CMS’s proposed 2027 Physician Fee Schedule includes the most significant changes to remote patient monitoring (RPM) and remote therapeutic monitoring (RTM) reimbursement since the codes were created in 2019. Four separate pieces of the rule drive that: a proposed revaluation of the current code set, new visit and enrollment requirements, a request for information on collapsing the code set into new G-codes, and a broader cut to the conversion factor that applies no matter what happens to RPM specifically.
Here’s what each one does.
A Revaluation Built on an Unverified Assumption
CMS’s stated rationale for revisiting RPM valuation is that devices likely cost less today than the agency assumed when it built the current payment rates. The CMS fact sheet doesn’t say what evidence backs that number, or which devices it’s using as the benchmark. It simply asserts the number and proposes revaluing the device codes, CPT 99453, CPT 99454, and CPT 99445, accordingly.
The treatment management codes take a different kind of cut on the same premise: CMS wants to strip out the clinical staff cost assumptions baked into CPT 99457, CPT 99458, and CPT 99470, while keeping their existing value and time components in place. The reasoning: These services supposedly don’t involve clinical staff time in the first place, an unusual claim for codes that exist specifically to pay for clinical staff time spent monitoring patients each month. Both changes assume delivering the work costs less than CMS originally estimated, but neither comes with the data to show it.
Two New Requirements Before Billing Can Start
CMS is proposing two prerequisites that would need to happen before an organization can bill for RPM or RTM at all. A separately reportable initiating visit would be required at the start of services, for both RPM and RTM. RTM would also pick up the established patient requirement RPM already has, closing off the option some programs currently use to enroll a new patient straight into monitoring. The codes themselves aren’t worth any less because of this.
Other remote care programs like chronic care management (CCM) have had an initiating visit requirement for some time. This proposal is a reasonable way to ensure patient buy-in at the onset of RPM or RTM services with minimal impact on program return on investment.
CMS Is Asking Whether to Bundle the RPM and RTM Code Sets
There’s also a more structural question: whether to fold the current RPM and RTM CPT codes into four new HCPCS G-codes, two for each. In CMS’s request for comments about this potential bundling, draft descriptions spell out exactly what’s on the table. The new RPM treatment management code would combine the device, the data, and the monthly clinical work into a single payment that only pays out once an organization logs at least 20 minutes of real-time contact with the patient that month. Fall short of that threshold and nothing gets paid. Today, an organization can still get paid for supplying the device and collecting the readings, billed under 99454, even in a month when nobody logs a single minute of live contact. That standalone option would disappear under the bundled structure.
That flexibility, much of it introduced in CMS’s own 2026 rule, would vanish under the bundled approach, effectively resetting the code set to something closer to its pre-2019 form. Providers pushed back hard on that earlier version, and most of what CMS has changed about RPM billing since 2019 traces back to that pushback.
The bundled code’s math also creates an odd incentive: the same 20 minutes of clinical staff time, billed instead under CCM or principal care management (PCM), could pay an organization more than the bundled RPM code would, and neither of those programs asks for a device or a live conversation to qualify.
The Conversion Factor Cut That Compounds Everything Else
Finally, the proposed 2027 conversion factor itself is dropping, to $33.17 for qualifying alternative payment model participants and $32.84 for everyone else. That decrease has nothing to do with RPM. It’s the scheduled expiration of a one-year conversion factor increase Congress enacted last year. But it means a code CMS doesn’t touch at all would still be worth less in 2027 than it was in 2026, and RPM and RTM don’t get an exemption from that math.
Get the Proposed Rule Breakdown on July 30
A modest revaluation, two new requirements that push the start of billable revenue out further, a bundling question that hasn’t even reached the proposal stage yet, and a conversion factor dip: no single piece might look alarming on its own, but organizations modeling next year’s RPM economics need to account for all four at once.
Prevounce’s Co-founder and CEO Daniel Tashnek, JD, will be covering all of this in more depth, along with CMS’s proposal to bar contracted staff from billing RPM and RTM services altogether, in a complimentary educational webinar on July 30 at 2 p.m. ET/11 a.m. PT. Part of that session covers what organizations with RPM and RTM programs can do right now, including how to submit an effective comment, to help keep questionable provisions like these out of the final rule.
Casey Johnson is the vice president of growth at Prevounce Health, a healthcare software and services company that simplifies the provision of remote patient monitoring, chronic care management, advanced primary care management, and preventive services.
Casey Johnson
Casey Johnson is the vice president of growth at Prevounce Health, a healthcare software and services company that simplifies the provision of remote patient monitoring, chronic care management, advanced primary care management, and preventive services.
