CMS 2027 Physician Fee Schedule: RPM & RTM Changes for Medical Practices

The Centers for Medicare & Medicaid Services (CMS) released its Calendar Year 2027 Medicare Physician Fee Schedule (PFS) proposed rule on July 14, 2026. The proposal includes changes to Medicare Part B payment policies that could affect physicians and medical practices providing Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM).

For practices using remote monitoring, several provisions deserve particular attention. CMS is proposing changes involving clinical staffing, initiating visits, RTM patient requirements, coding, valuation and payment.

The public comment period closes September 14, 2026. These are proposed policies, not final 2027 Medicare requirements. Practices should monitor the final rule before making permanent changes to staffing, billing or vendor arrangements.

Important: This article discusses the CMS CY 2027 Physician Fee Schedule proposed rule for educational purposes. It does not constitute legal, coding, billing, or compliance advice.

What Is the CMS 2027 Physician Fee Schedule?

The Medicare Physician Fee Schedule establishes payment policies and payment amounts for many professional services furnished to Medicare beneficiaries.

The CY 2027 PFS proposed rule, identified as CMS-1848-P, covers a broad range of Medicare Part B payment and coverage policies. For medical practices using remote monitoring, the RPM and RTM provisions are particularly important because they could affect how these services are staffed, initiated, coded, valued, and reimbursed.

This article focuses specifically on the proposed changes that could affect RPM and RTM programs operated by physicians and independent medical practices.

Quick Answer: What Are the Biggest Proposed RPM and RTM Changes for 2027?

The proposed rule could affect five major areas:

• Clinical staffing: CMS is proposing that RPM and RTM services be performed by clinical staff employed by the practice rather than contractors.
• Initiating visits: CMS is proposing a separately reportable initiating visit associated with the onset of RPM or RTM services.
• RTM patients: CMS is proposing that RTM services be furnished only to established patients.
• Coding: CMS is considering bundling the existing RPM and RTM codes and creating four new HCPCS G-codes.
• Valuation and payment: CMS is proposing updates to how RPM and RTM services are valued under the Physician Fee Schedule.

The practical impact will depend on what CMS ultimately includes in the final CY 2027 Physician Fee Schedule.

1. Proposed RPM and RTM Clinical Staffing Requirement

One of the most significant proposed changes concerns who performs the clinical work associated with RPM and RTM.

CMS is proposing to allow payment for RPM and RTM services only when the clinical services are furnished by clinical staff employed by the billing practitioner or practice, rather than when those services are delivered by contractors.

This could be particularly important for practices that use an RPM or RTM company providing both technology and clinical personnel.

Consider a common arrangement:

A medical practice contracts with an RPM company that provides:

• Blood pressure or other connected devices
• RPM software
• Cellular connectivity
• Nurses or other clinical personnel
• Alert review
• Patient communication
• Documentation support

If the proposal is finalized substantially as written, the practice would need to carefully evaluate the employment relationship of the people performing the clinical work.

What Should Practices Review?

Start by separating your vendor's services into three categories:

1. Technology
   • RPM or RTM software
   • Connected devices
   • Cellular connectivity
   • Data transmission
   • Technology infrastructure
2. Operational support
   • Device shipping
   • Device replacement
   • Device logistics
   • Technical support
3. Clinical services
   • Patient data review
   • Alert assessment
   • Clinical communication
   • Treatment management
   • Clinical decision-making
   • Clinical documentation

The key question is: Who performs the clinical work, and who employs those individuals?

Practices do not necessarily need to assume that their entire vendor relationship is affected. Instead, they should first understand exactly what the vendor does today and which activities involve clinical personnel.

How to Audit Your Current RPM Vendor Model Before 2027

If your practice currently works with an RPM vendor, don't begin by asking whether you need to terminate or replace the vendor.

Begin by mapping the services the vendor actually performs.

This exercise does not predict what CMS will ultimately finalize. It gives your practice a clearer picture of where technology ends and clinical responsibility begins. That distinction could become particularly important if CMS finalizes the proposed staffing requirement.

2. Proposed Initiating Visit for RPM and RTM

CMS is also proposing that practitioners reporting RPM or RTM services furnish a separately reportable initiating visit associated with the onset of those services.

For physicians and medical practices, this could affect how patients enter a remote monitoring program.

Your workflow should clearly establish:

• Why the patient needs remote monitoring
• What condition is being monitored
• Why RPM or RTM is appropriate
• Who established the clinical need
• What monitoring plan is being used
• Where the clinical decision is documented
• How the patient is enrolled

A practical workflow may look like:

Clinical evaluation → clinical decision → documentation → patient enrollment → device setup → ongoing monitoring

The objective is to create a clear connection between the patient's clinical need and the remote monitoring service.

3. Proposed Established-Patient Requirement for RTM

The proposed rule also includes an important change for Remote Therapeutic Monitoring (RTM).

CMS is proposing that RTM services be furnished only to established patients.

Practices using RTM should therefore review their current enrollment process and patient relationship documentation.

Your team should be able to identify:

• The patient's relationship with the practice
• The condition being monitored
• Why RTM is appropriate
• The practitioner responsible for care
• The clinical purpose of monitoring
• Supporting documentation

This may be particularly relevant for practices using automated or vendor-supported RTM enrollment workflows.

4. Proposed Four-Code Structure for RPM and RTM

CMS is also considering bundling the existing RPM and RTM CPT codes and creating four new HCPCS G-codes to describe remote monitoring services. CMS is seeking public comment on this potential approach.

This is important to understand:

The four-code structure is not a finalized 2027 coding system.

If CMS ultimately adopts a new structure, practices may need to review:

• Billing software
• EHR templates
• Charge capture
• Claims workflows
• Documentation processes
• Staff training
• Revenue forecasts

Should Practices Change Their Billing System Now?

Not necessarily.

Because CMS has proposed the changes but has not finalized them, practices should prepare for possible coding changes without making permanent production billing changes solely because of the proposed rule.

Once CMS publishes the final rule, practices can determine what actually needs to change.

5. Proposed Payment Changes

How the 2027 Physician Fee Schedule Could Affect RPM and RTM Payment

Payment and valuation are another important part of the proposal.

CMS is proposing updates to the valuation of RPM and RTM services because the agency believes the devices used for these services may be available at a reduced cost compared with its initial estimates.

For practices, this means the proposed 2027 changes are not simply about staffing and coding. The valuation of the services themselves is also under review.

However, practices should be careful when discussing 2027 RPM reimbursement or 2027 RTM reimbursement rates.

The proposed valuations are not the same as final Medicare payment rates.

Until CMS publishes the final rule, practices should treat the proposed payment policies as a planning consideration rather than a guaranteed 2027 reimbursement amount.

How Should Practices Prepare Financially?

Instead of building a 2027 RPM or RTM budget around one assumed reimbursement amount, calculate the complete cost of delivering the service.

Consider:

• Clinical staff compensation
• Patient enrollment
• Device costs
• Technology
• Connectivity
• Data review
• Alert management
• Patient communication
• Documentation
• Billing
• Administrative support
• Vendor expenses

Then create conservative, expected, and optimistic financial scenarios.

The important question is not simply: "What will CMS pay for RPM or RTM in 2027?"

It is: "What will it cost our practice to deliver the service compared with the Medicare payment?"

How Could the 2027 Fee Schedule Affect Medical Practices?

The proposed changes could affect more than reimbursement.

• Staffing: Practices using outsourced clinical monitoring services may need to review who performs clinical work and how those workers are employed.
• Patient Enrollment: Practices may need to review how clinical need, initiating visits, patient relationships, and monitoring plans are documented.
• Billing: Potential changes to codes and valuation could require updates to billing systems, EHR workflows, and staff training.
• Vendor Relationships: Practices should understand exactly what their RPM or RTM vendor provides and distinguish clinical services from technology and operational support.
• Financial Planning: Practices should evaluate both expected Medicare reimbursement and the actual cost of operating their monitoring program.

Can Medical Practices Still Use RPM Vendors in 2027?

The proposed changes do not mean that medical practices must eliminate third-party technology vendors.

A practice may still use outside organizations for services such as:

• RPM software
• Connected devices
• Cellular connectivity
• Device logistics
• Device shipping
• Technical support
• Technology infrastructure

The important issue is understanding the difference between technology and operational support and clinical services.

If a vendor supplies clinical personnel who perform work covered by the proposed staffing provisions, the practice should carefully evaluate that arrangement.

Because the rule is not final, practices should avoid making permanent vendor decisions based solely on the proposed language.

Why Is CMS Proposing Changes to RPM and RTM?

CMS notes that remote monitoring is a relatively recent area of Medicare payment and that the agency has established payment for RPM and RTM code families. In the 2027 proposal, CMS points to recent HHS Office of Inspector General reports and says the current coding structure may not fully address the concerns identified in those reports.

For medical practices, the broader lesson is straightforward: RPM and RTM should be managed as clinical services supported by technology, not simply as technology or billing programs.

Practices should be able to clearly demonstrate:

• Who performs the work
• Why the patient receives the service
• What condition is being monitored
• What clinical activity occurred
• How the service was documented
• How the service was billed

What Should Physicians and Medical Practices Do Now?

Medical Office Force recommends five practical steps:

1. Review Your Staffing Model: Identify everyone involved in RPM and RTM. Determine: Who reviews patient data? Who manages alerts? Who communicates with patients? Who performs clinical work? Who employs those individuals? Who documents the clinical activity?
2. Review Your Vendor Contract: Separate technology and operational services from clinical services. This gives your practice a clearer understanding of how the proposed staffing provisions could affect your current arrangement.
3. Review Patient Enrollment: Confirm how your practice establishes: Clinical need, Medical necessity, Patient eligibility, Initiating visits, Patient relationship, Monitoring plans, and Documentation.
4. Review Your Financial Model: Calculate the actual cost of your RPM or RTM program. Include staff, devices, technology, patient support, administrative work, billing, and vendor expenses. Then model potential 2027 reimbursement scenarios.
5. Monitor the Final Rule: Prepare now, but avoid treating the proposed rule as final. CMS's official regulation page lists September 14, 2026 as the comment-period deadline. The final rule will determine which proposed policies ultimately take effect.

CMS 2027 Physician Fee Schedule: Important Dates

• July 14, 2026: CMS issued the CY 2027 Physician Fee Schedule proposed rule.
• July 16, 2026: The proposed rule was published in the Federal Register.
• September 14, 2026: Public comments are due.
• Late 2026: CMS is expected to issue the final rule.
• January 1, 2027: Proposed policies would generally take effect if finalized.

CMS 2027 RPM and RTM FAQs

What is the CMS 2027 Physician Fee Schedule?
The CMS 2027 Physician Fee Schedule is the proposed Medicare payment and policy rule covering physician and other Part B services for calendar year 2027. CMS identifies the current proposal as CMS-1848-P.

What are the proposed 2027 RPM changes?
The proposal includes changes involving clinical staffing, initiating visits, coding, valuation, and other requirements that could affect Remote Patient Monitoring.

What are the proposed 2027 RTM changes?
The proposed changes include clinical staffing requirements, an initiating visit, an established-patient requirement, potential coding changes, and valuation changes.

Will RPM clinical staff have to be employed by the medical practice?
CMS is proposing to allow payment for RPM and RTM services only when the clinical services are furnished by clinical staff employed by the billing practitioner or practice, rather than by contractors. This is a proposed policy and is not yet final.

Can medical practices still use RPM vendors?
The proposed rule does not eliminate the use of third-party technology or operational vendors. Practices should, however, carefully evaluate arrangements in which a vendor provides clinical personnel.

Will RPM reimbursement change in 2027?
CMS is proposing updates to the valuation of RPM services. Final 2027 Medicare payment amounts will depend on the final Physician Fee Schedule.

Will RTM reimbursement change in 2027?
CMS is proposing updates affecting RTM valuation. Practices should wait for the final rule before treating proposed valuations as final 2027 reimbursement rates.

Will CMS create new RPM and RTM G-codes?
CMS is considering bundling the current RPM and RTM CPT codes and creating four new HCPCS G-codes. The agency is seeking comments on this approach; it is not yet a finalized coding structure.

Will RTM require an established patient in 2027?
CMS is proposing that RTM services be furnished only to established patients. This remains a proposed policy until the final rule is issued.

Will RPM and RTM require an initiating visit in 2027?
CMS is proposing that practitioners reporting RPM or RTM services furnish a separately reportable initiating visit associated with the onset of those services. The final requirements will depend on the final rule.

When will the CMS 2027 Physician Fee Schedule be final?
CMS is expected to publish the final CY 2027 Physician Fee Schedule later in 2026. Until then, the RPM and RTM provisions discussed here remain proposed.

Final Takeaway

The CMS 2027 Physician Fee Schedule proposed rule could change how medical practices approach RPM and RTM in several important areas, including staffing, patient enrollment, initiating visits, coding, documentation, valuation, and reimbursement.

For independent practices, this is the time to understand your current model, not to make rushed changes based on a proposal that could still be modified.

• Know who performs the clinical work.
• Know who employs those clinical workers.
• Know what your RPM or RTM vendor provides.
• Know how patients enter your monitoring program.
• Know what your program costs.

Then monitor CMS for the final 2027 requirements. The proposal is not the final rule. Preparation today can make it easier for your practice to respond if the proposed changes are finalized.

Medical Office Force analysis is intended for educational purposes and does not constitute legal, coding, billing, or compliance advice.

Authoritative Sources

• Centers for Medicare & Medicaid Services — CY 2027 Physician Fee Schedule Proposed Rule (CMS-1848-P)
• Centers for Medicare & Medicaid Services — CY 2027 Medicare Physician Fee Schedule Proposed Rule Fact Sheet
• Federal Register — CY 2027 Payment Policies under the Physician Fee Schedule and Other Part B Payment Policies
• HHS Office of Inspector General — Reports concerning Medicare Remote Patient Monitoring