CMS Restricts Remote Monitoring Payments to In-House Staff

The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule on July 16, 2026, outlining significant changes to remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) for the 2027 Medicare Physician Fee Schedule. The rule, CMS-1848-P, published in the Federal Register, addresses patient eligibility, initiating visits, staffing, payment, and coding structures. Public comments on the proposal closed on September 14, 2026.

CMS proposed several key modifications. First, RTM services would be limited to established patients only. Second, practitioners billing for RPM or RTM must conduct a separately reportable initiating visit when services begin. Third, payment for these services would require clinical staff to be employed by the practice, not contracted out. CMS also plans to adjust valuation for remote monitoring services based on updated device cost estimates and seeks input on consolidating current CPT codes into four new HCPCS G-codes. The agency cited recent Office of Inspector General reports as justification for the proposed G-code structure, emphasizing the need to address perceived gaps in the existing code framework.

The most impactful change for physician practices involves CMS’s proposal to restrict RPM and RTM payments to services provided by clinical staff employed directly by the billing practice, rather than contractors. This shift could reshape vendor relationships, staffing models, documentation protocols, and the financial viability of existing monitoring programs. RPM involves collecting patient-generated health data—such as blood pressure, weight, or pulse oximetry—through connected devices, while RTM tracks therapeutic or nonphysiologic data like respiratory status or medication adherence.

Chronic Care Management (CCM) serves a distinct role for patients with multiple chronic conditions requiring ongoing care coordination.

The coding framework has already evolved. Starting January 1, 2026, Medicare introduced shorter-duration codes, dividing RPM and RTM into device supply and treatment management categories. For RPM, CPT 99445 and 99454 cover device supply for 2-15 days and 16+ days, respectively, while 99470 and 99457-99458 address treatment management time.

RTM codes similarly split device supply (98984-98986 and 98976-98978) and treatment management (98979-98981). These changes reflect ongoing efforts to refine billing accuracy and service specificity.

Practice implications are substantial. Small, rural, and specialty practices relying on outsourced monitoring may need to overhaul staffing and workflows if clinical staff must be employed directly. Questions remain about CMS’s definition of “employed by the practice,” particularly whether it extends beyond traditional W-2 employees to affiliated arrangements.

Program integrity concerns extend beyond employment status. The False Claims Act case United States ex rel. Family Clinic of Albany v. ChartSpan Medical Technologies illustrates potential liability for unsupported billing or improper financial arrangements. CMS emphasized that changing a worker’s employment status does not inherently resolve compliance issues; the core requirement remains that services must be medically necessary, properly documented, and accurately billed. Practices are advised to review workflows, assess current compliance with medical necessity and documentation standards, and reconcile claims with source records before the final rule is issued.