On July 14, 2026, CMS released its proposed Physician Fee Schedule rule for 2027 — and buried inside it are changes that could meaningfully reshape how RPM programs are staffed and billed. Nothing here is final. This is a proposal; the comment period runs through September 14, 2026, and current RPM billing rules remain unchanged through the end of 2026, regardless of what happens next. But the proposal is specific enough and significant enough that independent practices should know what’s on the table now rather than find out in November.
What’s Actually Being Proposed
Four changes would directly affect RPM if finalized as written:
- RPM services would need to be performed by staff the practice directly employs — clinical staff contracted through a third party would no longer qualify for billing.
- A separately billable “initiating visit” would be required before starting RPM, rather than enrolling a patient directly into monitoring.
- RTM (a related but separate monitoring category) would require an established patient relationship, matching a rule that already applies to RPM.
- Device-supply codes would likely be revalued downward, based on CMS’s belief that RPM devices now cost less than originally estimated when the codes were priced.
The Provision Getting the Most Attention
The employment restriction is the one drawing the most industry response, and it has some history behind it. When 99457 first took effect in 2019, CMS required direct supervision — meaning contracted or remote staff couldn’t realistically deliver the service. CMS loosened that to general supervision the following year, which is what allowed the outsourced RPM staffing model many programs use today to exist in the first place. This proposal would largely close that door back up.
CMS’s stated reasoning traces back to two OIG findings it cites in the proposal: a 2024 review found a substantial share of RPM enrollees weren’t receiving all three components of the service as billed, and a 2025 data snapshot showed RPM payments had grown sharply year over year. Whether the employment restriction is the right response to that finding is a genuine point of industry debate — but that’s the rationale CMS is working from.
What’s Not Changing
Worth knowing directly: CCM and APCM are untouched by any of this. Contracted staffing arrangements remain fully permitted for those programs no matter how the RPM provisions are finalized. For a practice running RPM alongside CCM, that’s a meaningful piece of the care management model sitting entirely outside this proposal’s scope.
A Bigger Question in the Background
CMS is also asking for comment on something more structural: collapsing the current RPM and RTM CPT codes into four new bundled G-codes. Under the version described in the request for comment, device supply, data transmission, and 20 minutes of interactive management time would all need to be met together for any payment — an all-or-nothing model. That would be a notable reversal of the flexibility the 2026 code updates just introduced with 99445 and 99470, which exist specifically to pay for partial thresholds rather than requiring everything at once.
Will This Survive to the Final Rule?
Genuinely uncertain, and reasonable people in the industry disagree. Some RPM vendors and healthcare attorneys following the proposal have pointed out that CMS’s own language reads more like a request for missing cost and workflow data than a fully settled policy — atypical framing that historically has preceded CMS narrowing or walking back aggressive proposals during the comment period. Others simply note the proposal has already drawn public pushback from provider organizations. Neither outcome is guaranteed; the final rule is expected around November 1, 2026.
What to Do Right Now
Nothing needs to change in your program today. What’s worth doing:
- Review whether your current RPM staffing is in-house or contracted, so you know exactly how exposed your program would be if the employment restriction survives to the final rule.
- Don’t restructure preemptively — the comment period exists precisely because provisions like this one often shift before finalization.
- If you have a strong view, the comment period is open through September 14, 2026, at regulations.gov under file code CMS-1848-P.
The Bottom Line
This is a proposal, not a rule change — but it’s a proposal worth tracking closely if RPM is a meaningful part of your practice’s care management strategy. We’ll update this piece once the final rule is issued in November.
For how the current, unaffected billing rules work today, see our full breakdown of 99454, 99445, 99457, 99458, and 99470, or start with our RPM CPT Codes Explained overview.
Want help thinking through how your current staffing model would hold up if this proposal is finalized? Talk to our team about how Advaa Health keeps RPM management documented and defensible, regardless of how CMS’s 2027 rule ultimately lands.
