CMS released the CY 2027 Physician Fee Schedule proposed rule on July 14, 2026, and it carries the biggest change to remote monitoring billing since the codes were created. If it holds, the way a lot of clinics run RPM and RTM would have to change by January. 

The rule centers on one thing above all: who is allowed to do the monitoring. Since Medicare started paying for these services, a clinic could hand its remote monitoring duties to an outside company and still bill for it. CMS wants to close that door. It also wants a separate visit before monitoring begins, and it wants RTM limited to patients the clinic has already treated, the way RPM already is. 

Why CMS is proposing this 

Three years of oversight work sit behind the rule. In 2024, the HHS Office of Inspector General reported companies cold-calling Medicare patients to sign them up, and found that about 43% of enrollees who received RPM never got all three required parts: the setup and patient education, the device supply, and the monthly treatment management where a clinician reviews the data and adjusts the care plan. A follow-up in 2025 found Medicare paid more than $500 million for RPM in a single year, and flagged billing patterns that posed a program-integrity risk: practices billing for patients they had no prior relationship with, patients already enrolled at another practice, and several devices for the same patient in the same month. 

RPM use has grown steadily since 2019. Both reports came with recommendations, and CMS is now acting on them. The agency read those patterns as a supervision problem: when an outside vendor runs the monitoring, the billing practice isn't close enough to it to make sure patients actually get the care they're billed for. 

The three changes that matter most 

The first change is the one drawing the most attention. RPM and RTM would be payable only when the monitoring is performed by clinical staff who are direct employees of the billing practice. Contracted third-party monitoring would no longer qualify for payment. The staff don't have to sit inside the building and the patient doesn't have to be on site, but the people doing the work have to be the practice's own, under the billing clinician's general supervision. This runs through Medicare's incident-to rules, which let a practice bill for services its clinical staff deliver under a supervising clinician as if the clinician had provided them. Their time still counts toward the billing clinician's time, so the billing clinician does not have to personally review every reading. What changes is that those staff have to be on the practice's own payroll, not an outside company's. 

The second is a separate initiating visit. Before any monitoring can start, the billing clinician has to see the patient in a separately billable, face-to-face visit, in person or by telehealth, and discuss the monitoring during it. A code that involves no face-to-face contact can't stand in for it, and if monitoring never comes up at the visit, the visit doesn't count. This is a new step at the front of every monitoring episode, separate from the relationship requirement below. 

The third is that established-patient requirement. RPM already limits monitoring to patients the practice has treated before. The proposal extends the same limit to RTM, so a clinic could not start therapeutic monitoring on someone it has never seen. 

Here is the before and after: 

One more idea worth watching 

CMS floated a bigger idea for comment rather than proposing it outright: collapse all seventeen current RPM and RTM CPT codes into four new G-codes, two for RPM and two for RTM. Each monthly code would require a device supply, at least two days of transmitted data, and at least twenty minutes of treatment management that includes a live conversation with the patient. It would be cleaner to administer and harder to earn. 

Comments are open through September 14, 2026. If CMS finalizes the rule, the changes take effect January 1, 2027. 

What this means if you outsource monitoring 

A clinic that runs RPM or RTM through an outside monitoring company has the most to work through. The billing model those arrangements rely on, where a vendor's staff do the monitoring and the clinic bills for it, is the specific thing CMS is proposing to stop paying for. The rule doesn't touch the technology, though. A vendor can still supply the devices, the apps, the dashboards, and the analytics, and the clinic still bills Medicare and pays its technology partner out of what it collects. What would no longer be billable is the monitoring work itself when an outside company's staff performs it. 

A compliant program under the proposal has a recognizable shape: the clinic's own staff doing the monitoring, a documented initiating visit on file, and an established relationship with every patient enrolled. Clinics already working that way would mostly be checking boxes they have. Clinics leaning on a vendor's staff would be rebuilding the core of how their program runs. 

This is how Actuvi works already 

Actuvi, an FDA-listed, HIPAA-compliant RTM platform, was built this way from the start, on a simple belief: the best care happens when local providers deliver it, even digitally. Actuvi builds and launches the clinic's remote monitoring program, and the clinic's own care team does the monitoring. Patients stay inside the clinic's ecosystem. 

Actuvi's job is the software, the AI, and the automation that make those programs easy to run: AI agents that text patients who fall behind on their monitoring, and an AI-enabled RTM builder that gets a program live in one to two weeks. 

If this rule is finalized, nothing changes for clinics running on Actuvi. The model CMS wants to require is the model they already run on.