Remote Monitoring in 2027: CMS Wants to Rewrite RPM Billing

Your RPM program finally runs on autopilot. A vendor ships the cuffs and scales, their nurses watch the readings and your team bills the codes every month. Patients like it. Your cardiologists like the data.

Now CMS wants to take apart the exact model that makes it work.

The CY 2027 Physician Fee Schedule proposed rule would change who can perform remote monitoring, when it can start and possibly how it's coded. If your cardiology program depends on a third-party vendor, you need a plan before January 1.

The Vendor Model Is the Target

For years, Medicare let practices contract with outside companies whose staff handled monitoring, triage and patient calls. Those staff counted as auxiliary personnel of the billing practice.

The proposed rule would end that. As the law firm Benesch summarizes it, monitoring performed by third-party clinical staff couldn't be counted toward Medicare billing, regardless of quality. The staff doing the work would need to be employees of the billing practice.

That's a sharp reversal. Only a year ago, the CY 2026 rule expanded RPM with shorter data thresholds and new billing pathways.

Why CMS Changed Its Mind

Two HHS Office of Inspector General reports drove this. The first, covered by the American Hospital Association, found Medicare RPM use jumped from about 55,000 enrollees in 2019 to 570,000 in 2022.

The same report found about 43% of enrollees who got RPM didn't receive all three components: education and setup, device supply and treatment management. OIG said that raised questions about whether monitoring was being used as intended.

CMS read that as an oversight gap. Its fix is to pull the work back inside the practice and add more structure at the start of every episode.

Three Changes Your Program Would Feel

The proposed rule doesn't touch just one part of RPM. It reaches into staffing, patient intake and coding. If you run a cardiology monitoring program with an outside partner, each of these lands on a different team in your practice. Here's what's on the table.

• No outsourced clinical staff. Monitoring by contracted vendor staff wouldn't support Medicare billing. Your own employees would need to do it.
• A required initiating visit. Before monitoring starts, the billing practitioner would hold a separately billable face-to-face visit. Goodwin notes the visit must cover the monitoring plan, a clinical decision that RPM is warranted and documented patient consent.
• Established patients only for RTM. Remote therapeutic monitoring would be limited to patients with an existing relationship with the billing practitioner.
• Fewer, bundled codes. The American College of Cardiology reports CMS is floating four new G codes to replace 17 existing RPM and RTM codes. Bundled codes would pay only when every requirement is met.
• Lower valuations. CMS also proposed recalculating payment for monitoring services downward.

What Cardiology Programs Should Do Now

Nothing is final yet. CMS expects to publish the final rule in November. But the direction is clear, and a January 1 effective date leaves you almost no time to react.

Start by mapping who touches each RPM patient today. If vendor nurses own the monthly monitoring calls, you'll need a plan to bring that work in house. That means hiring, retraining existing staff or restructuring the vendor agreement so the clinical work sits with your employees.

Next, look at how patients enter your program. A required initiating visit means scheduling, documentation templates and consent capture all need to change. If a routine visit never mentions monitoring, it wouldn't qualify.

Then check your claims. OIG's findings on incomplete components are the reason this rule exists. If your data shows patients billed for device supply without treatment management, fix that now. It's the pattern auditors already look for.

The Practices That Keep RPM Profitable

RPM isn't going away. Cardiovascular services overall are projected to rise about 1% in 2027, according to ACC's payment calculator as reported by Cardiovascular Business. Monitoring still helps your patients between visits.

What changes is where the work lives. Programs that run monitoring inside their own EHR, with readings, time logs and consent stored in the chart, will adapt faster. Programs that rely on a vendor's portal and a monthly invoice will struggle.

That's why ADS builds remote patient monitoring into the same platform as charting and billing. Your team sees readings, logs interactive time and captures consent in one place, and the claim pulls from that same record. Our cardiology billing team then checks each claim before it goes out, which is how ADS clients hold a nearly 99% first-pass clean claim rate.

If you're still building out your program, start with our guide to the RPM revenue opportunity most practices miss. Then see how monitoring fits into your broader revenue cycle management plan.

Plan for the Rule You Can See

Waiting for the final rule feels safe. It isn't. If CMS finalizes even part of this proposal, you'll have about six weeks to restructure staffing, intake and coding. Practices that map their exposure now can move the day the rule drops.

Ready to see what monitoring looks like when it lives inside your chart? Request a live demonstration and see the Medics Suite run in your cardiology workflow. Have a quick question first? Call 1-800-899-4237 ext. 2264. A real person answers in under 2 minutes.

Sources: CMS CY 2027 Physician Fee Schedule proposed rule; American College of Cardiology; HHS OIG via American Hospital Association; Benesch; Goodwin; Cardiovascular Business.