On July 14, CMS released the Calendar Year 2027 Medicare Physician Fee Schedule proposed rule. Buried in it are provisions that would materially change how Remote Therapeutic Monitoring programs operate. The comment period closes Monday, September 14. If you run an RTM program, or you're a PT who cares about your patients having access to one, this is worth five minutes of your time.
Where this came from
The proposed changes trace back to an OIG report on fraud in Remote Patient Monitoring. That's a real problem, and I don't dispute the need for oversight. But the rule takes a fix designed for one program and applies it to another that was built differently.
"RPM and RTM are not the same program, and CMS's proposed rule treats them as if they are."
Two differences matter here, and both of them argue for treating RTM on its own terms.
RTM already requires a plan of care
The proposed rule would require a separately billable initiating visit before RPM or RTM can begin. For RPM, that's a meaningful gap CMS is right to close — RPM often starts without a documented clinical relationship. For RTM, it's redundant. A plan of care is already a prerequisite, so the clinical relationship and medical necessity documentation this initiating visit is meant to establish already exist by definition.
RTM is short and episodic. RPM often isn't.
RTM is billed against an active episode of care — it starts and ends with the plan of care it's tied to. RPM can run indefinitely, tracking a chronic condition for months or years with no natural endpoint. The fraud vulnerability OIG identified — extended, unsupervised billing with no clear stopping point — is structurally an RPM risk.
Applying the same fix to RTM without acknowledging that difference is where this rule needs correction.
Sept 14
Deadline for public comments on the proposed rule
2020
Year CMS reversed a restrictive RPM supervision rule after industry comment
5 min
About how long a short comment letter takes to write
The bigger issue: banning outsourced monitoring
The proposed rule would limit RPM and RTM monitoring to direct employees of the billing practice. Contracted clinical staff — including monitoring vendors, one of the services we offer at EverEx — would no longer qualify. This is the provision that needs the most commentary, because I don't think CMS has fully modeled the disruption. Outsourced monitoring isn't a workaround for practices avoiding investment in RTM — for many practices, it's the only way an RTM program can function at all. Clinic-based PTs are billing full patient loads all day. Asking them to also check in on RTM patients between visits doesn't scale, and it usually loses.
What happened when one practice made the switch
We've seen this directly. One of our customers ran their RTM program in-house before moving it to EverEx's outsourced clinical monitoring team. Patient engagement, exercise completion, and messaging response all went up after the switch — not down. The reason is straightforward: our clinicians are in the patient portal every day, because that's their job. In-clinic PTs are managing a full schedule, and RTM monitoring competes for time they don't reliably have. Outsourcing didn't dilute the clinical relationship here — it made the monitoring more consistent, which improved outcomes.
If CMS finalizes an employment-only requirement, practices that can't staff dedicated in-house monitoring will drop their RTM programs rather than absorb the burden internally. That's not a fraud fix. That's a coverage cut for the patients who benefit from RTM the most.
Reimbursement and code changes
CMS is also proposing changes to RTM code valuation and reimbursement, and separately seeking comment on consolidating the RPM and RTM code sets. Depending on where the final numbers land, this could affect whether RTM programs remain financially viable for practices already operating on thin margins. It's worth flagging in your comment even if the staffing provision is your primary concern — the two issues compound.
What to do Today
CMS is required to consider public comments before finalizing this rule, and comment volume changes outcomes — CMS reversed a similarly restrictive RPM supervision rule in 2020 after industry input showed it would collapse utilization. That only works if practices and clinicians actually submit comments.
The APTA has made this easy. Use their Patient Action Center to submit a letter opposing the outsourced-monitoring restriction and the misapplied initiating-visit requirement for RTM.
You don't need a long letter. A short comment describing how this rule would affect your patients or your practice's ability to run an RTM program carries real weight in the record CMS has to review.
