The CY 2027 Medicare Physician Fee Schedule Proposed Rule published on July 16, 2026, has proposed a significant set of changes to remote monitoring services. These proposed changes follow Office of Inspector General reports raising program integrity concerns about remote patient monitoring.

Notably, CMS is proposing to bar third-party outsourcing of remote physiologic monitoring ("RPM") and remote therapeutic monitoring ("RTM") services. Effective January 1, 2027, payment would be allowed only when clinical staff performing these services are direct employees of the billing practitioner or practice. CMS stated it “believes outsourcing RPM/RTM services to a third party can fragment care, lead to insufficient involvement and oversight of the billing practitioner, or result in services that do not actually represent or facilitate all required aspects of RPM or RTM services." CMS also questioned whether outsource arrangements can satisfy billing requirements themselves, stating it does “not believe that the full scope of service elements required to bill these codes are being met[.]" CMS did not clarify what a “direct employee” is for these purposes, therefore, uncertainty remains regarding the requirement's implementation.

Aside from the proposed change above, CMS also proposed, among other things, that both RPM and RTM would require a separately billable, face-to-face (in-person or telehealth) initiating visit during which the service is actually discussed and beneficiary consent is obtained. Further, CMS proposed consolidating the current myriad of related billing codes into four new G-codes. 

Providers offering remote monitoring services, particularly those relying on third parties, should evaluate how these proposed requirements could affect their current operations and closely monitor rulemaking developments.