If the record stays quiet, the monitoring stops January 1.
A new CMS proposal ends Medicare payment for the way most remote patient monitoring is delivered in America — the nurses watching seniors' blood pressure, blood sugar, heart, and oxygen readings every day go silent, and patients already enrolled get no protection. The only window to stop it closes September 14.
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The CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P) was published in the Federal Register on July 16, 2026. Buried in more than a thousand pages are two provisions that would dismantle remote physiologic and therapeutic monitoring as most of America receives it.
CMS proposes to pay for RPM and RTM services only when performed by clinical staff directly employed by the billing practice — eliminating payment when monitoring is furnished by specialized third-party clinical teams working under physician supervision.
This is not a crackdown on fraud. It is the elimination of the long-recognized "incident to" staffing model — the only model that makes 24/7/365 nurse monitoring possible for independent practices. And because the restriction is date-based, it reaches every patient already enrolled: on January 1, their monitoring claims simply stop being payable.
CMS proposes to require a separately reportable, face-to-face initiating visit in association with the onset of RPM/RTM services. The proposal is silent on the patients already enrolled — no exemption, no grandfathering, no transition period.
Without an explicit exemption, patients who have been stable for months or years because they are monitored could be forced through an appointment bottleneck before their monitoring may lawfully continue — millions of visits pushed into a system already short on appointment slots.
"What CMS has done in this rulemaking is just like cutting off the entire arm — because this ends RPM, both high quality and low quality."
Christopher Adamec, Executive Director, Alliance for Connected CareRemote monitoring through clinical partnerships is one of the most-studied care models in Medicare — including an independent actuarial analysis performed by Optum, one of the nation's largest health services companies.
Optum conducted a propensity-score-matched, difference-in-difference actuarial study of a national monitoring program — comparing 2,800+ monitored Medicare patients against more than 13,000 matched controls over 12 months, with monitoring reimbursement itself excluded from the savings math.
Across all three chronic conditions studied, monitored patients' medical costs rose thousands of dollars less than the matched patients who went unmonitored. Optum characterizes the directional savings as promising, with larger samples expected to confirm significance — evidence CMS says it wants, from the exact delivery model CMS proposes to eliminate.
Rural practices sit in the nation's deepest clinical staffing shortages. They cannot hire round-the-clock monitoring nurses, because those nurses do not exist to hire. Clinical monitoring partnerships are how a two-physician clinic in a shortage county offers its chronic-disease patients the same daily surveillance as an academic medical center.
An employee-only rule doesn't redirect this care in rural communities — it erases it. And it does so at the exact moment Congress is moving the opposite direction: the Rural Patient Monitoring Access Act (H.R. 3108) advanced out of the House Ways & Means Committee 39–0 on July 14, 2026 — the same day CMS proposed this restriction.
Continuous monitoring requires roughly one full-time clinician per 150–200 patients, plus platform, devices, logistics, and 24/7 coverage. For the small and independent practices that care for most of rural and Main Street America, the math has only one answer — and CMS is asking to see it. The rule itself states: "We are seeking comment on this proposal, specifically on how often third-party billing currently occurs and how this policy, if finalized, could impact access to remote monitoring services."
CMS asked. Let's answer — on the record, before September 14.
Federal law requires CMS to read and respond to substantive public comments. In past fee schedules, CMS has reversed proposals when the public supplied the evidence it was missing. That's the plan.
Every RPM patient you manage through a clinical monitoring partner loses payable monitoring the day this takes effect. The readings keep coming — but nobody is paid to watch them.
The "incident to" model exists across Medicare. Your orders, your protocols, your supervision, your clinical responsibility. Punishing the compliant majority for the fraud of a few is enforcement malpractice — CMS has audit, enrollment, and integrity tools built for exactly that job.
Re-processing every enrolled RPM patient through a new visit — on top of your existing schedule — is thousands of appointment slots your community doesn't have. At minimum, CMS must exempt already-enrolled patients.
CMS states in the proposal that it lacks cost and workflow data on RPM staffing. A comment describing your panel, your staffing reality, and your patients' outcomes is precisely what the administrative record needs.
The single most powerful action. We've drafted a full comment letter you can personalize with your practice's story and submit to the federal docket in one click.
or just copy the letter textJoin clinicians nationwide on a unified petition delivered to the CMS Administrator and congressional health committees before the comment deadline.
Sign the petitionSend the pre-written letter from your own inbox — to CMS leadership via the docket, with a copy to Protect RPM so your voice is counted when comments are delivered to Congress.
Your blood pressure, blood sugar, weight, or oxygen readings go to a nurse every single day. When something looks wrong, they call you the same day and alert your doctor — before it becomes an ambulance ride.
Medicare would stop paying for the nurses who watch your readings, because they work with your doctor instead of being employed by your doctor's office. Your doctor didn't choose this. Most offices simply can't hire 24/7 monitoring staff on their own.
Unless the rule changes, monitoring like yours ends on January 1, 2027 — and even where it could continue, you'd have to schedule a new office visit first, just to keep the care you already have.
CMS is legally required to read public comments — and patient stories are the ones regulators quote. You don't need to know policy. You just need to say what your monitoring does for you.
Add your name in 30 seconds. The petition is delivered to the CMS Administrator and Congress before the September 14 deadline.
Sign the petitionWe wrote a short letter in plain language. Add a sentence about what monitoring does for you, and submit it to the official federal docket.
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To the Administrator, Centers for Medicare & Medicaid Services:
We, the undersigned patients, caregivers, and clinicians, urge CMS to withdraw two provisions of proposed rule CMS-1848-P: the restriction eliminating payment for RPM/RTM services furnished by supervised clinical monitoring partners — the dominant delivery model, adopted because independent practices cannot staff 24/7 clinical monitoring alone — and the initiating-visit requirement applied without exemption to patients already enrolled in monitored care. Remote monitoring keeps patients out of hospitals and saves Medicare money. Address program integrity with targeted enforcement — not by disconnecting the patients who depend on monitoring today.
Signing takes 30 seconds in the action panel at the top of this page — then Step 2 puts your comment on the federal record.
CMS proposed ending teaching-physician virtual presence — then reversed after public comments showed how deeply the flexibility was embedded in real practice, finalizing it permanently instead.
In this very proposal, CMS acknowledges it lacks cost and clinical-workflow data on how RPM is staffed and delivered — and explicitly solicits that information. Well-evidenced comments don't just object; they fill the record CMS must rule on.
The Rural Patient Monitoring Access Act (H.R. 3108) advanced out of Ways & Means 39–0 on July 14, 2026. Bipartisan Washington wants more remote monitoring access — not less.
Re: CMS-1848-P — Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule
Dear Administrator:
I am a practicing clinician, and I write to oppose two provisions of the CY 2027 Physician Fee Schedule proposed rule: (1) the proposal to pay for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) only when furnished by clinical staff directly employed by the billing practice, and (2) the proposed initiating visit requirement, which is silent on — and therefore provides no protection for — patients already enrolled in monitored care.
[Describe your practice in 1-2 sentences: specialty, size, location, how many patients you monitor.]
Like countless practices across the country, mine partners with a specialized clinical monitoring organization because no practice of our size can staff licensed nurses 24/7/365 to review readings, triage alerts, and intervene before an emergency. This is the long-recognized "incident to" clinical staffing model — furnished under my orders, my supervision, and my clinical responsibility. Monitoring one panel of 150-200 patients requires a full-time clinician; a fully loaded RN care manager costs $110,000-$145,000 per year before platform, device, and coverage costs. The proposed employment restriction would not bring this staffing in-house — it would end the service.
The impact falls hardest on rural and underserved communities: 92% of rural counties are primary-care shortage areas and 199 rural counties have no primary-care physician at all. These are the practices least able to hire monitoring staff and the patients with the greatest chronic disease burden.
The initiating visit requirement compounds the harm. My enrolled patients have established relationships, active care plans, and months of monitoring history, yet the proposal does not state whether they are exempt. Requiring each to complete a new face-to-face visit before monitoring may continue would interrupt care for patients who are stable precisely because they are monitored. At minimum, CMS must explicitly exempt patients enrolled before the effective date in any final rule.
CMS specifically seeks comment "on how often third-party billing currently occurs and how this policy, if finalized, could impact access to remote monitoring services." I offer this response from direct experience: clinical partnership is how remote monitoring is delivered in my practice and throughout my community, and finalizing the employment restriction would end access for my patients on January 1, 2027. CMS should not finalize a restriction on a delivery model whose prevalence it acknowledges it has not measured.
Remote monitoring delivers measurable results. An independent actuarial analysis by Optum of one third-party-supported program found directional per-member per-year medical cost savings of $2,467 to $3,012 across hypertension, diabetes, and CKD cohorts versus matched controls — with monitoring reimbursement excluded from the savings calculation. Peer-reviewed literature shows reduced heart-failure hospitalizations, reduced total cost of care, and blood pressure reductions that translate directly into fewer strokes and heart attacks.
[Add one patient story — no identifying details: e.g., "Last month our monitoring partner's nurse flagged a hypertensive crisis reading at 9pm; the patient was treated the same night instead of arriving by ambulance."]
CMS states that it lacks cost and clinical workflow data regarding RPM staffing models. I offer this comment as exactly that evidence. I urge CMS to withdraw the employment restriction, exempt already-enrolled patients from any initiating visit requirement, and pursue program integrity through targeted enrollment screening, auditing, and enforcement against bad actors — not through elimination of the delivery model that makes monitoring possible for compliant practices nationwide.
You should see this exact title — "Medicare and Medicaid Programs: Calendar Year 2027 Payment Policies…" That's the right page.
Click in the box under "Comment*" and paste (Ctrl+V / ⌘V).
Choose "Physician - HC005" — or the option matching your role (Nurse Practitioner - HC015, Physician Assistant - HC010, Nurse - HC065, Rural Health Clinic - HPA65).
Type your email and check the box to get a confirmation with your tracking number.
You're commenting as yourself. Click the first tile — then enter your first and last name.
That's it — your comment is now part of the federal record CMS must respond to.
Re: CMS-1848-P — Please protect my remote patient monitoring
I am a Medicare patient and I use remote patient monitoring. Every day, my [blood pressure / blood sugar / weight / oxygen] readings go to a nurse who watches over me. When a reading is dangerous, they call me the same day — before it becomes an emergency room visit.
[In your own words, one or two sentences: what has monitoring caught for you? How does it make you feel safer?]
I understand CMS has proposed rules that would end the monitoring programs most patients like me use, and could require me to schedule a new doctor's visit just to keep the monitoring I already have. Please don't do this. My doctor's office cannot watch my readings around the clock by themselves. The nurses who monitor me work with my doctor — my doctor gets my results and adjusts my care because of them.
If this rule is finalized as written, patients like me lose the daily safety net that keeps us out of the hospital. Please withdraw these provisions and protect the monitoring patients already have.
You should see this exact title — "Medicare and Medicaid Programs: Calendar Year 2027 Payment Policies…" That's the right page.
Click in the box under "Comment*" and paste (Ctrl+V / ⌘V).
Choose "Individual - I0001".
Type your email and check the box to get a confirmation with your tracking number.
You're commenting as yourself. Click the first tile — then enter your first and last name.
That's it — your comment is now part of the federal record CMS must respond to.
