CMS's 2027 RTM Proposals: What Therapy Clinics Need to Know

What is CMS proposing to change about RTM in 2027?

Four things — and none of them take effect now. CMS issued the CY 2027 Physician Fee Schedule proposed rule on July 14, 2026; it was published in the Federal Register on July 16. Its remote-monitoring section proposes that RTM be furnished only to established patients, that a separately reportable face-to-face initiating visit occur before monitoring begins, that payment be allowed only when the service is furnished by clinical staff employed by the practice, and that the setup and device-supply codes be revalued downward. A fifth item — bundling all 17 remote-monitoring codes into four — is a comment solicitation rather than a formal proposal.

Before anything else, the part that matters most operationally: your 2026 billing is unaffected. The 16-day and 20-minute thresholds, the partial-period codes 98985 and 98979, and every rule in our code-by-code guide remain in force through December 31, 2026. Comments close September 14, 2026; the final rule follows in early November (the CY 2026 final rule published November 5, 2025); anything finalized would take effect January 1, 2027.

CMS is explicit about what drove this. Two HHS Office of Inspector General reports found billing patterns it considers abusive — companies cold-calling beneficiaries to solicit them for monitoring, and, in OIG’s words, “about 43 percent of enrollees who received remote patient monitoring did not receive all 3 components of it.” The proposals are program-integrity measures aimed largely at high-volume RPM vendors. Therapy clinics running RTM inside an existing plan of care are not the target — but they are inside the blast radius.

Would the established-patient rule affect therapy clinics?

Probably the least of the four. CMS established in the CY 2021 final rule that RPM would again be limited to established patients once the COVID-19 public health emergency ended; it now proposes extending the same condition of payment to RTM, reasoning that a practitioner with an established relationship “would likely have had the opportunity to collect relevant patient history and conduct a physical exam.”

For a therapy clinic this is close to a description of what already happens. RTM sits under a therapy plan of care, and a plan of care follows an evaluation — so by the time monitoring starts, the patient is established with the billing therapist by any ordinary reading. The clinics that should look closely are those enrolling patients into monitoring from a referral before an evaluation has occurred.

What would the initiating visit requirement mean?

A face-to-face visit, furnished by the billing practitioner, at which RTM is actually discussed — and it can be billed separately. CMS proposes that RPM and RTM “must be initiated by the billing practitioner during a face-to-face (in-person or telehealth) visit,” and sets two exclusions: CPT codes that don’t involve a face-to-face visit by the billing practitioner, or aren’t separately payable under Medicare, can’t serve as the initiating visit. There’s a third condition that’s easy to miss — if RTM isn’t discussed with the patient at that visit, the visit doesn’t count.

For therapy, the obvious candidate is the evaluation. It is face-to-face, it is furnished by the billing therapist, and it is separately payable — so on the face of the proposed text it appears to satisfy the requirement. But CMS’s discussion is written in general practitioner terms and never addresses therapy evaluations, so this is an inference, not a stated position. Don’t build a 2027 workflow on it until the final rule or subsequent guidance says so. It’s a reasonable thing to ask CMS to clarify in a comment.

The practical read, if finalized: the enrollment conversation has to happen at a real visit and be documented there. Clinics that enroll patients by phone or by message between visits would need to move that step.

Could clinics still outsource RTM to a third party?

No — that’s the most concrete of the four proposals. CMS proposes “to only allow payment for RPM or RTM services when furnished by clinical staff employed by the practice,” and states plainly that if finalized, beginning January 1, 2027, the codes “could not be billed in cases where the service is not performed by clinical staff of the billing practitioner and will not allow contracting out to third-party companies.”

Two clarifications CMS offers that soften it:

• Staff don’t have to be physically in the building. Remote work is fine, provided the clinical staff are under general supervision of the billing practitioner and the “incident to” requirements at 42 CFR 410.26 are met.
• The beneficiary doesn’t have to be on-site. Obviously — but CMS says it, so it’s settled.

What the proposal targets is the arrangement where a clinic pays an outside company to perform monitoring and patient outreach on its behalf. Software your own staff use to deliver the service is a different arrangement from outsourcing the service itself — the proposed rule text addresses who furnishes the service, not what tools they use. One open question worth flagging: CMS’s language requires clinical staff to be “a direct employee of the practitioner or the practitioner’s practice,” which raises a question for clinics staffed with contracted or PRN therapists and assistants. CMS doesn’t address that scenario. If it describes your clinic, it’s worth a comment.

Is CMS proposing to cut RTM payment?

It’s proposing to revalue the codes, and it says it believes they’re overvalued. The mechanism is a set of practice-expense crosswalks:

CMS’s stated reasoning is a data gap, not a judgment about clinical value: it has “received very little invoice or pricing information from interested parties for the specific devices used in RTM and RPM services,” and believes the typical device “may not be accurately captured in the data previously used for valuation.” It is explicitly asking for pricing evidence — “not just their associated costs and invoices, but robust evidence detailing what providers are actually paying for these devices, including discounts or other typical pricing details,” and whether those costs “include software, hardware, or both.”

That request is the opening. The valuation rests on an absence of data, which means data submitted before September 14 is unusually likely to matter. A clinic that can document what it actually pays for its RTM platform is exactly the interested party CMS says it hasn’t heard from.

The conversion factor moves too

There’s a second, separate downward pressure that applies to every code you bill, not just RTM. Payment under the fee schedule is RVUs multiplied by a conversion factor, and CMS proposes cutting it.

There are two conversion factors. The one behind the RTM rates we publish is the nonqualifying APM conversion factor — the rate for clinicians who aren’t qualifying participants in an Advanced Alternative Payment Model. (98977’s 1.54 RVUs × $33.4009 produces its $51.44 national rate.) It applies unless your practice is an Advanced APM participant. CMS proposes taking it from $33.4009 to $32.8409, a decrease of $0.56, or −1.68%. (The qualifying APM conversion factor, for practices that are Advanced APM participants, goes from $33.5675 to $33.1693.)

The driver is statutory: the Working Families Tax Cut legislation gave the fee schedule a one-year 2.50% increase for 2026 only, and it expires. Current law therefore requires a −2.50% reduction against 2026, partly offset by the statutory update and a positive budget-neutrality adjustment.

So RTM faces two independent downward pressures for 2027: the code-specific practice-expense revaluation above, and this across-the-board conversion factor cut. They compound. That’s the honest framing — and also why single-code projections floating around right now are unreliable, since most of them account for one and not the other.

We’re not publishing projected 2027 rates, and you should be skeptical of anyone who does right now. Proposed valuations change between the proposed and final rule, and 2026 was a live demonstration of how badly published RTM figures can go wrong — a widely repeated 98977 rate turned out to be read off a superseded addendum. Rates for 2027 will be knowable when CMS releases the final rule and the accompanying relative value files, and not before. Until then, 2026 rates govern; verify yours on the CMS fee schedule search.

What would collapsing 17 codes into four do?

This is the item with the largest consequences for therapy clinics, and it’s the least far along. CMS is “considering, and seeking comment on” bundling all 17 RPM and RTM codes into four HCPCS G-codes. Two would cover RTM:

• GRTM1 — RTM initial setup and patient education.
• GRTM2 — remote monitoring of therapeutic parameters, per calendar month, including device supply, 2 or more days of data transmission, and treatment management of at least 20 minutes with at least one real-time interactive communication.

Read GRTM2’s elements carefully, because CMS states that “as drafted, all service elements outlined in the G-code descriptors would be required each calendar month.” Three consequences follow, and they cut in opposite directions:

1. The 16-day threshold would disappear, replaced by a 2-day minimum. For pediatric clinics — where the parent is the logger and the 16-day bar is the hardest one to clear — that is a significant loosening.
2. The two-clock problem would disappear. Device supply currently runs on sequential fixed 30-day periods from the RTM start date while management runs on the calendar month; the drift between them is a reliable source of billing errors. GRTM2 puts everything on the calendar month.
3. But the cliff would come back, in a harder form. Today, a month with plenty of logged days but only 14 minutes of review still pays a device-supply code and 98979. Under a single bundled monthly code requiring all elements, a month that misses the 20-minute mark or the live communication would pay nothing at all — including for device supply that was genuinely furnished.

That third point deserves emphasis, because it runs directly against the direction CMS took last year. The 2026 rules were built to end all-or-nothing RTM billing; the partial-period codes exist precisely so that a near-miss month isn’t a zero. A bundled monthly G-code requiring every element would reinstate an all-or-nothing structure — with the failure point moved from patient behavior to clinician time. For a clinic, the operational consequence is that review time becomes the single point of failure for the entire month’s reimbursement.

None of this is proposed regulatory text yet. But CMS says it “could finalize payment for these codes” after considering comments, so it is a live possibility rather than an idle question.

What should your clinic do before September 14?

Operationally, nothing — and that’s the most important sentence in this post. Keep billing 2026 rules exactly as they stand. The failure mode we’d worry about is a clinic reading proposed-rule coverage and preemptively changing or pausing a compliant program.

What’s worth doing:

• Comment, especially on valuation. CMS said outright that it lacks pricing data and asked for it. Comments are due September 14, 2026, on file code CMS-1848-P — submit through the docket on regulations.gov. A short factual submission about what your clinic actually pays for its RTM platform addresses the exact gap CMS identified — and pricing evidence for therapy software is precisely what a rule written largely around physician-office RPM devices is least likely to receive.
• Check your staffing model against the employment proposal. If any part of your RTM workflow is performed by contracted staff or an outside company, that’s the arrangement most likely to require a change on January 1.
• Note where enrollment happens. If patients are enrolled between visits rather than at one, the initiating-visit proposal would move that step.
• Don’t rebuild projections yet. Any 2027 revenue model built on proposed valuations will be rebuilt in November.

We’ll update this post when the final rule publishes, expected in early November 2026.

For the rules currently in force, start with RTM CPT codes explained and the 2026 changes, or see which disciplines can bill RTM. The full picture, including a rate estimator for your clinic’s volume, is in our RTM guide. If you want the tracking layer that makes the 2026 thresholds — and whatever replaces them — automatic rather than manual, talk to us about Sulo.