CMS's 2027 Fee Schedule Proposal Could Ban Your Outsourced RTM Vendor

Using a full service model for RTM? Get ready for the CMS proposed changes to RTM to safeguard your revenue.

CMS has proposed a new rule for the CY2027 Physician Fee Schedule. It is a proposal, not final policy, but it could make your outsourced RTM vendor's billing model non-compliant.

• RTM would be limited to established patients only.
• A face-to-face initiating visit would be required before RPM or RTM begins.
• Billable services would be limited to those furnished by clinical staff employed by the billing practice.
• CMS asked for comment on collapsing the current 17 RPM/RTM CPT codes into four bundled HCPCS G-codes.
• Comments are due within 60 days of the July 15, 2026 notice.

The takeaway is simple. If the people monitoring your patients are not employed by your practice, your billing model is at risk under this proposal.

CMS's proposed CY2027 rule and why it lands differently this time

CMS proposed the new rule in a notice covered by the AHCA/NCAL blog, published July 15, 2026. You have 60 days to comment. Nothing is final yet, but the direction is clear.

Do you know this is coming if you run a full-service outsourced RTM or monitoring vendor? Many clinics don't. Their vendor handles the staffing and the monitoring, and the clinic bills for it. That arrangement is exactly what this rule targets.

This is not routine fee schedule tinkering. CMS is signaling a broader shift toward simpler, integrated remote monitoring delivered by the billing practice itself. The proposed staffing restriction and the request to bundle 17 codes into four G-codes point the same way. Outsourced monitoring becomes harder to bill, and in-house delivery becomes the compliant path.

What "employed by the billing practice" actually means

The proposed rule would only pay for remote monitoring when the person doing it works for your practice. That single line decides which staffing models keep billing and which ones stop.

A W-2 employee is the safest fit. If a physical therapist or clinical staff member on your payroll runs the monitoring, you clearly furnished the service through your own practice. A 1099 contractor is less certain. Depending on how the contract is written and how CMS reads "employed," a contractor may or may not count.

An outsourced monitoring vendor is the one most exposed. Full-service vendors run the monitoring with their own staff, not yours. Under this language, that staff is not employed by the billing practice, so the service they perform would not be billable. The problem isn't the CPT codes. It's who does the work. Even a perfectly coded claim fails if the monitoring came from a third party's team instead of your own.

None of this is final. CMS could change or drop the provision after the comment period. But the direction is clear enough to check now. The AHCA/NCAL summary of the proposed rule explains the staffing restriction and the wider push toward practice-delivered monitoring.

How the three staffing models stack up against the proposed rule

The proposed rule favors monitoring done by your own employed staff. The table below shows how each model lines up.

The rule points clearly toward the in-house model. When your own employed clinicians do the monitoring, the work stays inside your practice, and the billing holds up under the "employed by the billing practice" language. The outsourced model puts the monitoring staff outside your practice, which is exactly what this proposal treats as non-billable.

What to check in your current RTM vendor contract right now

Pull your RTM vendor contract and read the staffing section first. Find out who actually performs the monitoring and the interactive communication with your patients. If the answer is the vendor's own staff, and those people are not employed by your practice, the proposed rule puts your billing at risk.

Check how the contract defines who "furnishes" the service. Vendors often describe themselves as delivering the monitoring on your behalf. Under CMS's proposed language, that arrangement is the problem, because billable RTM would need to come from clinical staff your practice employs.

Ask your vendor directly whether their monitoring staff are your employees or theirs. Most full-service vendors use their own people, so expect that answer. Get it in writing.

On timing, the rule is a proposal, not final law, so you don't need to break your contract today. Read the AHCA/NCAL summary of the proposed rule and note the comment window during the 60 days after the July 15, 2026 notice. Use this period to map your exposure and line up an alternative. Hold off on any new multi-year outsourcing commitment until you see the final rule.

Preparing for a compliant, in-house model before the rule finalizes

If your review shows exposure, the fix is to bring monitoring in-house. Have your own W-2 clinical staff, or properly employed staff, deliver the monitoring, supported by a software platform instead of a staffing vendor. The proposed rule wants the billing practice to furnish the service with its own people, and a software tool your staff runs meets that standard where an outsourced monitoring team does not.

Build two other changes into your workflow now, whichever way the final rule lands. First, add a face-to-face initiating visit before RTM begins. Second, limit RTM to established patients. Both are in the proposal, and both are easy to bake into intake so you are not scrambling later. Set up your scheduling and documentation to require the initiating visit as a gate before any remote monitoring starts, and flag which patients qualify as established. Getting these habits in place early costs little and protects your billing regardless of the final timing.

Move your RTM in-house before the rule forces the issue

The rule isn't final, but the staffing risk is clear enough to start planning now. If your monitoring staff work for an outside vendor instead of your practice, your billing could stop qualifying under this proposal. Moving that work in-house protects it.

Physitrack's RTM platform lets your own employed clinicians deliver monitoring, with software handling the tracking and communication. You keep the billing relationship inside your practice, which is what the proposed rule favors.

Look at your current outsourced contract, then compare it to a staff-delivered model. Even before CMS finalizes anything, building monitoring around your own employed clinicians puts you on solid ground.

FAQs

Is the rule final? No. CMS has issued a proposed rule for CY2027, and it can still change. Nothing takes effect until the final version is published.

When are comments due? Within 60 days of the July 15, 2026 notice, per the AHCA/NCAL summary. You can submit comments to CMS during that window.

Does this affect RPM too? Yes. The proposal requires a face-to-face initiating visit before both RPM and RTM begin, and the same staffing restriction applies. Both models sit in scope.

What happens to existing patients under the established-patient limit? The proposal would limit RTM to established patients, so your current patients stay eligible. New patients would need an initiating visit before monitoring begins.

What happens if the 17 codes collapse into four G-codes? CMS has asked for comment on bundling the current RPM and RTM codes into four HCPCS G-codes. If adopted, you would bill simpler bundled codes instead of the current set, which changes your billing workflow but not who is allowed to deliver the service.