Medicare’s remote patient monitoring framework, which launched in 2019, was designed to reimburse providers for tracking patient health data between office visits using home devices.
In 2022, CMS expanded this framework by introducing remote therapeutic monitoring codes, covering patient-reported outcomes in respiratory, musculoskeletal, and cognitive behavioural therapy settings.
Both code families grew steadily through rulemaking and CPT panel revisions, driving rapid adoption fuelled in large part by third-party vendors supporting practices to deliver these services.
That growth has now drawn significant regulatory scrutiny, prompting CMS to propose sweeping changes in its CY 2027 Medicare Physician Fee Schedule Proposed Rule, published on July 16, 2026.
The proposals include prohibiting billing practitioners from relying on vendors to furnish monitoring services, requiring stronger evidence of a clinical relationship between practitioners and patients, and reducing reimbursement rates for several codes.
Two Office of Inspector General reports appear to have driven these proposals, with a 2024 report finding that approximately 43% of remote patient monitoring enrollees did not receive all three required service components.
The OIG also identified risks including insufficient staff to monitor enrollees and inadequate training on device use, painting a troubling picture of how these services were being delivered at scale.
A follow-up OIG report issued in 2025 found that some practices billed for patients with whom they had no established clinical relationship, billed for patients already enrolled with other practices, and billed for multiple monitoring devices per month per enrollee.
Beginning January 1, 2027, CMS would restrict reimbursement to services furnished by clinical staff who are “a direct employee of the practitioner or the practitioner’s practice,” effectively ending widespread outsourcing of monitoring functions.
CMS acknowledged that many practices had delegated most or all monitoring functions to outside vendors who supplied devices, managed patient outreach, reviewed data, and employed the clinical staff performing those services.
Providers would still be permitted to purchase software platforms and technical tools from external vendors, but all clinical monitoring work would need to be performed by direct employees of the billing practice.
CMS further proposes an established patient requirement and a mandatory initiating visit, conducted in person or via telehealth, before any remote monitoring services can begin under a given practitioner.
On payment rates, CMS proposes revising practice expense valuations for device supply and set-up codes, while eliminating practice expense inputs for treatment management codes, which would reduce reimbursement for commonly billed remote monitoring services.
CMS is also soliciting stakeholder comments on consolidating all seventeen existing RPM and RTM CPT codes into just four new HCPCS G-codes, though this consolidation has not been formally proposed.
Comments on the Proposed Rule are due September 14, 2026, and any changes adopted in the final rule would take effect January 1, 2027, leaving affected organisations with a compressed window to restructure their operations.