2026 expanded RTM. 2027 would restrict it.
Both are true at the same time, which is what makes this year confusing. In July, CMS proposed that remote monitoring be furnished only by clinical staff a practice employs directly — ending vendor-staffed RTM — alongside an initiating-visit requirement and a downward revaluation of the device codes. It is a proposal, not law. If you are choosing an RTM vendor right now, it is the thing to read first.
- Document
- CMS-1848-P
- Federal Register
- FR Doc 2026-14327
- Published
- 16 July 2026
- RTM discussion
- 91 FR 43892–43895
- Comments closed
- 14 September 2026
- Status
- Proposed — not final
- 01
Monitoring would have to be done by your own staff
“To count the time spent by clinical staff providing aspects of RPM or RTM services, the clinical staff must be a direct employee of the practitioner or the practitioner's practice.”
Today a vendor can staff your RTM programme: their people watch the data, place the monthly call, and your practice bills for it. CMS is proposing to end that — the rule states it would not allow contracting out to third-party companies.
Two carve-outs are widely misread. Staff need not be in your building: CMS says the requirement does not mean clinical staff must necessarily always be physically located within the practice, so remote employees qualify. And buying software or devices from a vendor stays permitted. What ends is vendor staff performing the service.
- 02
An initiating visit would be required
“RPM or RTM services must be initiated by the billing practitioner during a face-to-face (in-person or telehealth) visit.”
The patient would have to be established with your practice, and RTM would have to be discussed at a billable face-to-face visit before monitoring starts.
CMS is explicit that the conversation has to actually happen: if RPM or RTM is not discussed with the patient at that visit, that visit cannot count as the initiating visit. The initiating visit can itself be billed separately.
- 03
Device-supply codes would be revalued downward
“we are concerned that, due to lack of information regarding the typical device used to perform these procedures, these services are overvalued.”
CMS proposes crosswalking the practice-expense inputs for the device-supply codes to 93270, and eliminating practice-expense inputs entirely for the treatment-management codes while keeping their work RVUs.
CMS proposed no dollar figures. Any specific 2027 rate circulating now is a projection, not a CMS number. CMS is soliciting device invoices and pricing evidence.
What this means if you are choosing a vendor now
A multi-year contract that depends on the vendor’s staff doing your monitoring is the arrangement CMS has proposed to disallow. A contract for software and devices, with your own clinical staff doing the monitoring, is the arrangement CMS explicitly preserves. That distinction is worth checking before signing anything that runs past this year.
We should be plain about our own interest: SCRENR sells software, not monitoring staff, so the proposed rule favours how we are built. That is a reason to check the source rather than take our word for it — the citation is above.
Why CMS says it is doing this
The rule cites two HHS Office of Inspector General reports. The 2024 report OEI-02-23-00260found that “about 43 percent of enrollees who received remote patient monitoring did not receive all 3 components of it.” The 2025 data snapshot OEI-02-23-00261 reported remote monitoring payments of $536M in 2024, up 31% in a year, and flagged outliers — 45 practices had no prior relationship with more than 80% of the patients they billed for.
Neither report reviewed medical records, estimated improper payments, or identified confirmed fraud. They are screening measures for finding outliers, and are worth reading as such.
This page is written for planning, not as billing or legal advice. The proposed rule may be finalized as written, modified, or not finalized at all. Code selection and claim submission remain with your clinic and your biller. For what is billable today, see the 2026 code changes.
Find out what hybrid care would mean for your clinic.
Twenty minutes. We look at your caseload and payer mix, where hybrid care would free up therapist time, whether remote therapeutic monitoring (RTM) is worth billing, and how your current adherence data would hold up if someone asked you to defend it. If the numbers do not work for your practice, we will tell you that on the call.
On the call we cover
- Whether your patient mix clears the monitoring thresholds
- What your current adherence record would survive
- Conservative revenue math against your own numbers
- What a scoped pilot would involve