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The CMS CY 2027 Physician Fee Schedule proposed rule does more than change who can perform Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) services. It also proposes changing the codes themselves, how they are valued, and potentially how many of them exist at all.
If your practice bills RPM or RTM today, this article walks through exactly which codes are affected, what CMS is proposing to do to each one, and what your billing and coding team should be reviewing before the final rule is published.
Educational Notice: This analysis covers the CMS CY 2027 Physician Fee Schedule proposed rule for informational purposes and does not constitute formal legal, coding, billing, or compliance advice.
For the broader staffing, initiating visit, and operational changes in the same proposed rule, explore our foundational breakdown in the CMS 2027 RPM Update: What Physicians and Practices Need to Know. Furthermore, if you are evaluating the financial impact of clinical labor shifts, check out our guide on CMS 2027 RPM Practice Cost Forecasting.
CMS is proposing two separate but related coding changes for 2027:
Neither of these is decided yet. Both are still proposals under review.
Before looking at what might change, it helps to see the full list of codes under review across both monitoring categories.
| CPT Code | What It Covers | Code Type |
|---|---|---|
| 99453 | Initial setup and patient education on RPM device use | Practice expense (one-time) |
| 99454 | Device supply with daily recording or programmed alert transmission, 16 or more days in 30 | Practice expense (monthly) |
| 99445 | Device supply with daily recording or programmed alert transmission, 2 to 15 days in 30 days | Practice expense (monthly) |
| 99091 | Collection and interpretation of physiologic data, minimum 30 minutes | Physician/QHP work |
| 99457 | Treatment management, first 20 minutes of interactive communication per month | Clinical staff/physician time |
| 99458 | Treatment management, each additional 20 minutes per month | Clinical staff/physician time |
| 99470 | Treatment management, 10-minute increment per month | Clinical staff/physician time |
| CPT Code | What It Covers | Code Type |
|---|---|---|
| 98975 | Initial setup and patient education on RTM device use | Practice expense (one-time) |
| 98976 | Device supply, respiratory system monitoring | Practice expense (monthly) |
| 98977 | Device supply, musculoskeletal system monitoring | Practice expense (monthly) |
| 98978 | Device supply, cognitive behavioral therapy monitoring | Practice expense (monthly) |
| 98984 | Device supply, respiratory system, short duration (2-15 days in 30 days) | Practice expense (monthly) |
| 98985 | Device supply, musculoskeletal system, short duration (2-15 days in 30 days) | Practice expense (monthly) |
| 98986 | Device supply, cognitive behavioral therapy, short duration (2-15 days in 30 days) | Practice expense (monthly) |
| 98980 | Treatment management, first 20 minutes of interactive communication per month | Clinical staff/physician time |
| 98981 | Treatment management, each additional 20 minutes per month | Clinical staff/physician time |
That is 16 individual codes across both code families, plus 99470, for a total of 17 codes CMS has flagged as part of this proposal.
CMS is not proposing a single across-the-board cut. Instead, the agency is proposing two different adjustments depending on what type of code it is.
CMS is proposing to reassign, or "crosswalk," the practice expense inputs of certain RPM and RTM codes to other existing CPT codes that carry lower resource assumptions:
In practical terms, this means CMS wants to value the work and supply cost of setting up and maintaining RPM or RTM devices using the cost profile of a different, generally lower-cost service, rather than the cost data originally used to build these codes.
For the treatment management codes (99457, 99458, 99470, 98979, 98980, and 98981), CMS is proposing something more direct: eliminating the practice expense component entirely, while keeping the existing physician work values and time components in place.
CMS's stated reasoning is that these codes already reflect physician or qualified healthcare professional work, and that the resource costs are captured there rather than in separate clinical staff time. Practices should understand what this means for their financial modeling: if finalized, this proposal would strip out the portion of the code's value tied to clinical staff time even though clinical staff time is central to how most practices actually deliver treatment management services.
This is a meaningful distinction. It is not simply an across-the-board rate reduction; setup and supply codes may be pegged to lower-cost codes, and treatment management codes may lose their clinical staff cost component altogether. For a deeper breakdown of how this interacts with staffing requirements, see our physician guide to the CMS 2027 RPM update.
Separately from the revaluation proposal, CMS is seeking public comment on collapsing the 17 codes above into four new HCPCS Level II G-codes, generally understood to correspond to two codes for RPM and two for RTM.
What this would likely mean, based on how CMS frames the request:
What we do not yet know:
Because CMS has only requested comments on the concept, not published draft code language, practices should not assume any specific G-code definitions at this stage.
While you shouldn't overhaul your systems prematurely, there are three proactive steps to complete during the comment period:
Do not overhaul your billing system based on a proposal. Wait for the final rule. Making permanent changes now, based on proposed language that could still shift after public comments, creates unnecessary work and risk.
Not necessarily. CMS has only requested public comments on the idea of replacing the current codes with four new ones. No decision has been made, and CMS has not declared that current codes will be eliminated.
Not confirmed. CMS has stated it wants to update valuation because it believes device costs are lower than originally assumed, but exact final numbers are not yet published.
CMS has not published specific definitions for these codes yet. It has only asked for public comments on the general concept of combining the current codes into four new ones.
If CMS finalizes changes as proposed, they would generally take effect starting January 1, 2027.
Not yet. Identify where affected codes live in your system to prepare, but hold off on permanent updates until the final rule is published late in 2026.
The coding portion of the CMS 2027 proposed rule is easy to undersell as a simple valuation update, but it represents a structural shift. CMS is proposing to revalue setup and device supply codes using cost data borrowed from unrelated services, strip practice expense entirely from treatment management codes, and explore replacing the entire 17-code RPM/RTM family with four new codes.
For billing and coding teams, the immediate mandate is preparation, not implementation: audit code utilization in your EHR, model financial scenarios, and track commercial payer alignment. For more details on clinical staffing rules and initiating visit requirements, refer to our companion analysis on CMS 2027 RPM Policy Updates.
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Thanks for sharing. This is very valuable information, and there are a lot of great learning lessons to take away from it.
Nice information about RTM and RPM which is initial setup, education codes and device supply codes.
Helpful overview of the proposed CPT code changes
Very informative, thanks for sharing, replacing 17 codes with 4 g-codes makes billing simpler though practices must prepare now for the coding transition.
great information
Very informative update on the upcoming RPM/RTM billing changes. This will be helpful for us to understand the new requirements and prepare our billing process accordingly.
Excellent explanation—very informative and easy to understand.
Informative
Very informative!
Very informative update on the upcoming RPM/RTM billing changes.