codes into four new HCPCS G-codes. That is a request for comment, not a proposed code set.

How do I submit a comment on the rule?

Through Regulations.gov, under file code CMS-1848-P, by September 14, 2026.

The provisions above are proposed, not final, and may change in the final rule expected in late 2026. Check with your billing and compliance teams before making program decisions based on proposed rulemaking.

Conclusion

The CY2027 proposed rule does not end remote patient monitoring — it draws a clearer line around who can bill for it and what has to happen before a patient is enrolled. For programs already run by employed clinical staff with clean documentation, the rule mostly formalizes what good practice already looks like. For programs leaning on a vendor’s monitoring staff, the comment period is the window to get a written answer on what changes if the employed-staff requirement is finalized as proposed.

Want a second set of eyes on your 2027 RPM and RTM economics? Book a HealthArc demo and we will walk through your program against the proposed rule, line by line.