Remote monitoring is entering a significant policy transition as the Centers for Medicare & Medicaid Services (CMS) considers new payment, staffing, and billing requirements for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services. The proposed changes are included in the 2027 Medicare Physician Fee Schedule and would apply beginning January 1, 2027 if finalized.
For California physicians, the proposal is important because remote monitoring has become part of how practices manage patients outside traditional office visits. RPM can allow clinicians to receive electronically transmitted physiologic information, while RTM focuses on treatment-related data and therapeutic management. CMS currently recognizes separate payment structures for these services, but the agency is proposing changes to how they are furnished and valued.
CMS Proposes New Remote Monitoring Requirements
One of the most significant elements of the proposal would change the conditions under which remote monitoring services can be furnished. CMS proposes requiring RTM services to be provided only to established patients. The proposal would also require practitioners billing RPM or RTM services to furnish a separately reportable initiating visit associated with the beginning of remote monitoring services.
CMS is also proposing to limit payment for remote monitoring when the services are performed by clinical staff employed by the practice. Under the proposal, services furnished by contractors would not qualify for payment. This could have operational consequences for physician practices that currently rely on outside vendors, contracted personnel, or third-party arrangements to support their monitoring programs.
These provisions remain proposals rather than final Medicare requirements. However, practices using RPM or RTM should understand the potential implications because changes to staffing arrangements, patient onboarding, and billing workflows may require advance planning if the provisions are finalized.
Payment Valuation Could Also Change
CMS is also proposing to revise how remote monitoring services are valued under the Physician Fee Schedule. The agency said it believes certain devices used for these services may now be available at lower costs than when the existing payment values were initially developed. That assessment has prompted CMS to propose updates to the practice-expense assumptions used in valuing RPM and RTM services.
For physician practices, changes to practice-expense assumptions can affect the payment associated with individual services. The potential effect on a practice will depend on its volume of monitoring services, patient population, staffing model, technology costs, and other operational factors.
The proposed valuation changes make remote monitoring relevant not only as a clinical technology issue but also as a reimbursement planning issue. Practices that have invested in connected devices, software platforms, monitoring personnel, or clinical workflows may need to reassess the financial assumptions behind those programs.
CMS Considers Broader Coding Changes
CMS has also raised a broader question concerning the structure of remote monitoring codes. The agency is seeking comments on potentially bundling existing RPM and RTM CPT codes and establishing four new HCPCS G-codes for remote monitoring services. CMS said this approach could address recommendations identified in recent Office of Inspector General reports that the agency believes cannot be fully resolved under the current coding structure.
If such a restructuring eventually occurs, physician practices could face additional coding and billing changes. Existing workflows built around individual CPT codes may need to be modified, and billing teams could need new guidance for determining when and how services qualify for payment.
This possibility also demonstrates why remote monitoring should not be viewed as a static reimbursement category. CMS has continued to refine the payment framework as utilization, technology, and program experience develop.
California Practices Should Review Their Workflows
The proposed remote monitoring policies could require California physician practices to examine how patients are enrolled and how monitoring services are initiated. Practices may need to confirm whether their clinical documentation establishes the appropriate patient relationship and whether an initiating visit is separately documented and billed when required.
Staffing arrangements could require particular attention. A practice that uses employees to perform monitoring-related clinical work may need to evaluate those responsibilities differently from a practice that contracts with an outside organization. If the proposed contractor limitation is finalized, organizations may need to modify existing arrangements before the 2027 payment year.
Technology vendors may also be affected indirectly. Although the proposed rule is directed at Medicare payment policy rather than technology companies themselves, changes in billing requirements can lead practices to reassess whether their electronic health record systems, monitoring platforms, claims processes, and documentation tools can support the new framework.
Remote Monitoring Remains Part of Medicare’s Virtual Care Strategy
CMS continues to recognize remote monitoring as a Medicare-covered approach for collecting and using patient health information outside traditional encounters. Its current RPM guidance describes monitoring as involving the collection of physiologic data through connected medical devices, followed by clinical review and management of the patient’s condition.
The 2027 proposal therefore does not eliminate remote monitoring. Instead, CMS is considering changes to the conditions under which these services are paid and how their costs are represented in the Physician Fee Schedule.
That distinction matters for physicians considering virtual-care investments. Remote monitoring can remain clinically useful while the reimbursement framework changes around it. Practices should therefore evaluate clinical value and payment policy separately rather than assuming that a reimbursement change necessarily determines whether the underlying technology remains appropriate for patient care.
Preparing for Potential 2027 Changes
California physicians should continue tracking the final CMS rule before making permanent changes to their remote monitoring programs. The proposed rule’s comment period closed September 14, 2026, and CMS will use the rulemaking process to consider submitted comments before issuing the final 2027 Physician Fee Schedule.
In the meantime, practices can review the number of patients receiving RPM or RTM, the codes currently being billed, the personnel involved in monitoring, the technology used to collect data, and the documentation supporting each service. Reviewing these elements can help practices identify areas that could require modification if CMS adopts the proposed requirements.
The potential changes also reinforce the importance of coordination between physicians, clinical staff, billing professionals, and technology vendors. Remote monitoring programs depend on multiple operational components, and a change in one part of the reimbursement framework can affect the entire workflow.
For California physician groups, the 2027 proposal represents another development in the continuing evolution of Medicare payment for technology-enabled care. The final rules will determine whether the proposed patient, staffing, valuation, and coding provisions take effect, but practices have an opportunity now to understand where their current remote monitoring arrangements could intersect with the proposed framework.
Official Source: For the complete proposed requirements and CMS documentation concerning RPM and RTM services, visit the CMS Calendar Year 2027 Medicare Physician Fee Schedule Proposed Rule.
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