Policy, translated into operations.

October 2026 · Proposed rule

What the proposed 2027 RPM rule would change

These changes are proposed, not final.

Medicare's proposed CY 2027 Physician Fee Schedule rule would pay for RPM and RTM only when the clinical staff furnishing them are employed by the billing practice, not contracted. It would also require a separately reportable initiating visit associated with starting RPM or RTM.

• Employed clinical staff. Under the proposed rule, the clinical staff furnishing RPM and RTM would need to be employed by the billing practice, not contracted. I would review the service model and staffing together.
• A separately reportable initiating visit. The proposed rule would require a visit associated with starting RPM or RTM. I would define how it is scheduled, conducted and documented.
• Established patients for RTM. The proposed rule would limit RTM to established patients.
• Proposed valuation updates. CMS proposes valuation updates reflecting lower estimated device costs, so review the effect on your program's margins.
• A question for comment. CMS is asking for comment on bundling the RPM and RTM codes into four new HCPCS G-codes. This is a question for comment, not a finalized change.

I review the staffing model, initiating visit workflow and margins as connected parts of the operation.

Source: CMS fact sheet: proposed CY 2027 Medicare Physician Fee Schedule rule.