CY2027 Fee Schedule Final Rule: RPM and RTM Changes Explained

Matteo

Updated November 2026. Written by Matteo Grassi, clinical psychologist and cofounder of HANA Health.

The CY2027 Physician Fee Schedule final rule, released 4 November 2026, is CMS's annual Medicare Part B payment update, and it changes remote monitoring from 1 January 2027. Remote therapeutic monitoring (RTM) is limited to established patients, RPM and RTM both need an initiating visit, and values are updated. The employed staff only rule is delayed to 1 January 2029.

From the clinical side, the initiating visit is the change to read first, because it decides how every monitoring program starts.

Key facts

CMS released the CY2027 Physician Fee Schedule final rule on 4 November 2026, effective 1 January 2027 (CMS fact sheet, 2026).
CMS finalized three of four proposed remote monitoring policies as proposed: RTM for established patients only, a separately reportable initiating visit for RPM and RTM, and updated valuation (CMS fact sheet, 2026).
The fourth policy, paying only when clinical staff employed by the practice do the work, is delayed two years to 1 January 2029 (CMS fact sheet, 2026).
The final rule is scheduled for Federal Register publication on 9 November 2026 (Federal Register public inspection, 2026).
The 2027 conversion factor is $32.63 for non qualifying clinicians, down from $33.40 (a 2.31% cut), and $32.95 for qualifying APM participants, down from $33.57 (CMS fact sheet, 2026).
Medicare and Medicare Advantage paid $536 million for RPM in 2024, up 31% from 2023, and nearly 1 million enrollees received it (HHS OIG data snapshot, 2025).
About 43% of enrollees who received RPM in 2022 missed at least one of the three components (HHS OIG, 2024).

What did CMS finalize for RPM and RTM?

CMS kept most of what it proposed in July and delayed the part that worried vendors and practices the most. The 4 November fact sheet lists four proposals and says what happened to each.

Here's the scorecard:

RTM for established patients only: finalized as proposed, effective 1 January 2027.
Separately reportable initiating visit: finalized as proposed. Practitioners reporting RPM or RTM must furnish a visit in association with the onset of services.
Updated valuation: finalized as proposed. The fact sheet says CMS is changing how these services are valued but doesn't give code level rates in that summary, so check the rule's payment tables for your codes.
Employed staff only: delayed to 1 January 2029. From then, CMS would pay for RPM or RTM only when clinical staff employed by the practice perform them, not contractors.
Bundled G codes: not finalized. CMS took comments on replacing the current RPM and RTM codes with four new G codes and says it may consider them in future rulemaking.

If you read our earlier explainer on the proposal, this is the update it promised. Our CY2027 contractor proposal post was written before the final rule, so treat the final rule as the current word.

What counts as an initiating visit for RPM and RTM?

An initiating visit is a separately billable visit, in person or by telehealth, tied to the start of remote monitoring. CMS says practitioners reporting RPM or RTM must furnish one "in association with the onset" of services. The fact sheet doesn't spell out documentation details.

The proposed rule did. A law firm summary of the proposal said the billing practitioner would discuss the monitoring plan, decide monitoring is clinically appropriate and document consent, and that a visit where monitoring wasn't discussed wouldn't qualify (Shumaker, Loop and Kendrick, 2026). CMS finalized this policy as proposed, but the rule runs 2,468 pages, so confirm the exact language in the Federal Register text before you build a template around it.

RPM already required an established patient relationship. OIG notes that CMS requires one and found 45 practices that lacked a prior relationship with more than 80% of the patients they billed for RPM in 2024. The new rule extends the same logic to RTM and adds the visit.

Why did CMS delay the contractor rule to 2029?

CMS says it delayed the employed staff requirement "to provide additional time for practices to adapt." Press coverage adds that health tech companies, providers and lawmakers pushed back, because many rural, small and independent practices rely on outside clinical partners to offer monitoring at all.

The delay is a delay, not a reversal. The policy is still scheduled to take effect for RPM and RTM services beginning in CY2029. Nothing in the fact sheet suggests CMS dropped the idea.

The timeline now looks like this:

14 July 2026: CMS issues the CY2027 proposed rule.
4 November 2026: CMS releases the final rule.
9 November 2026: scheduled Federal Register publication.
1 January 2027: RTM established patient rule, initiating visit and new valuation take effect.
1 January 2029: payment only for RPM and RTM done by employed clinical staff.

The reason behind the policy hasn't changed. OIG found about 43% of enrollees who got RPM in 2022 missed at least one of its three components, and about 12% never had treatment management billed. CMS cited oversight concerns when it proposed the staffing rule. The evidence doesn't show that employment status predicts quality, which is partly why the delay got support.

Do other care management programs change in 2027?

The fact sheet's remote monitoring section names only RPM and RTM. Other parts of the rule touch care management, mostly on payment levels and ACO incentives.

Conversion factor: $32.63 for non qualifying clinicians and $32.95 for qualifying APM participants. CMS says current law removes a one year 2.50% increase that applied in 2026.
CoCM: CMS finalized higher work RVUs and updated clinical labor rates for the Behavioral Health Care Manager. Our CoCM billing guide covers the codes.
ACO modifiers: G2211 becomes modifier B1, adding 16% to the E/M payment. A new modifier B2 adds 32% for practitioners in a Shared Savings Program ACO or a LEAD Model ACO.
New codes: two advance care planning G codes (G0572 and G0573) for clinical staff time, plus shared medical appointment coding.

The fact sheet doesn't mention any change to who may deliver CCM. Our post on outside staff and CCM still describes the staffing rules for that program, but check it against the final rule text because CMS keeps asking questions about care management delivery.

What this means for your practice

If you bill RPM or RTM, you have two jobs: fix intake by 1 January 2027, and plan the staffing model by 2029. If you don't bill them, the final rule mostly affects your payment rate and any ACO plans.

Here's a practical order of work:

Map your starts. List how patients begin RPM or RTM today and where the initiating visit fits. If monitoring starts from a referral or a phone call, add the visit before the first setup code.
Check RTM eligibility. If you bill RTM for patients new to the practice, those patients need an established relationship first.
Audit your three components. OIG's 43% finding is a useful self test. Pull a month of enrollees and see who got setup, a device and treatment management.
Count your contracted staff. If outside clinicians do monitoring work under your billing number, you have until 2029 to bring it in house or change the arrangement. Ask counsel what "employed" means for your structure.
Update your pricing model. Rework any 2027 budget that assumed current RPM and RTM values and last year's conversion factor.

At HANA we build patient outreach for practices that run care management programs, and our remote care page explains how that fits alongside your own clinical staff. For billing specifics, start with our RPM billing requirements guide and the RPM vs RTM comparison.

Frequently asked questions

Can my practice keep using a remote monitoring vendor in 2027?

Yes, under the final rule as CMS describes it. The requirement that only employed clinical staff perform RPM and RTM is delayed to 1 January 2029. The initiating visit and RTM established patient rules still apply from 1 January 2027.

Does the initiating visit have to be a separate appointment?

CMS calls it a separately reportable visit. That means a visit you can bill on its own, in person or by telehealth. Confirm in the final rule text whether a visit you already schedule for another reason can serve this purpose.

Are the RPM and RTM codes being replaced by G codes?

Not in this rule. CMS asked for comment on four bundled G codes and says it may consider those comments for future rulemaking. Keep billing the current CPT codes in 2027.

Is the 2027 payment cut the same for everyone?

No. CMS finalized $32.63 for clinicians who aren't qualifying APM participants and $32.95 for those who are. The percentage cuts are 2.31% and 1.83%, and actual payment still varies by code and geography.

When does the final rule become official?

CMS released it on 4 November 2026 and the Federal Register lists publication for 9 November 2026. Policies take effect 1 January 2027 unless the rule says otherwise, as it does for the 2029 staffing change.

Sources

CMS, "Calendar Year (CY) 2027 Medicare Physician Fee Schedule Final Rule" fact sheet, 2026: cms.gov
HHS, "CMS Finalizes CY 2027 Physician Fee Schedule to Shift from Sick Care to Healthcare and Curb Waste," press release, 4 November 2026: hhs.gov
Federal Register, "Medicare and Medicaid Programs: Calendar Year 2027 Payment Policies under the Physician Fee Schedule," public inspection document 2026-22743, 2026: federalregister.gov
HHS OIG, "Billing for Remote Patient Monitoring in Medicare," data snapshot OEI-02-23-00261, 2025: oig.hhs.gov
HHS OIG, "Additional Oversight of Remote Patient Monitoring in Medicare Is Needed," OEI-02-23-00260, 2024: oig.hhs.gov
Fierce Healthcare, "CMS finalizes steeper Medicare physician pay cuts for 2027, delays restriction on third-party RPM vendors," 2026: fiercehealthcare.com
American Hospital Association, "CMS issues CY 2027 physician fee schedule final rule," 2026: aha.org
Shumaker, Loop and Kendrick, "2027 Physician Fee Schedule Proposed Rule Would Upend Third-Party RPM and RTM Arrangements," 2026: shumaker.com

This article is educational and isn't billing, coding, clinical or legal advice. Check current CMS guidance and your MAC before you bill. If you want to talk through how this affects your care management program, book a discovery call.