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Webinar

RTM Education

CY 2027 Physician Fee Schedule Proposed Rule: What It Means for RTM

Understand what CMS is proposing for Remote Therapeutic Monitoring in CY 2027, how the potential changes could affect reimbursement and clinical workflows, and what practices can do now to make their voices heard.

About this webinar

CMS’ CY 2027 Medicare Physician Fee Schedule Proposed Rule introduces several potential changes that could reshape how Remote Therapeutic Monitoring is delivered, staffed, and reimbursed. While these policies are not yet final, understanding what CMS is proposing is important for practices using RTM today or considering it as part of their care model.

In this webinar, Natesh Sood of EverEx and CJ Morrow, PT, DPT, Founder & Managing Director of CJM Strategic Consulting, break down the proposed rule and its implications for physical therapy, occupational therapy, and remote monitoring. The discussion separates the major RTM proposals, examines potential reimbursement and workflow impacts, and outlines how clinicians can provide meaningful feedback to CMS before the September 14, 2026 comment deadline.

In this session, we cover:

If your practice currently uses RTM or is evaluating how remote monitoring fits into its care model, this webinar provides a practical breakdown of what is being proposed, what remains unresolved, and how to prepare while the rule is still under consideration.

Key Questions About the CY 2027 RTM Proposal

Short answers to the questions practices are asking most about Remote Therapeutic Monitoring under the CY 2027 Medicare Physician Fee Schedule Proposed Rule. Everything below describes what the Centers for Medicare & Medicaid Services (CMS) has proposed — none of it is final policy.

What is CMS proposing for RTM in 2027?

CMS is proposing several changes to Remote Therapeutic Monitoring, including requirements related to established patients, initiating visits, clinical staffing, and reimbursement valuation. CMS is also seeking feedback on potentially consolidating existing remote monitoring codes into four bundled G-codes.

Will an initiating visit be required for RTM?

Under the proposed rule, practitioners reporting RTM or Remote Physiologic Monitoring (RPM) services would need to furnish a separately reportable face-to-face initiating visit, either in person or through telehealth, in association with the start of remote monitoring. This remains a proposal and is not yet final.

Would RTM be limited to established patients?

CMS is proposing that RTM services be furnished to established patients. The webinar also discusses an unresolved sequencing question around how the initiating-visit and established-patient requirements would interact.

How could the proposal affect outsourced RTM monitoring?

CMS is proposing that clinical staff furnishing remote monitoring services be direct employees of the billing practice. If finalized as written, this could have significant implications for practices using outsourced or contracted monitoring models.

What could happen to RTM reimbursement?

CMS is proposing changes to the valuation of certain remote monitoring device and data transmission codes, including CPT 98977 and CPT 98985. Because these policies remain proposed, practices should evaluate potential implications while continuing to follow current Medicare Part B requirements.

How can clinicians respond to the proposed rule?

Clinicians and other stakeholders can submit comments to CMS before the September 14, 2026 deadline. The webinar recommends focusing on real clinical experiences, patient access, continuity of care, workflow impacts, and relevant practice data rather than feeling obligated to produce a lengthy legal analysis.

The policies described on this page are contained in the Centers for Medicare & Medicaid Services (CMS) CY 2027 Medicare Physician Fee Schedule Proposed Rule and are not final CMS policy. This page is educational and is not legal, compliance, or billing advice. Practices should continue to follow current Medicare Part B requirements unless and until CMS issues a final rule.

Speakers

CJ Morrow, PT, DPT, Founder and Managing Director of CJM Strategic Consulting, LLC

CJ Morrow, PT, DPT

Founder & Managing Director

CJM Strategic Consulting, LLC

CJ is the Founder and Managing Director of CJM Strategic Consulting, LLC and serves as a quality and governance consultant for EverEx. Her work focuses on regulatory and governance considerations for healthcare technology and services, helping healthcare organizations understand evolving policy and translate complex regulatory developments into practical considerations.

CJ Morrow on LinkedIn
Natesh Sood, Head of Business Operations at EverEx

Natesh Sood

Head of Business Operations

EverEx

Natesh leads Business Operations at EverEx, working closely with practices as they integrate Remote Therapeutic Monitoring into their care delivery models. His work focuses on the operational side of RTM implementation and helping practices navigate evolving reimbursement, workflow, and regulatory considerations.

Natesh Sood on LinkedIn

Resources Mentioned in This Webinar

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