2027 CMS Proposed Rule: RTM Changes for Practices

On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year 2027 Medicare Physician Fee Schedule Proposed Rule. Among the proposals are several potentially significant changes to how Medicare would cover and reimburse Remote Therapeutic Monitoring (RTM) beginning in 2027.

These proposals reach further than any single specialty. Because CMS is proposing parallel changes to both RTM and Remote Physiologic Monitoring (RPM), they would affect physician practices, physical therapy and occupational therapy practices, and any other healthcare organization billing Medicare for remote monitoring.

For healthcare practices, the biggest proposed changes include limiting RTM to established patients, requiring a separately reportable initiating visit when remote monitoring begins, restricting certain billable remote monitoring services performed by contracted clinical staff, and reevaluating how remote monitoring services are valued under the Medicare Physician Fee Schedule.

These changes are proposals, not current Medicare policy. CMS is accepting public comments through September 14, 2026, before determining what will be included in the final CY 2027 Physician Fee Schedule.

Understanding the proposals now can help healthcare practices evaluate their workflows, staffing models, technology partners, and remote monitoring programs before any potential changes take effect.

For a deeper look at the CY 2027 proposed rule and its potential impact on Remote Therapeutic Monitoring, our team recently hosted a webinar breaking down the key changes, reimbursement considerations, and what practices should be watching as CMS moves toward the final rule. Watch the discussion below for additional context before we break down the major RTM proposals in more detail.

What Is CMS Proposing for RTM in 2027?

CMS identified several areas of remote monitoring that it wants to change or further evaluate for CY 2027.

The proposals represent a meaningful shift toward making remote monitoring more closely integrated with the patient’s existing care team.

Who Do the 2027 Remote Monitoring Proposals Affect?

Because CMS is proposing changes to both RPM and RTM, the proposals reach across specialties rather than sitting with one discipline.

• Physician practices billing RPM, and physicians who order or supervise remote monitoring as part of a broader care plan.
• Physical therapy and occupational therapy practices billing RTM for musculoskeletal or respiratory monitoring.
• Any healthcare organization whose remote monitoring program relies on contracted clinical staff, third-party vendors, or enrollment workflows separate from the treating clinician.

The specific codes differ by discipline, but the underlying direction is consistent: CMS wants remote monitoring tied more closely to an established clinical relationship and to the practice’s own care team.

1. RTM Could Be Limited to Established Patients

One of the most significant proposed changes is an established-patient requirement for RTM.

CMS currently applies an established-patient requirement to Remote Physiologic Monitoring (RPM). For 2027, CMS is proposing to extend a similar requirement to RTM. CMS states that an established relationship gives the practitioner an opportunity to collect relevant medical history and conduct an appropriate physical examination before beginning remote monitoring.

What would the RTM established-patient requirement mean?

If finalized, a practitioner could not simply enroll an entirely new Medicare patient directly into an RTM program without first establishing the required clinical relationship.

For healthcare practices, this could reinforce an important distinction:

RTM would function as an extension of an existing plan of care rather than as a stand-alone service disconnected from the patient’s treating clinician.

Practices should therefore think about where RTM fits within the patient journey, including evaluation, plan-of-care development, home programming, monitoring, follow-up, and treatment progression.

2. CMS Is Proposing an Initiating Visit for RTM

CMS is also proposing that practitioners reporting RPM or RTM services furnish a separately reportable initiating visit in association with the start of remote monitoring services.

The proposed initiating visit could be furnished face-to-face either in person or through telehealth, according to analyses of the proposed rule.

Would every RTM patient need an initiating visit?

If this proposal is finalized as written, practices would need to incorporate an appropriate reportable initiating visit into the beginning of the patient’s remote monitoring workflow.

For physician, physical therapy, and occupational therapy practices alike, that makes workflow design especially important. Instead of treating enrollment as an administrative step, practices may need to make sure the start of monitoring is clearly connected to an appropriate clinical encounter.

That means practices should be able to answer:

• When is remote monitoring introduced to the patient?
• Who determines that remote monitoring is appropriate?
• When does monitoring officially begin?
• How is the initiating encounter documented?
• How does monitoring connect to the patient’s broader treatment plan?

Building these steps into a standardized workflow can help reduce confusion if the proposal ultimately becomes Medicare policy.

3. CMS Is Targeting Outsourced Clinical Monitoring

One of the most consequential proposals concerns who performs billable remote monitoring services.

CMS is proposing to allow Medicare payment for certain RPM and RTM services performed by clinical staff only when those clinical staff are employed by the billing practice rather than supplied through a contractor.

Does the 2027 proposed rule ban remote monitoring technology vendors?

No. The proposal does not state that healthcare practices cannot use third-party RTM or RPM software and technology platforms.

Instead, CMS is addressing situations in which contracted clinical staff perform services that are then billed as part of the practice’s remote monitoring program.

A practice could use technology to collect patient-reported information, organize monitoring data, support home exercise or treatment adherence, communicate with patients, or document monitoring activity while maintaining the clinical work within its own care team.

If CMS finalizes the proposal, the distinction between buying technology and outsourcing clinical work could become increasingly important.

4. RTM Reimbursement Could Be Revalued

CMS is also proposing updates to the valuation of remote monitoring services under the Physician Fee Schedule.

CMS specifically noted that remote monitoring devices may now be available at lower costs than were assumed when the services were originally valued. As a result, the agency is reevaluating portions of the payment methodology used for remote monitoring.

That does not mean every RTM code will automatically receive a specific reimbursement reduction. It does mean that practices should avoid building long-term remote monitoring financial models around the assumption that today’s Medicare payment amounts will remain unchanged indefinitely.

5. CMS Is Considering a Larger Restructuring of Remote Monitoring Codes

CMS is also seeking feedback on a potentially larger change to remote monitoring. The agency is considering whether the existing RPM and RTM CPT code structure could eventually be bundled into four new HCPCS G-codes describing remote monitoring setup and ongoing monitoring or management.

This portion of the proposal is particularly important to interpret correctly. CMS is seeking comments on the concept. The agency has not announced that the existing RTM CPT codes will disappear in 2027.

Current RTM codes therefore remain important, including the newer codes introduced for CY 2026. For example, CMS added CPT 98985 for musculoskeletal RTM device supply involving 2 to 15 days of data within a 30-day period and CPT 98979 for the first 10 minutes of RTM treatment management services during a calendar month, subject to applicable requirements.

Practices should continue following current Medicare requirements while monitoring what CMS ultimately finalizes for 2027.

What Is Changing for RTM Right Now?

Nothing in the CY 2027 proposed rule changes current RTM requirements today. The rule is still in the proposal and public-comment stage.

CMS released the proposed rule on July 14, 2026, published it on July 16, and will accept comments through September 14, 2026.

That means practices should not begin treating these proposals as finalized billing requirements. Instead, this period should be used to understand the direction CMS is considering and identify areas of the remote monitoring program that may need attention if the proposals are finalized.

How Healthcare Practices Can Take Action on the CY 2027 RTM Proposed Rule

Because the CY 2027 Physician Fee Schedule is still a proposed rule, practices have an opportunity not only to prepare for potential changes, but also to participate in the rulemaking process.

1. Submit Feedback to CMS Before September 14

CMS is accepting public comments on the CY 2027 Physician Fee Schedule Proposed Rule through September 14, 2026.

Healthcare organizations, clinicians, providers, suppliers, and other stakeholders can submit comments through Regulations.gov using the file code CMS-1848-P.

For practices currently using RTM, this is an opportunity to share real-world feedback about how the proposed requirements could affect patient access, clinical workflows, staffing, technology use, and the sustainability of remote monitoring programs.

When submitting comments, practices should focus on specific operational or clinical impacts and provide supporting examples or data when possible.

2. Review Your Current RTM Workflow

Map how RTM currently fits into the patient journey, from the initial evaluation through enrollment, monitoring, clinical interaction, documentation, and completion.

Pay particular attention to:

• When RTM is introduced
• How patient eligibility is determined
• Who initiates monitoring
• Who performs clinical monitoring activities
• How treatment-management time is documented
• How RTM connects back to the patient’s overall plan of care

This can help identify where the proposed established-patient and initiating-visit requirements could affect current workflows.

3. Evaluate Your Staffing Model

CMS is proposing to limit payment for certain RPM and RTM services performed by clinical staff to situations in which those staff members are employed by the billing practice rather than provided through a contractor.

Practices using third-party support should clarify exactly who performs the clinical components of their RTM program and how those individuals are connected to the billing organization.

This does not mean practices should stop using RTM technology vendors. Instead, organizations should understand the difference between using an external technology platform and outsourcing the clinical work associated with billable RTM services.

4. Review Your RTM Technology and Vendor Relationships

Ask your RTM partner how its model would align with the proposed 2027 requirements if they are finalized.

Key questions may include:

• Does the vendor provide technology only, clinical services, or both?
• Who communicates with patients?
• Who performs billable treatment-management activities?
• Who documents those interactions?
• Does the practice retain control of clinical decision-making?
• Would any part of the current workflow need to change under the proposed staffing requirements?

Practices should have a clear understanding of these responsibilities before the final rule is released.

5. Model the Potential Reimbursement Impact

CMS is also proposing changes to how remote monitoring services are valued under the Physician Fee Schedule.

Practice leaders should evaluate whether their RTM program remains operationally sustainable under different reimbursement scenarios rather than assuming current payment levels will remain unchanged.

Consider reviewing clinician time, staffing costs, technology costs, patient participation, documentation requirements, and reimbursement together.

6. Prepare, But Do Not Change Billing Practices Yet

The CY 2027 Physician Fee Schedule is still a proposed rule.

Practices should continue following current Medicare requirements unless and until CMS finalizes new policies.

The goal right now should be to understand the proposals, identify potential operational impacts, participate in the public-comment process where appropriate, and prepare for different possible outcomes.

The Most Important Next Step

For organizations that believe the proposed RTM changes could meaningfully affect patient care or their ability to deliver remote monitoring, the immediate opportunity is to make that perspective known.

After the comment period closes, practices should watch for the CY 2027 final rule to determine which proposals are ultimately adopted and what changes will be required for January 1, 2027.

Frequently Asked Questions About the 2027 RTM Proposed Changes

Who do the 2027 RTM changes affect?

The proposals would affect any healthcare practice billing Medicare for remote monitoring. Because CMS is proposing parallel changes to RPM and RTM, that includes physician practices as well as physical therapy and occupational therapy practices.

Is RTM changing in 2027?

CMS has proposed several changes to RTM for CY 2027, but they are not yet final. Proposed changes include an established-patient requirement, an initiating visit requirement, restrictions involving contracted clinical staff, and changes to how remote monitoring services are valued.

How can practices comment on the 2027 proposed rule?

Healthcare organizations, clinicians, providers, suppliers, and other stakeholders can submit comments through Regulations.gov using the file code CMS-1848-P. CMS is accepting comments through September 14, 2026.

Will RTM require an established patient in 2027?

CMS is proposing that RTM services be furnished only to established patients beginning in CY 2027. The requirement will not become Medicare policy unless it is finalized.

Will RTM require an initiating visit?

CMS is proposing that practitioners reporting RTM or RPM furnish a separately reportable initiating visit in association with the start of remote monitoring.

Can healthcare practices still use a remote monitoring vendor?

The proposed rule does not prohibit practices from using RTM or RPM technology vendors. CMS is proposing restrictions on Medicare payment when certain remote monitoring services are performed by contracted clinical staff rather than staff employed by the practice. Practices should distinguish between purchasing technology and outsourcing clinical services.

Are the RTM CPT codes going away?

Not at this time. CMS is seeking comments on whether the existing remote monitoring coding structure could eventually be replaced or consolidated using four HCPCS G-codes. This is a proposal under consideration, not a finalized coding change.

When would the proposed RTM changes take effect?

Policies finalized through the CY 2027 Physician Fee Schedule would generally take effect on or after January 1, 2027. The final policy may differ from what CMS has proposed.

When does the public comment period end?

CMS is accepting comments on the CY 2027 Physician Fee Schedule Proposed Rule through September 14, 2026.

The Bigger Picture for Remote Monitoring

The CY 2027 proposed rule signals that CMS continues to view remote monitoring as part of the Medicare care landscape while also looking for stronger safeguards around how these services are delivered, documented, staffed, and reimbursed.

For healthcare practices across specialties, that makes clinical integration increasingly important.

Remote monitoring should not sit outside the patient’s plan of care. The strongest programs connect between-visit monitoring with the clinician who understands the patient’s history, goals, response to treatment, and progression.

As CMS evaluates the next phase of remote monitoring policy, practices that have built these programs into their own clinical workflows will be better positioned to adapt.

See EverEx in action

If your team is mapping how remote monitoring fits inside the plan of care ahead of the final rule, the fastest way to judge fit is to see the workflow against your own patient scenarios. Request a demo, or try the RTM revenue calculator to estimate the impact on your practice.

This article is intended for educational purposes only and does not constitute legal, billing, or compliance advice. Medicare requirements and reimbursement policies may change. Practices should review current CMS guidance and consult qualified billing, compliance, or legal professionals when appropriate.