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Field notes

What we learned reading the rules so you don't have to.

We spend an unreasonable amount of time inside fee schedules, proposed rules, and OIG reports. These are the parts that change what a small practice should actually do — written plainly, with the citations attached.

CMS rulemakingBilling rulesAudit risk
A thick stack of printed government pages with reading glasses resting on top
CMS rulemakingJuly 21, 2026 · 5 min read

CY2027's remote monitoring staffing rule: what CMS actually proposed

The CY2027 Physician Fee Schedule proposed rule would require that RPM treatment management be furnished by staff the billing practice itself employs. Here is what the proposal says, who it affects, what it leaves alone, and what remains uncertain until the final rule.

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A printed fee schedule and calculator on a clinic desk in warm low light
Billing rulesJune 11, 2026 · 6 min read

What APCM actually pays in 2026, and who qualifies for each level

Advanced Primary Care Management has three levels, no minute thresholds, and one hard consent requirement. Here are the published national rates, the eligibility criteria for each tier, and the tier most practices forget to check for.

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A paper wall calendar on a kitchen counter with a blood pressure cuff resting across one corner
Billing rulesMay 19, 2026 · 4 min read

The 16-day rule, and the new code for the months you miss it

RPM device supply is paid on distinct transmission days, and fifteen days is not ninety-four percent of sixteen — it is a different code. What counts as a transmission day, what does not, and how the 2–15 day tier changes the arithmetic.

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A thick closed folder of documents on a plain desk under a hard shaft of late window light
Audit riskMarch 17, 2026 · 4 min read

OIG found 43% of RPM enrollees didn't get what was billed. Read it before you scale.

The September 2024 HHS-OIG review of Medicare remote patient monitoring is the single most important document for any practice billing this program. What it found, what it recommended, why the recommendation still being open matters, and what a defensible month looks like.

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Two nearly identical stacks of printed paper side by side on a desk with a pen laid between them
Billing rulesFebruary 24, 2026 · 4 min read

APCM or CCM: how to choose, patient by patient

They are mutually exclusive in the same month for the same patient, and the right answer differs across your panel. A framework for deciding, and the reason most small practices should start with APCM even when CCM pays more on paper.

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Two pairs of hands at a clinic counter across a single sheet of paper, one offering a pen
Audit riskJanuary 27, 2026 · 5 min read

Consent for APCM and RPM: the requirements, and the four ways practices fail them

Consent is the cheapest compliance artifact to get right and one of the most common to get wrong. What must be disclosed, why an inherited CCM consent doesn't work, and the sequencing that determines whether your program survives month two.

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Reading is fine. Numbers are better.

If any of this is relevant to your practice, the fastest way to find out what it is worth is thirty minutes against your own panel.

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