Remote Monitoring: CMS Gave Practices More Time, but There's a Catch

By Jennifer McNamara | Healthcare Inspired

CMS finalized several changes to remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) for 2027. Practices using outside monitoring companies should read the final policy carefully.

CMS will require RTM services to be furnished to established patients. It also finalized a requirement for a separately reportable initiating visit associated with the start of RPM or RTM services and updated the valuation of those services.

The agency had proposed limiting payment to services performed by clinical staff employed by the practice rather than outside contractors. After public comments, CMS delayed that staffing restriction until January 1, 2029.

Some practices will view the delay as welcome relief. I understand why, especially for organizations that have built monitoring programs around vendors.

But I would not use the extra time as a reason to postpone reviewing the program.

Start with how the service is actually performed.

I've seen arrangements where the physician group handles enrollment and billing, while a vendor provides the technology, collects data, and performs much of the day-to-day monitoring work.

The physician may have visibility into the program without fully understanding how each billed service is being completed and documented.

That creates risk when responsibilities are unclear.

Before evaluating the new staffing deadline, I would want to see the contract, the workflow, the documentation, and the claim detail.

Who orders the monitoring? Who establishes the patient in the program? Who furnishes the initiating visit? Who reviews the data? Who communicates with the patient? Who is supervising the clinical staff, and how does the practice verify that required services occurred?

The billing practitioner remains responsible for submitting claims that satisfy the applicable requirements. A vendor report does not, by itself, answer every billing question.

The initiating visit requirement needs its own review.

For 2027, CMS finalized a separately reportable initiating visit in association with the onset of RPM or RTM services.

Practices should not assume that enrollment into a platform, device shipment, or an automated onboarding process satisfies that requirement.

I would work through several actual patient records and confirm that the initiating visit is performed, separately reportable, and captured appropriately before the remote monitoring services begin.

The RTM established-patient requirement also needs to be reflected in referral and enrollment workflows.

Billing staff should not be responsible for discovering these problems after a claim is submitted.

A delayed staffing requirement is not a blanket approval of every vendor model.

CMS delayed the employed-clinical-staff limitation until 2029. Other Medicare requirements, including applicable supervision, documentation, and code-specific billing conditions, still need to be met in the meantime.

I would not interpret the delay as confirmation that all contractor arrangements are compliant through 2028.

There may be legitimate reasons to outsource operational work, but practices need clear responsibilities, accessible documentation, and a process for verifying the services they report.

I would also review whether the program is providing meaningful clinical follow-up rather than simply generating data and billing units.

That discussion belongs with clinical leadership as much as it does with the revenue cycle department.

Use 2027 to test the program against real claims.

Start with a small, representative sample of RPM and RTM patients. Trace each claim back to the physician order, initiating visit, device or platform activity, staff interaction, and medical record.

Then compare the vendor's documentation against the elements required for the reported codes. Review any gaps with the clinical team and revise the workflow where needed.

I would also confirm that contracts and operational plans address the January 1, 2029, staffing policy rather than assuming the current model can continue indefinitely.

CMS gave practices additional time on one requirement. It also finalized other requirements for 2027.

I'd use the next year to make sure the clinical program and the claims tell the same story.

Next in the series: New Medicare payment options and the work required before billing them.

SOURCE CMS: CY 2027 Medicare Physician Fee Schedule Final Rule (November 4, 2026)