September 1, 2026
Comments on the CY2027 Physician Fee Schedule close at 11:59pm Eastern on September 14. After that the record is closed and CMS writes the final rule, expected around November 1.
If you have a view on the proposal to stop paying for remote therapeutic monitoring performed by third-party clinical staff, this is the window. There is not another one.
I am going to make the case for commenting, explain what separates a useful comment from an ignorable one, and give you the structure we are using. Take any of it.
Why a short comment from a small clinic matters
CMS reads comments. Not every comment changes a rule, but the agency is required to consider them and to respond to significant issues in the final rule preamble. Comments describing concrete operational consequences carry more weight than comments expressing displeasure.
The remote monitoring industry will file long, well-lawyered comments. Those are useful. They are also easy for an agency to read as self-interested, which is exactly how I expect ours to be read.
What CMS does not have much of is the view from a five-therapist practice in a town of forty thousand, describing what happens to their patients on January 1 if the monitoring staff they contract with stops being payable. That is the gap you can fill, and it takes twenty minutes.
What makes a comment useful
Be specific about your own operation. Numbers beat adjectives. How many patients do you monitor, how many minutes a month does it take, who performs those minutes today, and what would you actually do if you could not buy them.
Address the agency’s stated concern rather than talking past it. CMS is responding to OIG findings about oversight and about who really performs monitoring services. A comment that ignores that reads as a complaint. A comment that says here is how supervision and documentation work in my arrangement, and here is a narrower way to reach the bad actors, reads as help.
Suggest an alternative. Blanket opposition gives the agency nothing to work with. Disclosure requirements, supervision standards, per-minute attribution of who performed the service, credential verification for contracted staff. Any of those target the fraud concern without eliminating the delivery model.
Say what happens to patients. This is a Medicare program. The strongest comments connect a payment rule to a beneficiary outcome, and you are the only person who can describe yours.
Be honest about your interest. If the change would cost you money, say so. Agencies discount comments that hide the ball. They do not discount ones that are upfront.
A structure you can use
Open with who you are, where you practice, and how long you have run RTM. Two sentences.
State your position on the specific proposal and identify it clearly. The direct-employee requirement for RPM and RTM clinical staff in the CY2027 PFS proposed rule.
Give your operational numbers. Patients enrolled, monitoring minutes per month, who performs them today.
Describe what you would do on January 1 under the proposal, honestly. If the answer is that you would stop offering RTM, say that.
Describe the effect on your patients.
Propose an alternative that addresses the oversight concern.
Close with your name, credentials and practice.
That is the whole thing. One page is fine. A comment does not get better past about eight hundred words.
Where to file
Comments go through the federal rulemaking portal at regulations.gov. Search for the CY2027 Physician Fee Schedule proposed rule, Federal Register document 2026-14327, and use the comment button. Reference the specific provision you are addressing so it routes correctly.
Do not email CMS. Do not post it on LinkedIn and assume that counts. It has to go in the docket.
Two things worth saying plainly
My interest here is obvious. We provide the kind of virtual monitoring team the proposal would make unpayable. Discount my argument accordingly and file your own comment based on your own operation rather than mine.
And this rule may be finalized anyway. Proposed rules become final rules more often than not. Commenting is worth twenty minutes. It is not a substitute for planning. Do both.
What this means for your clinic
Block twenty minutes before September 14. Write from your own numbers. File it in the docket.
Then go answer the harder question, which is who on your team would do the monitoring if you had to bring it in-house, and whether those hours actually exist on anyone’s schedule.
If you want help modelling that against your real patient volume, request a demo and we will build it with you. The RTM calculator will get you a rough answer in about two minutes if you would rather start there.