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

On July 16, 2026, CMS published the CY2027 Physician Fee Schedule proposed rule. Comments closed on September 14, 2026, and a final rule is expected around November, with provisions effective January 1, 2027.

Everything below describes a proposal. Proposed rules change, sometimes substantially, between publication and finalization. We are writing about it now because the practices most affected need lead time, not because the outcome is settled.

The provision that matters most

CMS proposed that clinical staff furnishing remote patient monitoring and remote therapeutic monitoring treatment management must be employees of the billing practice. The "incident to" framework is retained, and the staff may work remotely — but contracting the function out to a third-party monitoring company would no longer support billing.

The plain reading: if a monitoring vendor's nurses are the people spending the clinical minutes, those minutes stop being billable through your practice.

The proposal does not restrict vendors from selling software, devices, or technical services. It restricts who may furnish the clinical work.

Why CMS is proposing this

The context is not subtle. In September 2024, HHS-OIG published a review of Medicare remote patient monitoring (OEI-02-23-00260) finding that 43% of enrollees did not receive all three components being billed for them, and that Medicare frequently could not identify the ordering provider at all. OIG recommended that Medicare identify and monitor remote-monitoring companies as entities in their own right. That recommendation is still open.

Enrollment in RPM went from roughly 55,000 beneficiaries in 2019 to roughly 570,000 in 2022. Growth curves like that attract program-integrity attention, and the vendor-staffing model is the structure that made the growth possible.

Who this hits, and who it does not

Directly affected: practices whose remote monitoring is staffed by a vendor's clinical personnel billing through the practice. Under the proposal, the arrangement has to change or the revenue stops. This is a large share of the small-practice RPM market.

Not affected: software and device vendors. Selling technology to a practice whose own staff furnishes the care remains fine. (We should disclose the obvious: this is the side of the line we are on, and we employ zero clinical staff. Read the rest accordingly.)

Explicitly spared: APCM and Chronic Care Management. As proposed, contracted staff under general supervision remain permitted for those programs. This is a meaningful distinction and one worth confirming against the final rule, because a request for information in the same document signalled that CMS is thinking about the same restriction for CCM in future years.

The payment cuts nobody is talking about

The staffing provision has taken the oxygen, but the proposal also contains material payment reductions for RPM.

Device-supply codes would be crosswalked toward a substantially lower valuation — the direction of travel would remove a large fraction of device revenue. Treatment-management codes would lose practice-expense inputs. Taken together, a monitored patient who supports roughly $170 a month at the current ceiling could support something closer to $70–110 under the proposal.

If you are building a financial model that depends on RPM device revenue at today's rates persisting through 2027, that model has a hole in it. We plan conservatively against the lower band internally, and we would rather tell practices that before a contract than after.

There is also a request for information about consolidating the current set of monitoring codes into bundled G-codes. That is the least likely piece to arrive as described, but it is a signal about where the category is headed.

What else is in the document

• Conversion factor reductions for both the non-APM and APM tracks, in the range of one to two percent.
• G2211 becomes a modifier valued at a percentage of the base E/M service, with a materially higher percentage for practices participating in Shared Savings or LEAD ACO models.
• The established-patient requirement extends to RTM, matching RPM.
• An initiating-visit requirement framed around a face-to-face visit where monitoring was actually discussed — aimed squarely at enrollment driven by marketing rather than by clinical decision.
• A request for information on AI delivering annual wellness visits, which is not operationally relevant this year but is a striking thing to see in a fee schedule.

What a practice should actually do

If you use a vendor whose nurses do your monitoring: find out now, in writing, what their plan is. Some will move to a software-only model. Some will not have an answer. Either way you want to know before December.

If you are considering starting RPM: build the program around your own staff from the beginning. The staffing model is the part that is expensive to change later.

If you are considering starting APCM: the proposal leaves it alone, and CMS has expanded the program every year since 2025. Practices that stand it up this year bill it through the transition rather than after it.

Regardless: do not treat a proposed rule as final, and do not let a vendor tell you it is settled in order to close you. Read the final rule in November. If your compliance counsel has an opinion, that opinion outranks anything on this page.

Our position, stated plainly

We think the proposal is directionally correct, and we would say that even if it hurt us. The vendor-nurse model made it possible to bill for monitoring that nobody was really doing, and the OIG numbers are the evidence. Requiring that the clinical work be furnished by the practice's own supervised staff makes the accountability match the claim.

It also happens to be how we were built, which means we have an obvious interest in the outcome. Weigh this post accordingly, and go read what the compliance posture actually looks like rather than taking our word for it.

Sources: CMS-1848-P (CY2027 Medicare Physician Fee Schedule proposed rule, published July 16, 2026); HHS-OIG, Additional Oversight of Remote Patient Monitoring in Medicare Is Needed, OEI-02-23-00260, September 2024.