RPM Logix’s Comment Letter to CMS on the 2027 RPM Rule

Illustration of a calendar marked September 14 2026 with an overlapping clock showing the CMS public comment deadline for the proposed 2027 RPM and RTM staffing rule.
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    Key Takeaways

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    CMS’s proposed CY 2027 rule would bar contracted clinical staff from billing RPM and RTM. RPM Logix has formally asked CMS to reconsider.

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    CMS already tried restrictive RPM supervision rules in 2019, and reversed them in 2020 after utilization collapsed. This proposal risks the same outcome.

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    ~98% of patients in RPM Logix’s program have never previously worked with a credentialed diabetes educator or dietitian. The employment rule would cut off that access for most of them.

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    Small and independent practices, who can’t afford to hire in-house RPM clinical staff, would be hit hardest, accelerating consolidation.

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    The comment period is open now and closes September 14, 2026. Your comment matters, even a short one.

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    Read our full letter to CMS, then submit your own comment at regulations.gov before the deadline.

    On July 14, 2026, CMS released its Calendar Year 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P), and buried inside it is a provision that would reshape how Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) programs are staffed nationwide.

    If finalized as written, the rule would only allow Medicare to pay for RPM/RTM services when they’re performed by clinical staff who are direct employees of the billing practice — effectively ending the use of outsourced, contracted clinical teams like ours.

    We think this is the wrong fix for a legitimate problem. We’ve submitted a formal public comment to CMS explaining why. You can read the full letter here [PDF].

    For a full breakdown of what the rule proposes, read our full breakdown of the proposed rule.

    What CMS Is Proposing for RPM/RTM Staffing in 2027

    In response to Office of Inspector General findings on program integrity in remote monitoring, CMS’s proposed rule would, starting January 1, 2027:

    • Limit RTM services to established patients only
    • Require a separately billable, face-to-face initiating visit before RPM/RTM begins
    • Allow RPM/RTM payment only when clinical staff are direct employees of the billing practice — not contractors
    • Revalue RPM/RTM codes downward, and solicit comment on bundling existing CPT codes into new HCPCS G-codes

    The comment period is open now and closes September 14, 2026. Provisions are regularly modified or dropped in response to public comments — this is not final policy.

    Why We’re Asking CMS to Reconsider

    1. CMS already learned this lesson once.

    When RPM payment was first established in 2019, it required direct supervision — and utilization was extremely low. CMS itself recognized the problem and moved to general supervision starting January 1, 2020, which is what allowed the program to actually grow. The proposed employment requirement risks repeating that same mistake, just through a different mechanism.

    2. Thousands of patients would lose access to specialists they’ve never had before.

    Our clinical team includes registered nurses, Certified Diabetes Care and Education Specialists, and registered dietitians. Based on our own program data, roughly 98% of the patients we monitor have never previously had the chance to work one-on-one with a credentialed diabetes educator or dietitian as part of their regular care. For many, our monthly check-ins are the only place a specialist reviews their glucose trends or talks through nutrition and medication adherence in real depth. Small practices don’t have RDs or CDEs on staff and have no realistic path to hiring them just to keep a monitoring program alive.

    3. Employment status isn’t a proxy for clinical quality.

    The billing practitioner’s supervisory and documentation responsibilities don’t change based on whether staff are employed or contracted. Dedicated outsourced clinical teams often bring more standardized training and specialized credentials than a general practice could staff internally. The oversight concerns CMS has raised are better addressed by the initiating-visit and established-patient requirements already in this same rule — not by eliminating the contracted staffing model outright.

    4. Small and rural practices will be hit hardest.

    Independent practices make up the majority of who we serve, and they rely on outsourced staffing because hiring dedicated in-house RPM/RTM clinical staff isn’t economically feasible at their patient volumes — compounded by a nationwide shortage of RNs and credentialed specialists. Larger health systems can absorb this mandate. Many independent practices simply can’t, which risks further consolidation and less access to care in smaller communities.

    How You Can Submit Your Own Comment Before September 14, 2026

    This is a proposed rule, not final policy — and CMS is required to consider public comments before finalizing it. If your practice runs an RPM or RTM program, your voice matters here, especially if you can speak to your own patient outcomes or operational impact.

    How to submit a comment:

    1. Go to regulations.gov
    2. Reference docket CMS-1848-P / CMS-2026-2377
    3. Submit before 5:00 PM ET on September 14, 2026

    You don’t need a long letter — even a short comment describing how this rule would affect your patients and practice carries weight.

    The comment deadline is September 14, 2026.

    Submit your comment directly on regulations.gov and reference docket CMS-1848-P. Every comment submitted — including short ones from individual practices — is part of the official public record CMS must consider before finalizing the rule.

    Submit a Comment to CMS →

    This post reflects RPM Logix’s public comment submitted to CMS on July 21, 2026, on the CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P). The provisions discussed are proposed, not final, and remain subject to change.

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    Disclaimer

    • The information provided by RPM Logix is intended for educational purposes only and should not be construed as legal or medical billing advice. While every effort is made to ensure the accuracy and timeliness of the content, RPM Logix makes no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability, or availability of the information provided. The coding and billing guidelines, including but not limited to CPT, HCPCS, and ICD codes, are subject to updates and changes by regulatory authorities such as CMS (Centers for Medicare & Medicaid Services) and the AMA (American Medical Association).
    • RPM Logix is not responsible for any errors, omissions, or outcomes resulting from the use of this information. It is the responsibility of the healthcare provider to verify the accuracy of coding and billing information, to remain informed about updates, and to comply with all relevant payer guidelines and regulations. RPM Logix strongly recommends consulting legal counsel, reimbursement specialists, or the appropriate authoritative resources before submitting any claims.
    • By using the information provided by RPM Logix, you acknowledge and agree that RPM Logix shall not be held liable for any claims, damages, or other liabilities arising from your use of the information, including but not limited to any billing, coding, or reimbursement issues that may result from reliance on the material presented.