CMS has proposed that starting January 1, 2027, remote physiologic monitoring and remote therapeutic monitoring may only be billed when furnished by clinical staff directly employed by the billing practice. If your RPM or RTM program runs through a third party vendor, and the rule finalizes as written this fall, you will have roughly eight weeks between the final rule and the effective date to restructure. This checklist is the preparation work you can do now, while it is still cheap. It summarizes a proposed regulation as of August 2026 and is not legal or billing advice; verify against the final rule before acting.
1. Measure your exposure
- List every remote monitoring code you billed in the last 12 months (RPM: 99091, 99445, 99453, 99454, 99457, 99458, 99470, 99473, 99474; RTM: 98975, 98976, 98977, 98978, 98979, 98980, 98981, 98984, 98985, 98986) and the monthly revenue on each.
- Mark which of those claims involved vendor staff performing the monitoring or the patient contact. That revenue is what the proposal puts at risk.
- Pull your vendor contract: termination notice period, auto renewal date, early exit fees, and who owns the devices, the platform access, and the patient data if you separate.
2. Put four questions to your vendor, in writing
- If the employee staffing requirement finalizes, what is your model on January 1, 2027?
- Who employs the people who contact our patients today?
- Can we keep the software platform and devices while moving the staffing to our own employees, and what does that cost?
- How does patient data migrate if we leave?
A vendor with a real answer to the third question is a future software supplier. A vendor without one is a contract to exit.
3. Model the in house version
- Count enrolled patients by program and the monthly management minutes they actually generate.
- Size the staffing: model whether one care coordinator could carry the monitoring work across RPM and RTM plus CCM and PCM, which the proposal does not touch.
- Price platform licensing separately from staffing, since the proposal addresses who employs the clinical staff and does not on its face reach software or device licensing.
- Draft the hiring timeline backward from January 1: post the role when the final rule lands (final rules in this series have typically published in early November), hire by early December, train before the new year.
4. Fix the paperwork while it is quiet
- Confirm every monitored patient has documented consent on file.
- Check that each patient is an established patient of the billing practitioner; the proposal extends this requirement to RTM.
- Plan for initiating visits: the proposal requires a face to face visit, in person or telehealth, where monitoring is actually discussed, before services start.
- Make sure monthly time is logged as actual minutes with the interactive communication documented, whoever ends up doing the work.
5. Watch three dates
- September 14, 2026: the comment period closes. If the rule as written would harm your patients or your program, say so on regulations.gov, docket CMS-1848-P.
- Early November 2026: final rules in this series have typically published around then. Read the staffing provision as finalized before changing anything.
- January 1, 2027: the proposed effective date.
Get our analysis the day the final rule publishes
We will read the final rule the day it lands and email you what finalized, what changed from the proposal, and what to do about it. No newsletter, just that one analysis.
Background reading: what the 2027 proposal actually says, the RPM code set, the RTM code set, and the in house vs vendor revenue calculator.
Practice Management Consultancy runs this assessment with practices and builds the in house program on the other side of it, staffed by your own team. Start with a care management assessment.
