In the CY 2027 Medicare Physician Fee Schedule proposed rule, CMS proposed a change that would end outsourced staffing for remote monitoring. If finalized, remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) could only be billed when the work is performed by clinical staff directly employed by the billing practice, starting January 1, 2027. This is a proposal, not a final rule. Here is what the text actually says, who it touches, and the dates that matter.
What CMS proposed
“We are proposing to only allow payment for RPM or RTM services when furnished by clinical staff employed by the practice. To count the time spent by clinical staff providing aspects of RPM or RTM services, the clinical staff must be a direct employee of the practitioner or the practitioner’s practice.”
CY 2027 Physician Fee Schedule proposed rule, 91 FR 43842 (July 16, 2026), docket CMS-1848-P
The rule text continues: if finalized, 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 will not allow contracting out to third-party companies.”
The proposed requirement would sit on top of the existing incident to rules rather than replacing them. General supervision would still apply, and CMS says the staff would not need to be physically located at the practice. Under the proposal, remote employees would still count. Contractors would not, regardless of how closely they are supervised. Today, contractor staffing remains permitted; that is exactly what the proposal would change.
Which codes are covered
The proposal applies to the RPM code set (CPT 99091, 99445, 99453, 99454, 99457, 99458, 99470, 99473, and 99474) and the RTM code set (CPT 98975, 98976, 98977, 98978, 98979, 98980, 98981, 98984, and 98985).
What is not covered
Chronic care management (CCM), principal care management (PCM), behavioral health integration (BHI), and advanced primary care management (APCM) are not part of this staffing proposal. We read the rule text directly: no mention of CCM or PCM in the document imposes a staffing or employment condition. Outsourced CCM remains permitted under the current incident to rules. If you see a headline saying Medicare banned outsourced chronic care management, it is describing this rule incorrectly.
Two more proposed requirements in the same section
First, an initiating visit. Practitioners reporting RPM or RTM would need to furnish a separately billable face to face visit, in person or by telehealth, at the onset of services, and use it to assess clinical appropriateness and obtain the patient’s consent. A visit where remote monitoring was never discussed would not count.
Second, established patients only. The CY 2021 rulemaking restored the established patient limit for RPM once the COVID-19 public health emergency ended. For CY 2027, CMS proposes extending the same limit to RTM, reasoning that a practitioner with an established relationship has the history and exam context to order monitoring appropriately.
The timeline
The proposed rule published July 16, 2026. Comments close September 14, 2026, on regulations.gov under docket CMS-1848-P. Final rules in this series have typically arrived around early November, and CMS proposes an effective date of January 1, 2027. Whether the staffing provision survives as written is genuinely open. A coalition of remote monitoring vendors has organized to ask CMS to withdraw it, and CMS is explicitly seeking comment on how often third party billing occurs and how the policy would affect access.
Why CMS says it is doing this
The rule cites the HHS Office of Inspector General’s September 2024 report on remote patient monitoring, which flagged companies cold calling beneficiaries to solicit monitoring they may not need, enrollees who did not receive every billed component of the service, and the fact that Medicare claims do not capture who ordered the monitoring. CMS adds its own concern about the transparency of services billed incident to a practitioner. Its stated goal is oversight and continuity: services billed under a practitioner should be delivered by people that practitioner genuinely supervises and works with.
What to do now if you use a monitoring vendor
Inventory which codes currently flow through your vendor and how much revenue rides on them. Ask the vendor directly how their model works if a direct employment requirement takes effect. Model what in house staffing would look like; the same care coordinator can often support CCM and PCM as well, which are unaffected by this proposal. If the rule as written would harm your patients or your program, tell CMS in a comment before September 14. Then watch for the final rule this fall and read the staffing provision as finalized before changing anything. Our 2027 transition checklist turns this into a working document.
This article summarizes a proposed regulation as of August 2026 and is not legal or billing advice. Verify against the final rule text before acting.
Practice Management Consultancy helps practices design and implement in house care management programs. The model comes from the program we implemented and support at our own medical clinic, where the clinic’s own staff runs it. If you want a second set of eyes on your exposure before the final rule lands, start with a care management assessment.
