October 20, 2026
Most clinics evaluating remote therapeutic monitoring ask what the software does. Fewer ask what the people do, which is strange, because the people are what Medicare is paying for.
Here is what a licensed virtual monitoring team actually does in a week, why the model exists, and what the CY2027 proposed rule would do to it.
What the work actually is
Start with the billing requirement, because it defines the job. CPT 98980 requires at least 20 minutes of treatment management time in a calendar month and at least one interactive communication with the patient or caregiver. Not a push notification. A real conversation.
So the work breaks into four things.
Reviewing data. Someone opens the dashboard and looks at who logged exercises, who reported higher pain, who has not opened the app in nine days. On a panel of 60 patients this is a daily pass, not a monthly one, because the point is catching drift early.
Calling patients. This is the part clinics underestimate. It is not one call per patient per month. It is one connected call per patient per month, which is a different number. Some patients answer on the first try. Many do not.
Documenting. Time logged with dates and activities, the interactive communication recorded with mode and participant, day counts that match what the platform captured. Most RTM denials trace back to this, not to clinical judgment.
Escalating. Flagging the patient whose pain is climbing or whose function is regressing back to the treating therapist, so a human decides whether they need to come back in.
Why the model exists at all
Because the arithmetic is unforgiving. Sixty patients at 20 minutes is 20 hours a month before documentation. A hundred patients is 33 hours. That is most of a full-time position, and it lands on a clinic that is already fully booked.
The virtual team model exists because buying those hours was cheaper and faster than hiring them, and because the hours are lumpy. You need more in a growth month and fewer in a slow one, and a part-time employee does not flex that way.
What a good team looks like versus a call center
This distinction matters more than any software feature.
The people doing the calling should be licensed. Our team are PTAs and COTAs, which means they can have a clinical conversation rather than a scripted one. When a patient says the exercise makes their shoulder catch, a licensed clinician knows whether that is normal adaptation or a reason to stop.
They should be consistent. The same person calling the same patient month over month builds the relationship that produces adherence. A rotating queue does not.
And they should escalate quickly rather than manage around a problem. The virtual team is not a substitute for the treating therapist’s judgment. It is a way to notice sooner that judgment is needed.
The honest part about 2027
CMS has proposed that Medicare pay for RTM monitoring only when the clinical staff performing it are direct employees of the billing practice. If finalized, that would make the model described above unpayable for Medicare patients starting January 1, 2027. Here is the full breakdown of the proposal.
I run a company that provides this service, so read the rest with that in mind.
The proposal comes from real concerns. The HHS Office of Inspector General has raised questions about oversight in remote monitoring and about arrangements where it is unclear who performed the service. Those concerns are legitimate. I think the remedy is broader than the problem, and I think disclosure, supervision standards and per-minute attribution would reach the bad actors without eliminating the delivery model. That is what we are saying in our comment.
But I am not going to tell you the proposal will not be finalized, because I do not know that.
What this means for your clinic
If you are evaluating a virtual monitoring team right now, ask what happens to your program on January 1 under both outcomes, and get the answer in writing. Any vendor who tells you the rule definitely will not pass is selling you certainty they do not have.
If you already use one, start the in-house contingency now rather than in November. Hiring and training a coordinator into a compliance-sensitive role takes longer than the eight weeks between the final rule and the effective date.
And whichever way this lands, the underlying question does not change. Someone has to do the twenty minutes. The only real decision is whether you buy those hours or hire them.
Comments on the proposed rule closed September 14. It is Federal Register document 2026-14327.
If you want to talk through what your program looks like under either outcome, request a demo and we will model it with your actual numbers. The RTM calculator will show you the staffing math on its own if you would rather start there.