Who Can Bill for RPM and RTM Under the Proposed CMS 2027 Rules?

A common question from medical practices is: Who can bill Medicare for Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM)?

The answer depends on the specific service, applicable Medicare requirements, and the practitioner's scope of practice. But the proposed 2027 changes create another important question: Who actually performs the clinical work?

For more details on how these proposed policy updates affect practice operational expenses, check out our guide on How the CMS 2027 RPM Proposal Could Change Your Practice Costs. Additionally, for an in-depth review of specific CPT code valuations and crosswalk changes, read our analysis on CMS 2027 RPM and RTM CPT Code Changes.

Quick Answer

The practitioner who reports an RPM or RTM service and the clinical staff performing the underlying work are not necessarily the same person.

Who may report a particular RPM or RTM service depends on the applicable Medicare requirements, the specific service or code, and the practitioner's eligibility. Separately, CMS is proposing that RPM and RTM services be performed by clinical staff who are direct employees of the billing practitioner or the practitioner's practice, rather than provided through a third-party contractor.

If finalized, this means practices should evaluate both:

• Who reports the service
• Who performs the clinical work

Why Does This Matter?

A practice might have an eligible practitioner reporting the service while other staff:

• Review patient data
• Review alerts
• Communicate with patients
• Document interactions
• Perform care management

Under the proposed CY 2027 framework, the employment relationship of those clinical staff becomes especially important. CMS is proposing that RPM and RTM services be performed by clinical staff employed by the billing practitioner or the practitioner's practice, rather than by clinical staff provided through third-party companies. If finalized, this could significantly affect practices that currently rely on outside organizations to provide clinical personnel for RPM or RTM. To explore broader practice preparation strategies, read our foundational guide, CMS 2027 RPM Update: What Physicians Need to Know.

Review Your Current Workflow

Create a simple internal map to evaluate your practice's compliance status:

If a third-party vendor provides clinical staff who perform these functions, identify that arrangement now and determine who employs those individuals.

What About Nurse Practitioners and Other Practitioners?

Medicare billing eligibility depends on the service and the practitioner's applicable Medicare rules. The key point for the proposed 2027 changes is not simply whether a practitioner can report the service. Your practice also needs to understand who performs the clinical work supporting the service.

What About the Proposed RTM Established-Patient Requirement?

CMS is also proposing a change specifically affecting Remote Therapeutic Monitoring (RTM). Under the proposed CY 2027 rule, RTM services would be furnished only to established patients.

CMS is also proposing that practitioners reporting RPM or RTM services furnish a separately reportable initiating visit associated with the onset of RPM or RTM services. These are proposed changes and are not yet final Medicare requirements. Practices that provide RTM should therefore review how patients are established, how the initiating visit is performed and documented, and when the monitoring service begins.

What Should an Independent Practice Ask?

Ask key operational questions to identify structural gaps:

• Who submits the claim?
• Who employs the clinical staff?
• Who reviews the data?
• Who handles alerts?
• Who communicates with the patient?
• Who documents the work?
• Who provides clinical oversight?
• Are the clinical staff performing the service employees of the practice or a third-party contractor?

These answers should be consistent with your actual workflow.

What Medical Office Force Recommends

Do not begin with the billing code. Begin with the patient workflow. Map the process sequentially:

Patient → Practitioner → Clinical Staff → Technology → Documentation → Billing

Once you understand the workflow, it becomes much easier to identify where the proposed CMS changes could affect your practice.

Final Takeaway

For 2027, physicians and medical practices should look beyond the question of "Who bills for RPM or RTM?" The better question is:

"Who is eligible to report the service, who is actually performing the clinical service, and how is that clinical staff relationship structured?"

CMS is proposing that RPM and RTM services be performed by clinical staff who are direct employees of the billing practitioner or the practitioner's practice, rather than by clinical staff contracted through third-party companies. CMS is also proposing that RTM services be furnished only to established patients and that practitioners reporting RPM or RTM furnish a separately reportable initiating visit associated with the onset of those services.

These are proposed CY 2027 policies, not final rules. Practices should review their current workflows and staffing arrangements now so they can evaluate the potential impact if the proposals are finalized. For deeper insight into financial modeling, refer to our analysis on How the CMS 2027 RPM Proposal Could Change Your Practice Costs.

Authoritative Sources

• Centers for Medicare & Medicaid Services — CY 2027 Medicare Physician Fee Schedule Proposed Rule
• Federal Register — CY 2027 Payment Policies Under the Physician Fee Schedule
• CMS — Physician Fee Schedule Overview