2027 Medicare Physician Fee Schedule Final Rule: What Changes for RTM and RPM?

CMS has finalized the 2027 Medicare Physician Fee Schedule, with changes to patient enrollment, clinical staffing and reimbursement for Remote Therapeutic Monitoring (RTM) and Remote Patient Monitoring (RPM). We covered the proposed changes in our earlier article. Here is what changed in the final rule and what it means for your clinic.

Discuss RTM or RPM with new patients during an existing qualifying appointment

From January 1, 2027, a clinic cannot bill RTM or RPM for a new patient until the billing practitioner has had an initiating visit with them: a face-to-face visit, in person or by telehealth, where remote monitoring is discussed. The visit must be separately reportable under Medicare.

RTM also now carries the established-patient requirement RPM already had. An established patient has received professional services from the billing practitioner, or from a same-specialty colleague in the same group, within the past three years. For physical, occupational and speech therapists, a patient under an active plan of care counts. A genuinely new patient becomes established once the initiating visit requirement is met, so one qualifying visit is enough to start.

Monitoring can be discussed during an existing qualifying visit

• The initiating visit does not have to be a separate appointment: RTM or RPM can be discussed during an existing qualifying appointment. The visit must be face-to-face, in person or through permitted telehealth, with the billing practitioner. A regular follow-up or annual wellness visit can qualify when the other requirements are met.

• Telehealth counts through December 31, 2027. After that, telehealth initiating visits follow the statutory telehealth limits in effect at the time, unless Congress extends the current flexibilities.

• One visit per patient. No new initiating visit is needed for a device change, a clinical change, or a different billing practitioner within the same practice.

• Patients already receiving monitoring before January 1, 2027 do not need an initiating visit to continue, as long as all other requirements are met.

• Use a visit code that Medicare pays separately. CMS says the visit does not have to produce a separate payment in every situation. If a visit is already included in a surgery's payment, ask your billing team to confirm whether it qualifies before using it to start RTM or RPM.

• No carve-outs. CMS declined to create exemptions from the initiating-visit requirement, including for patients aligned with Accountable Care Organizations.

• CMS set no deadline between the visit and device activation, and added no documentation requirements beyond those that apply to every Physician Fee Schedule service.

One caution from the rule text: CMS said it "discourages any misuse of enrolling beneficiaries in remote monitoring services between the publication of this rule and January 1, 2027." Clinics should enroll patients because monitoring fits their care, not to beat the deadline.

Medicare is changing RTM and RPM payments in 2027

The tables compare 2026 and 2027 Medicare payments for RTM and RPM, from setup and device supply to monthly treatment management. They show national non-facility estimates.

Medicare rates for RTM in 2027

Medicare rates for RPM in 2027

The 2027 estimates use CMS's final-rule Addendum B. Local payments can vary.

CMS lowered setup and device-supply payments

Medicare will pay less for setting patients up and supplying monitoring devices in 2027. Clinics should use the new rates in the tables when budgeting for RTM and RPM programs.

CMS did not adopt the proposed treatment-management cuts

CMS had proposed cuts to payments for the staff time spent reviewing monitoring data and managing patient care. It did not adopt those cuts. In 2027, RTM treatment-management rates rise slightly, while RPM rates show small increases or decreases depending on the service.

Medicare now sets national rates for CBT device supply

Medicare has set national device-supply rates for cognitive behavioral therapy (CBT) monitoring for the first time. Previously, local Medicare contractors set these rates. Both CBT device-supply options pay $40.79 nationally in 2027, giving clinics a clearer starting point for budgeting.

RTM and RPM clinical staff must be directly employed from January 1, 2029

The direct-employment requirement for RTM and RPM clinical staff starts January 1, 2029, not 2027. CMS finalized the policy but delayed implementation by two years. The requirement concerns clinical staff who furnish remote monitoring services: they must be direct employees of the billing practitioner or practice. CMS wants monitoring integrated with the treating practice rather than delivered as a largely outsourced service.

Until then, contracting out remains allowed. CMS said it "will continue to allow contracting out to third-party companies until December 31, 2028," provided all existing incident-to and other billing rules are met, and it cautioned that the billing practitioner must retain a real level of involvement in the services. Before 2029, CMS will publish guidance clarifying which clinical staff arrangements qualify; it has not yet said which ones will.

Buying software, devices and technical support from outside companies remains allowed; the staffing restriction concerns third-party clinical staff time. CMS expressly allows practices to obtain software, devices, connectivity, data hosting, cybersecurity, interoperability, implementation support and technical assistance externally. Clinics do not have to build their own technology or stop using a monitoring platform in 2029.

Existing CPT codes remain in place

• No bundled G-codes. CMS sought comments on four codes: separate setup codes and monthly codes combining device supply with treatment management for RPM and RTM. It did not adopt them for 2027, so the existing CPT code structure remains in place.

• No practice-expense cut to treatment management, as covered above.

• RPM and RTM can be billed in the same month as chronic care management (CCM), principal care management (PCM), transitional care management (TCM) or behavioral health integration (BHI) when each service's requirements are met. Time cannot be counted twice.

Prepare your clinic for January 1, 2027

• List every patient in monitoring as of December 31. These patients carry over without an initiating visit. Keep enrollment dates and orders on file in case of an audit.

• Build the initiating-visit step into enrollment. From January 1, a new patient needs a qualifying visit where monitoring is discussed before the first billed month. Record the discussion and consent in the note.

• Keep documentation tight. CMS continues to respond to OIG findings on remote monitoring billing, so records should show medical necessity, patient consent, practitioner involvement and treatment management time.

• Check new RTM patients against the three-year established-patient rule. Anyone new to the practice needs the visit first.

• Update RTM and RPM budgets with the 2027 rates. Both setup codes pay $19.90 nationally; device supply pays $41.11 for RPM, $41.11 for respiratory RTM and $40.79 for musculoskeletal and CBT RTM. Use the treatment-management rates for the service actually furnished, not a device-only revenue assumption.

• Plan staffing ahead of 2029. Clinics whose contracted staff perform monitoring time have until December 31, 2028 to restructure, and should watch for CMS guidance on which arrangements will qualify.

Actuvi builds the program around your care team

The 2027 final rule keeps RTM and RPM tied to the treating practice. Actuvi gives clinics the technology and implementation support to run that model without building a remote care platform of their own.

For RTM, Actuvi builds the program around your care pathways: assessments, clinical thresholds, monitoring tracks, team roles and workflows are configured before launch. Actuvi trains administrative, clinical and billing staff for their roles, then supports patient onboarding and the rollout across locations. Clinics can monitor at each site or organize a central team, with access set for the patients and tools each person needs.

Actuvi automatically tracks billable staff time and data transmission days and generates CPT-coded billing reports. Its guardrails help prevent overbilling and overcalculation of monitoring time, with documentation available for audit review. Automated reminders and AI text outreach help patients keep submitting their monitoring responses between visits.

Support continues after launch. A customer success manager reviews program performance, identifies problems and helps the team improve the program. RTM and RPM are available on the same digital care platform, so clinics can add programs around their patient population rather than operate disconnected systems.

Launch or expand RTM and RPM across your clinics

Talk to Actuvi about your patient population, care pathways and staffing model. Actuvi can show how the program would run across your clinics and what the 2027 reimbursement changes mean for your planned volume.

Request a demo

Frequently asked questions

Does every patient need another visit in January 2027?

No. Patients already receiving RTM or RPM before January 1, 2027 do not need a new initiating visit just to continue. For patients starting under the new policy, a qualifying visit is required before monitoring can be billed; it can be part of an existing qualifying appointment.

Can clinics still use outsourced clinical staff in 2027?

Yes, through December 31, 2028, subject to existing supervision, incident-to and other billing rules. The delay does not remove the billing practitioner's responsibility for oversight and clinical integration.

Does the staffing rule mean clinics must replace their monitoring software?

No. The direct-employment requirement concerns clinical staff, not technology ownership. Outside companies may continue to supply software, devices, connectivity and technical support after 2028.

Will clinics receive exactly the rates shown in these tables?

Local payments can vary, and some clinicians qualify for different Medicare rates. Other insurers set their own rates.

Can the initiating visit happen by telehealth?

Yes, when applicable Medicare telehealth requirements are met. The current statutory flexibilities run through December 31, 2027; after that, the rules in effect at the time determine which telehealth visits qualify.

This is not legal or billing advice. National rates are shown before geographic adjustment. Confirm payer-specific requirements and special billing situations with your Medicare Administrative Contractor or compliance advisor.