CMS Signals Major Shift in Medicare Remote Monitoring Requirements

Medicare’s proposed 2027 Physician Fee Schedule would require closer physician involvement in remote monitoring and could significantly affect existing business arrangements between physician practices and third-party monitoring companies.

The Centers for Medicare & Medicaid Services (CMS) has proposed significant changes to Medicare payment requirements for Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM). The proposed rule would require an established physician-patient relationship, a separately billable initiating visit, and greater physician involvement in furnishing and billing for remote monitoring services.

Most significantly, CMS proposes prohibiting physician practices from billing Medicare for RPM or RTM services performed by clinical staff supplied by third-party monitoring companies. Beginning January 1, 2027, clinical staff time generally could count toward Medicare billing only when the staff member is directly employed by the billing physician or the physician’s practice. If finalized, the proposal could require physician practices, remote monitoring companies, technology vendors, and healthcare organizations to reevaluate existing business arrangements. More broadly, the proposal reflects CMS’s growing concern that remote monitoring has, in some instances, become disconnected from the physician responsible for the patient’s care.

Why This Matters

Remote monitoring has expanded rapidly as physicians and healthcare organizations increasingly use technology to monitor patients outside the traditional office setting. RPM is commonly used to monitor physiologic information, such as blood pressure, weight, blood glucose, pulse oximetry, respiratory function, and other clinical data, while RTM may be used to evaluate treatment adherence, musculoskeletal conditions, respiratory conditions, and certain digital therapeutic interventions.

The rapid growth of remote monitoring has also created an expanding industry of technology companies, monitoring platforms, staffing organizations, and vendors that support physician practices through equipment, software, patient communications, and operational services. These business models have enabled many practices to expand remote monitoring without building the necessary infrastructure internally. CMS has questioned whether some arrangements provide the level of physician involvement and oversight required by Medicare’s payment rules. The proposal follows reports issued by the HHS Office of Inspector General that identified weaknesses in Medicare’s oversight of remote patient monitoring and raised concerns regarding billing practices in certain remote monitoring arrangements.

Established Physician-Patient Relationship

CMS proposes extending the established-patient requirement for RPM to RTM services. Under the proposal, a physician would need an established relationship with the patient before furnishing and billing Medicare for RTM services. CMS explained that an existing physician-patient relationship allows the practitioner to evaluate the patient’s condition and determine whether remote monitoring is medically appropriate.

Under the proposal, physician practices will need to review how they establish and document the physician-patient relationship before remote monitoring services begin. Organizations relying on existing enrollment models may wish to evaluate whether those arrangements would satisfy CMS’s proposed requirements if finalized.

Initiating Visit Requirement

CMS also proposes requiring a separately reportable initiating visit before RPM or RTM services begin. The billing physician would be required to initiate remote monitoring during an in-person visit or qualifying telehealth encounter that is separately payable under Medicare. CMS explained that the visit allows the physician to determine whether remote monitoring is medically appropriate, discuss the service with the patient, coordinate treatment, and obtain the patient’s consent. The proposal reflects CMS’s continuing emphasis that remote monitoring should remain integrated into the physician’s overall management of the patient’s care rather than function as a stand-alone reimbursable service.

Restrictions on Third-Party Clinical Staff

The proposal may have the greatest operational impact on third-party clinical staff. Many physician practices contract with remote monitoring companies that provide technology, equipment, patient communications, clinical personnel, and operational support for RPM and RTM programs. In some arrangements, personnel employed by the outside company perform much of the patient interaction supporting Medicare billing.

CMS proposes allowing clinical staff time to count toward RPM or RTM billing only when the clinical staff member is directly employed by the billing physician or the physician’s practice. Services generally could not be billed when the clinical staff is employed by a third-party company rather than the billing physician or the physician’s practice. The proposal could change the role of third-party vendors in remote monitoring programs and how physician practices structure those relationships going forward.

Why Healthcare Organizations Should Pay Attention

Physician practices, remote monitoring companies, technology vendors, healthcare investors, and other organizations participating in remote monitoring arrangements may need to reevaluate existing business relationships if the proposal is finalized. CMS is placing greater emphasis on physician involvement, supervision, and accountability in remote monitoring services. Organizations operating under existing business models should consider whether those arrangements remain consistent with the direction reflected in the proposed rule and closely monitor the rulemaking process as CMS considers public comments.

Key Takeaway

Physicians, medical practices, remote monitoring companies, and healthcare organizations should carefully review the proposed rule and consider how it could affect existing remote monitoring arrangements if finalized.

The proposal provides a clear view of the issues that CMS considers important, including physician involvement, patient relationships, supervision, and the role of third-party vendors in furnishing remote monitoring services. It does not eliminate remote monitoring or the use of third-party technology companies but signals that CMS expects remote monitoring to remain closely integrated into the physician-patient relationship and under the meaningful direction of the physician billing Medicare. Organizations that rely heavily on remote monitoring should begin assessing the potential legal, operational, and business implications now rather than waiting for CMS to issue a final rule.

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