The CY2027 RPM and RTM Contractor Proposal: What Changes for Practices

Matteo

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

The CY2027 RPM and RTM contractor proposal is a CMS plan, published in July 2026, to pay for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) only when the clinical work is done by staff the billing practice directly employs. If finalized, it starts 1 January 2027. It doesn't touch CCM, PCM, APCM, TCM, BHI or CoCM.

I've sat on both ends of the monitoring call, and the question practices keep asking me isn't "is this fair?" It's "which of my programs is actually exposed?" That's what this explainer answers.

Key facts

CMS issued the CY2027 Physician Fee Schedule proposed rule on 14 July 2026, and it was published in the Federal Register on 16 July 2026 (CMS fact sheet).
The rule would allow RPM and RTM payment only when services are performed by clinical staff employed by the practice, not by contractors (Federal Register, 2026).
Public comments closed on 14 September 2026. If finalized, the policy applies from 1 January 2027.
Medicare paid $536 million for RPM in 2024, and nearly 1 million enrollees received it (HHS OIG, 2025).
About 43% of enrollees who received RPM in 2022 didn't receive all three components of the service (HHS OIG, 2024).
A coalition letter dated 14 September 2026 with more than 200 signers asked CMS not to finalize the policies (Alliance for Connected Care, 2026).
Senators Mark Warner and Marsha Blackburn wrote to CMS on 23 September 2026 asking it to reconsider the staffing limits (Warner and Blackburn letter, 2026).

What exactly did CMS propose for RPM and RTM?

CMS proposed four changes to remote monitoring and asked for comment on a fifth. The headline is the staffing rule, but the other three change how a program starts and what it earns.

Here's the list, straight from the CMS fact sheet and the proposed rule:

Direct employment. RPM and RTM would be payable only when clinical staff employed by the billing practice do the work. Contracted staff from a third party company wouldn't count.
Initiating visit. Every RPM or RTM episode would need a separately reportable visit, in person or by telehealth, where the billing practitioner actually discusses monitoring with the patient.
Established patients for RTM. RTM would join RPM in being limited to patients who already have a relationship with the practice.
Revaluation. CMS proposed lowering practice expense values because it believes devices now cost less than its original estimates.
Bundling (comment only). CMS asked whether to replace the current RPM and RTM codes with four G codes. It didn't propose rates for them.

Staff don't have to sit in the office. They can still work remotely under general supervision. What changes is whose payroll they're on.

Why is CMS targeting contractors now?

CMS points to Office of Inspector General findings on how remote monitoring has been billed. The short version: fast growth, and a lot of programs where the billing practice had thin involvement with the patient.

The numbers behind that concern are public. OIG found Medicare paid $536 million for RPM in 2024, up 31% from 2023, with nearly 1 million enrollees. Its 2024 report found that about 43% of 2022 enrollees didn't receive all three RPM components: setup and education, device supply, and treatment management. OIG notes CMS doesn't require all three to be billed, but it flagged the gap as a sign that monitoring may not be used as intended.

CMS's own language in the proposed rule says outsourcing can fragment care and leave the billing practitioner with too little oversight. That's the logic: if the practice employs the people doing the work, the practice owns the relationship.

The honest limit here is that the rule doesn't show employment status predicts quality. Plenty of contracted nurses work inside a practice's workflow and escalate well. Plenty of employed staff don't. CMS chose employment as a bright line because it's easy to audit, not because the evidence proved it's the right proxy.

Which programs are exposed, and which aren't?

Only RPM and RTM are named in the proposal. Every other care management code keeps today's staffing rules.

RPM (99453, 99454, 99445, 99457, 99458, 99470, 99091): exposed. Contracted clinical staff time would stop counting from 1 January 2027 if finalized.
RTM (98975, 98976, 98977, 98978, 98984, 98985, 98986, 98979, 98980, 98981): exposed, plus the new established patient rule.
CCM (99490, 99439, 99487, 99489, 99491, 99437): not in the proposal. CMS's CCM FAQ says a practice may use clinical staff external to the practice, for example a case management company, if all incident to rules are met (CMS CCM FAQ).
APCM (G0556, G0557, G0558): not in the proposal.
PCM, TCM, BHI and CoCM: not in the proposal.

Two caveats. First, the CCM FAQ also says the billing practitioner's oversight work can't be subcontracted, and CCM staff can't be located outside the United States. Second, the same proposed rule includes a broad request for information on care management. Legal analysts at Nixon Law Group note that it asks how much care management should be delivered by the supervising practitioner versus auxiliary staff. So CCM is safe for 2027 as proposed, not forever.

If you want the wider map of which codes can sit together, our post on why APCM and CCM can't be billed together covers the overlap rules.

What's the timeline between now and January?

The comment period is closed, so the next move is CMS's. Here's the sequence:

14 July 2026: CMS issues the proposed rule.
16 July 2026: publication in the Federal Register.
14 September 2026: comments close. The coalition letter lands the same day.
23 September 2026: Senators Warner and Blackburn send their letter.
Later this fall: CMS publishes the final CY2027 fee schedule. It can finalize the policy as proposed, change it, delay it, or drop it.
1 January 2027: finalized provisions take effect.

The gap between step 5 and step 6 is the real risk. If the rule is finalized as proposed, a practice with a contracted RPM team would have only weeks to hire, move patients, or wind the program down. That's why planning now matters even though nothing is final.

Who is pushing back, and what are they asking for?

The pushback is broad and bipartisan. It isn't only monitoring companies.

The Alliance for Connected Care coalition letter, signed by health systems, specialty societies and patient groups, argues the rule would disrupt care for about 1 million beneficiaries and hit small, rural and safety net practices hardest. It asks CMS to delay and build targeted safeguards instead of a blanket employment rule.

The Warner and Blackburn letter makes a similar case. It says many hospitals and small practices rely on outside clinical partners for onboarding, data review, alerts and escalation, and asks CMS to act on OIG's earlier recommendations, such as collecting ordering provider data, before restricting staffing models.

None of this guarantees a change. CMS has heard strong objections to fee schedule proposals before and finalized them anyway. Plan for both outcomes.

What this means for your practice

Start by sorting your programs into exposed and not exposed. Then decide what you'd do in each scenario before the final rule arrives, not after.

List who does the clinical work for each RPM and RTM patient. W2 staff of the billing entity are clearly inside the rule. Vendor supplied nurses are clearly outside it. Staff employed by an affiliated entity or MSO are a grey zone the proposal doesn't define, so get a legal read.
Model the in house option. Count patients, monthly treatment management minutes, and what it would cost to employ that time.
Check your enrollment workflow against the initiating visit rule. Monitoring has to be discussed at a billable face to face visit.
Leave CCM, APCM and TCM alone for now. Outside clinical staff remain allowed there under incident to rules, so don't dismantle a working program out of fear.
Assign one person to read the final rule the week it's published.

Technology, devices and software aren't restricted under the proposal. HANA builds that kind of patient outreach infrastructure for practices through HANA Remote; for AI calls to patients, our TCPA healthcare exemption explainer covers the consent side.

Frequently asked questions

Can I still buy RPM devices and software from a vendor in 2027?

Yes, as proposed. The restriction targets clinical staffing, not devices, platforms or analytics. The clinical time you bill would need to come from your own employees.

Do remote RPM nurses have to work in my office?

No. The proposal says clinical staff don't need to be physically in the practice and can work under general supervision. They'd need to be direct employees of the practitioner or the practice.

Does the contractor ban apply to chronic care management?

Not in the CY2027 proposal. CMS guidance still allows CCM clinical staff external to the practice if all incident to rules are met, though the billing practitioner's own oversight work can't be subcontracted.

What happens to patients already enrolled in RPM on 1 January 2027?

CMS's summary of the proposal doesn't describe a transition period, and commenters have asked CMS to add one. Until the final rule says otherwise, assume existing patients would need to meet the new rules too.

Is the four G code bundle happening in 2027?

It isn't formally proposed. CMS only asked for comments on replacing the current codes with four bundled G codes and hasn't proposed payment rates, so it would take future rulemaking.

Sources

Centers for Medicare & Medicaid Services. Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule, fact sheet. 2026. cms.gov
Federal Register. Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule (CMS-1848-P). 2026. federalregister.gov
HHS Office of Inspector General. Billing for Remote Patient Monitoring in Medicare (OEI-02-23-00261). 2025. oig.hhs.gov
HHS Office of Inspector General. Additional Oversight of Remote Patient Monitoring in Medicare Is Needed (OEI-02-23-00260). 2024. oig.hhs.gov
Centers for Medicare & Medicaid Services. Frequently Asked Questions about Billing Medicare for Chronic Care Management Services. cms.gov
Alliance for Connected Care. Over 230 Organizations Urge CMS to Protect Remote Monitoring. 2026. connectwithcare.org
Sen. Mark R. Warner and Sen. Marsha Blackburn. Letter to CMS Administrator on remote monitoring. 2026. warner.senate.gov
Nixon Law Group. The CY 2027 MPFS Proposed Rule is here: What's at Stake for RPM, RTM, and Care Management? 2026. nixonlawgroup.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're working out what the final rule means for your programs, book a call with me.