On July 14, 2026, CMS released the CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P), and its remote monitoring section is the most consequential regulatory proposal these programs have faced since the codes were created. If finalized as written, it would bar contracted third-party clinical staff from performing billable RPM and RTM services, require a face-to-face initiating visit before monitoring begins, and revalue the code families downward.
One word in that paragraph carries all the weight: proposed. None of this is final. The comment period closes September 14, 2026, the changes would take effect January 1, 2027 only if finalized, and the 2026 rules and rates stand unchanged through December 31, 2026. This guide covers what CMS actually proposed, what it deliberately did not, and what practices should do in the next month.
What did CMS propose on July 14, 2026, and why?
The rule went on public inspection July 14, 2026 and was published in the Federal Register on July 16 (Document 2026-14327). For remote monitoring, it contains four things: an employment requirement for the clinical staff who perform the services, a new initiating-visit requirement, proposed revaluation of the setup, device-supply, and management codes, and a request for information on consolidating the code families into monthly bundles.
CMS frames the package as a program-integrity response to two HHS Office of Inspector General reports — the 2024 report "Additional Oversight of Remote Patient Monitoring in Medicare Is Needed" and a 2025 follow-up on RPM billing. The proposed rule quotes the OIG finding that "about 43 percent of enrollees who received remote patient monitoring did not receive all 3 components of it" — setup, device supply, and treatment management. In CMS's telling, a meaningful share of monitoring is being billed without the full service behind it, and the agency traces much of that to outsourced staffing models with thin connections to the billing practice.
The procedural facts, stated plainly:
- Status: proposed rule, open for public comment.
- Comment deadline: September 14, 2026 (a 60-day window).
- Effective date if finalized: January 1, 2027.
- Until then: the CY 2026 rules — the code structure, the 2-day and 16-day tiers, and current rates — remain fully in effect through December 31, 2026.
Who would be allowed to perform RPM and RTM under the proposal?
This is the provision practices are calling "the employment requirement," and it deserves precision, because the proposal is narrower than some of the early coverage suggested.
CMS proposes that, as a condition of payment, the clinical staff performing RPM and RTM services "must be a direct employee of the practitioner or the practitioner's practice." In the rule's words, beginning January 1, 2027 the RPM and RTM codes "could not be billed in cases where the service is not performed by clinical staff of the billing practitioner," and the policy "will not allow contracting out to third-party companies." The nurses and medical assistants who review readings, call patients, and log management time would have to be the practice's own employees.
Equally important is what the proposal does not change:
- Supervision stays general. This is a condition of payment layered onto the existing incident-to framework, not a supervision change. The regulation governing incident-to services (42 CFR § 410.26) is untouched.
- Remote employees remain fine. The proposal does not require staff to be on-site. A practice's own W-2 nurse working from another state can still perform the services, and the patient does not need to be on-site either.
- Technology vendors are not barred. Law-firm analyses of the rule consistently read the proposal as targeting contracted clinical staff who perform the billable service time — not third-party software platforms, device logistics, or technology support. A practice using vendor software while its own staff do the clinical work would remain compliant under that reading.
CMS's stated rationale is about care fragmentation and oversight. The rule argues that outsourced staff with "little to no established relationship with the beneficiary" can "fragment care," and states that CMS does "not believe that RPM or RTM services provided by clinical staff contracted by a third party can ensure the billing practitioner has adequate oversight, management, or collaboration." The agency cites OIG findings about beneficiaries being cold-called into monitoring programs. Notably, CMS also explicitly seeks comment "on how often third-party billing currently occurs and how this policy, if finalized, could impact access" — an open question the industry's comment letters will need to answer with data.
What is the proposed initiating-visit requirement?
The second major proposal would require a "separately reportable initiating visit in association with the onset" of RPM or RTM — for both programs. The elements:
- The visit must be face-to-face, either in person or via telehealth.
- It must be furnished by the billing practitioner — the one who will bill the monitoring codes.
- RPM or RTM must actually be discussed at the visit. In the rule's framing, "if RPM or RTM is not discussed with the patient at that visit, that visit cannot count."
- Visit codes that lack a face-to-face component, or that are not separately payable, cannot serve as the initiating visit.
- The visit is separately billable — it is not absorbed into the monitoring codes.
CMS describes the purpose as twofold: establishing clinical appropriateness before monitoring begins, and ensuring genuine patient consent — again a response to the OIG's cold-calling findings.
The proposal also closes a gap between the two programs. RPM has required an established patient relationship since the CY 2021 final rule; RTM currently has no established-patient requirement at all. The proposed rule would extend the established-patient requirement to RTM, putting both programs on the same footing. Today, neither program has a free-standing initiating-visit requirement — this would be new for both.
How would payments change?
The proposal's third leg is revaluation, and here the direction is clear even though the magnitude is not.
CMS states that it suspects the device-related codes are overvalued — that "devices may be available at a reduced cost compared to our initial estimates" — and notes it has received "very little invoice or pricing information" from industry to support current practice-expense inputs. Its proposed fix works through crosswalks:
- Setup codes (99453 and RTM's 98975) would take their practice-expense inputs from CPT 99473, the self-measured blood pressure setup code.
- RPM device-supply codes (99445 and 99454) would take practice expense from CPT 99474.
- RTM device codes (98976, 98977, 98978, 98984, 98985, 98986) would crosswalk to CPT 93270.
- The treatment-management codes (99457, 99458, 99470, and RTM's 98979, 98980, 98981) would have their practice-expense inputs eliminated entirely, retaining only their work RVUs.
The net effect, if finalized, would be meaningful cuts to setup, device-supply, and management payments. No single percentage figure exists — final numbers depend on rate-setting mechanics and on the invoice and pricing evidence CMS is explicitly soliciting from industry — so any specific cut percentage you see quoted is an estimate, not a published fact. The device requirements themselves (the FDA device definition and transmission rules) are unchanged.
For the current code structure and rates these proposals would modify, see our 2026 RPM CPT code billing reference.
Is CMS replacing the CPT codes with G-codes?
Not in this proposal — but it is thinking about it out loud, and the thinking is detailed enough to take seriously.
Alongside the formal proposals, the rule includes a request for information on consolidating the 17 RPM and RTM codes into four monthly G-code bundles: GRPM1 and GRTM1 for setup and patient education, and GRPM2 and GRTM2 as per-calendar-month bundles combining device supply, at least 2 days of data, and treatment management including at least one real-time interactive communication and at least 20 minutes of time. As drafted in the RFI, "all service elements would be required each calendar month" — which would erase the 2-day/16-day distinction, eliminate the add-on codes, and make treatment management mandatory in every billed month. CMS floated work RVUs of 0.61 for GRPM2 (drawn from 99457) and 0.62 for GRTM2 (from 98980), and seeks comment on implementation for rural health clinics and FQHCs.
The discipline here is in the verbs: CMS is considering and seeking comment, not proposing to require. But an RFI in a proposed rule can mature into final policy after the comment period, so practices modeling 2027 and beyond should understand what the bundled structure would mean for their panels — particularly for months that currently bill device supply without 20 minutes of management time.
What is not in the proposal?
Given the volume of commentary, the framing corrections matter as much as the proposals:
- No supervision change. General supervision for incident-to remote monitoring stays.
- No new data-day rules. The 2026 structure — 2–15 days under 99445, 16–30 days under 99454, and the RTM equivalents — stands. The proposal does not revisit it outside the G-code RFI.
- No new documentation or audit mandates in the remote monitoring section beyond the requirements the proposals themselves would create.
- Nothing effective in 2026. Every rate and rule in effect today remains in effect through December 31, 2026.
What should practices do before September 14, 2026?
The comment window is the operative deadline. A practical sequence:
Assess your staffing model against the employment requirement. If your monitoring is performed by your own employed nurses and medical assistants, you are largely aligned with the proposal already. If clinical service time is performed by contracted third-party staff, review those vendor contracts now and understand which functions are clinical staffing versus software, devices, and logistics — the line the proposal draws.
Design initiating-visit workflows regardless of outcome. A documented face-to-face visit where the practitioner discusses monitoring and obtains consent is defensible practice under any version of the rules, and analysts across the spectrum recommend building it now rather than retrofitting it in December 2027 planning.
Hold your 2027 budget assumptions. With revaluation proposed but unquantified, projecting 2027 remote monitoring revenue from 2026 rates is guesswork in both directions. Model scenarios; commit to none until the final rule.
Submit comments. Comments are due September 14, 2026 through regulations.gov under the CMS-1848-P docket. CMS has asked directly for data on how often third-party staffing occurs and what an employment requirement would mean for access, and for device invoice and pricing evidence. Attorneys following the rulemaking — Nixon Law Group among them — have observed that well-supported industry comments have a realistic chance of influencing the final rule.
The pushback is already substantial. ATA Action's Kyle Zebley called the proposal a "stark contradiction" with bipartisan congressional support for remote monitoring, adding: "CMS is looking to reduce fraud, waste, and abuse in healthcare, a goal we share. However, it should not be at the expense of providing remote monitoring for patients." Congress is a wildcard in the other direction, with bills like the Rural Patient Monitoring Access Act (H.R. 3108) and the KIDNEY Remote Monitoring Act (H.R. 8319) seeking to expand access.
How is Neuvora supporting practices through this?
Neuvora operates both staffing models today. Practices that want full-service monitoring use Neuvora's clinical team; practices that prefer to keep monitoring in-house run their own nurses and medical assistants inside Neuvora's software. The platform is identical either way — time tracking, alerting, documentation, and EHR flow into Tebra, PrognoCIS, and eClinicalWorks.
That matters here, because it makes the transition path operational rather than technological. If the employment requirement is finalized as written, a practice using full-service monitoring would shift its monitoring minutes to employed staff working in the same platform, with the same documentation trail — no software migration, no data loss, no retraining on a new system. Under the law-firm reading of the proposal — that software, technology, and device-logistics vendors are not barred, only contracted clinical staff performing service time — the platform layer remains compliant in both configurations.
Beyond the software, we work with practices on compliant workflow design, including initiating-visit scheduling and consent documentation — both worth building now, whatever the final rule says. For practices weighing the shift, we will help size the in-house model: how many monitoring hours a panel actually generates, and what it would take to staff them, before 2027 budgets are set.
We are following the rulemaking closely, including the comment docket and the G-code RFI, and will publish an analysis when the final rule lands — expected in late fall 2026, though that timing is a projection, not a published date. In the meantime, our RPM program overview describes how the practice-staffed model works today, and practices weighing their exposure to the proposal can talk to our team.
The bottom line
The CY 2027 proposed rule is not the end of remote monitoring, and it is not yet the law. It is CMS drawing a line: monitoring billed by a practice should be performed by that practice's people, initiated face-to-face, and priced on evidence. Practices running employed-staff programs are largely already on the right side of that line. Practices relying on contracted clinical staffing have a month to tell CMS — with data — what the proposal would mean for their patients, and a year to plan for whichever version becomes final.
This article is general billing information, not billing, legal, or medical advice. Verify current rates and payer policies against the CMS Physician Fee Schedule and your MAC before billing.
