CMS Remote Monitoring Proposal
The Centers for Medicare & Medicaid Services (CMS) proposed sweeping changes to Medicare remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) that, if finalized, will dismantle established programs and disrupt care for patients who rely on them across the nation.
The Alliance for Connected Care is mobilizing an all-hands-on-deck national advocacy effort throughout the public comment period to protect patient access, preserve responsible innovation, and ensure CMS understands the real-world impact of its proposals on remote monitoring programs.
Background
Remote monitoring is a set of services involving the collection, analysis, and interpretation of digitally collected data, followed by the development of a treatment plan and patient care management under that treatment plan.
CMS created RPM codes in the Calendar Year (CY) 2019 Medicare Physician Fee Schedule, providing reimbursement for using technology to monitor patients between visits. In 2022, CMS further expanded remote monitoring to certain medical specialties through remote therapeutic monitoring (RTM), which allows for the collection of non-physiological data.
| Remote Physiologic Monitoring | Remote Therapeutic Monitoring | |
|---|---|---|
| What it monitors | Physiologic data | Non-physiologic data |
| Examples | Weight, blood pressure, pulse oximetry, respiratory flow rate, glucose, and ECG data | Musculoskeletal system status, respiratory system status, therapy like medication adherence, and therapy response |
Why RPM Moves on a Different Track Than Medicare Telehealth
Medicare telehealth and Medicare RPM are often discussed together, but they operate under fundamentally different legal authority. This distinction shapes their policy trajectories.
Medicare telehealth is written directly into statute under Section 1834(m) of the Social Security Act, which means any change to it (including extension and permanency) requires an act of Congress. The most recent extension came through the Consolidated Appropriations Act, 2026, which extended Medicare telehealth flexibilities through December 31, 2027.
Medicare RPM is different. CMS has determined that RPM services are inherently non-face-to-face and fall outside the scope of Section 1834(m), meaning RPM is not subject to the statutory telehealth restrictions that require periodic Congressional renewal.
A Fast-Moving Policy Area
RPM is a fairly nascent federal policy area relative to most Medicare benefits, having gone through only a handful of rulemaking cycles since its creation:
- 2018: CMS sought public input on remote patient monitoring in the CY 2019 Physician Fee Schedule and concluded that Section 1834(m) does not apply to all remote physician services.
- 2019: CMS created a G-code for remote evaluation while the American Medical Association (AMA) developed a corresponding CPT code.
- 2020: CMS adopted AMA’s family of RPM codes, including treatment management codes, formally establishing RPM as a care management service.
- 2019–2023: Under pandemic-era waiver authority, RPM was temporarily available to both new and established patients and for both acute and chronic conditions; post-pandemic, RPM reverted to established patients only, while continuing to cover both acute and chronic conditions.
- 2025: RPM policy reached an inflection point, as CMS received significant stakeholder feedback on the adequacy of its practice-expense methodology for modern monitoring technology, setting up a consequential CY 2026 rulemaking cycle.
CY 2027 Proposed Rule: Sweeping Changes on the Table
In its CY 2027 Physician Fee Schedule proposed rule, CMS has proposed a sweeping changes:
- A direct-employment restriction: CMS proposed limiting payment for RPM services to those furnished by clinical staff directly employed by the billing practitioner or practice, effectively prohibiting the use of contracted RPM clinical staff. This would disrupt vendor relationships and the centralized staffing models many clinically integrated networks rely on today.
- Significant rate cuts: CMS proposed crosswalking RPM payment rates to self-measured blood pressure codes (99473/99474) and RTM rates to an unrelated electrocardiographic rhythm code (93270), citing a lack of information on the devices and costs involved in furnishing these services. Notably, the proposed crosswalks point to unrelated cardiac codes and would eliminate clinical services from the payment for treatment/management codes.
- New initiating-visit requirement: CMS proposed that RPM be initiated only during a separately billable, face-to-face visit (in person or via telehealth) with the billing practitioner regardless of whether the patient has already had an E/M visit with that provider in the prior twelve months. This could create redundant visits and add to existing primary care and specialist access bottlenecks.
- Potential RPM code bundle: CMS is soliciting comment on bundling RPM/RTM services (setup, device supply, data transmission, and treatment management) into fewer monthly G-codes. CMS suggests this could help address OIG’s concerns about individual RPM components being billed without the others.
Momentum for Tech-Enabled Care in Washington
In Congress: The House Ways and Means Committee has held a series of hearings on rural health, chronic disease management, and tech-enabled care, including Modernizing Care Coordination to Prevent and Treat Chronic Disease (November 2025) and Health at Your Fingertips: Harnessing the Power of Digital Health Data (June 2025). Pending RPM-related legislation includes the Rural Patient Monitoring Access Act (H.R. 3108/S. 1535), the Expanding Remote Monitoring Access Act (H.R. 3032), and the Connected MOM Act (S. 141/H.R. 4977).
In CMS:
- ACCESS Model (Advancing Chronic Care with Effective, Scalable Solutions) tests an outcome-aligned payment approach in fee-for-service Medicare for technology-supported chronic disease care. Medicare Part B–enrolled organizations may apply on a rolling basis beginning in 2026 for a ten-year model spanning four clinical tracks—early cardio-kidney-metabolic risk, cardio-kidney-metabolic disease, musculoskeletal pain, and behavioral health—with per-beneficiary payments and a rural add-on.
- Rural Health Transformation Program is a $50 billion, five-year federal investment across all 50 states. Every state’s application included telehealth, and nearly all incorporated some form of remote patient monitoring.
- Health Tech Ecosystem initiative has drawn more than 180 pledged digital health companies committed to interoperability and expanded data-sharing, alongside a Medicare App Library to help beneficiaries find HIPAA-vetted health apps.
Top Challenges for Remote Physiologic Monitoring Providers
- Cellular, Wi-Fi, Bluetooth connectivity and transmission service for the device
- Secure and HIPAA compliant software capable of ingesting and processing patient vitals
- Integration with the provider’s electronic medical record
- Two-way patient engagement support software (via SMS, audio, video, or email)
- Compliant time tracking and billing software
- Technical support, device replacement, and battery replacement
- Many others
It is not possible to simply purchase an individual medical device without such features given Medicare’s requirement that, in order to report CPT code 99454, the device must automatically upload a patient’s data, which necessarily means the inclusion of software that must be created and maintained in various ways.
CMS SHOULD CONSIDER THE VARIOUS COMPONENTS REQUIRED FOR A HIGH-QUALITY RPM PROGRAM
CMS’s current valuation of 99454 (monthly remote monitoring, device supply) accounts only for a medical device as a direct practice expense (PE) input. It does not account for the cost of RPM software as a direct PE input. CMS notes, “as the PE data age, these issues involving the use of software and other forms of digital tools become more complex”, and may consider adding software as a direct PE input in the future.
CMS SHOULD INCORPORATE RPM SOFTWARE OR CELLULAR AND WI-FI DEVICE FEES AS DIRECT PRACATICE EXPENSE INPUTS IN VALUING RPM DEVICE SUPPLY CPT CODE 99454
The 20-minute threshold for reimbursement under 99457 and 99458 results in approximately 30% of care being uncompensated. CMS should structure treatment management codes to resemble primary care services by offering reimbursement for care furnished in smaller increments, as opposed to the 20-minute rule. This would improve the long-term viability and reach of RPM.
99453 and 99454 may only be reported once per patient during a 30-day period, even if multiple medical devices are provided to a patient for their conditions. CMS does not permit reporting of multiple instances of 99453 and 99454 when multiple devices are provided to a patient, even when medically necessary. For example, in the case of a patient with type 2 diabetes and hypertension, requires a blood glucose for their diabetes and a blood pressure monitor for their hypertension.
The work RVUs associated with 99457 and 99458 do not accurately reflect the work associated with providing RPM services. The work RVU of 0.61 associated with 99457 and 99458 should be increased to at least match the work RVU associated with chronic care management (CCM) service codes 99490 and 99439, which are 1.0 and 0.70, respectively. The work RVUs associated with RPM codes 99457 and 99458 should increase for the same reasons.
CMS does not reimburse 99457 and 99458 under the Hospital Outpatient Prospective Payment System (OPPS). The lack of reimbursement for 99457 and 99458 means that providers practicing in hospital outpatient department (HOPD) settings are unable to offer RPM services to their patients.
Data
Upcoming Federal Study
The Department of Health and Human Services (HHS) Office of Inspector General (OIG) announced it is working on a study: The Use of Remote Patient Monitoring Services in Medicare (OEI-02-23-00260).
The review will be based on Medicare fee-for-service claims and Medicare Advantage (MA) encounter data for remote patient monitoring services. It will look at the extent to which the use of remote patient monitoring services has changed, the nature of remote patient monitoring services being used by Medicare enrollees, and the characteristics of enrollees using remote patient monitoring services. The review will also determine the extent to which provider billing for remote patient monitoring services may indicate fraud, waste, or abuse.