August 25, 2026
CMS published the CY2027 Physician Fee Schedule proposed rule on July 16. Buried in it is a change that would end the way a large share of remote therapeutic monitoring gets delivered in this country.
The proposal is short and blunt. Medicare would pay for RPM and RTM clinical monitoring only when the person doing the monitoring is a direct employee of the billing practitioner or that practitioner’s practice, working under general supervision, meeting the usual incident-to requirements. Clinical staff supplied by a third-party monitoring company would no longer count.
If that language survives to the final rule, it takes effect January 1, 2027.
I want to be direct about my own position before going further. MovementRx offers a full-service model where our licensed PTAs and COTAs perform the monitoring. This proposal is aimed squarely at arrangements like ours. I am not a neutral party. But the rule affects every clinic running RTM, not just the ones who buy from us, and most of the coverage I have read so far gets the details wrong.
What the rule actually proposes
Four changes matter for physical therapy.
The direct-employee requirement is the headline. Today a practice can contract with a monitoring company, bill under its own NPI, and remit a share of collections. Under the proposal that arrangement stops being payable. The monitoring minutes have to come from someone on your payroll.
The established-patient requirement is the one nobody is talking about, and I think it will break more programs. CMS proposes extending to RTM the rule that already applies to RPM, meaning the billing practitioner must have an established relationship with the patient before RTM begins. Read that against how most clinics actually enroll and you will find edge cases immediately.
The initiating visit requirement says practitioners must furnish a separately reportable visit in connection with the start of monitoring. For a clinic where the evaluation already happens in person, this is mostly a documentation change. For anyone enrolling patients remotely, it is a workflow change.
Then there is disclosure. CMS proposes requiring practices to report when a third-party vendor furnishes all or part of the RPM or RTM services being billed. That one is worth reading twice, because it tells you what CMS is actually worried about.
Why this is happening
The proposal did not appear out of nowhere. The HHS Office of Inspector General has spent the last two years raising concerns about growth and oversight in remote monitoring, and about billing arrangements where it is unclear who actually performed the service. CMS is responding to that.
Whether the response is proportionate is a separate question from whether it is coming. Comments close September 14. The final rule is expected around November 1.
What it would do to a real clinic
Run the arithmetic on a practice with 100 patients enrolled. CPT 98980 requires at least 20 minutes of clinical time in a calendar month plus one interactive communication. That is 2,000 minutes before anyone documents anything. Thirty-three hours. Add the documentation, add the patients who do not pick up the first time, and you are north of a full-time position.
Under today’s rules a practice can buy those hours. Under the proposal it has to hire them. Those are very different decisions, and the second needs lead time you will not have if you wait for the November final rule to start planning.
The honest answer about what to do now
Do not tear up your RTM program. This is a proposed rule, and proposed rules change. The comment period exists for a reason and the remote monitoring industry is going to use it hard.
Do start answering one question. If you had to bring monitoring in-house on January 1, who would do it? Name a person. Look at whether their hours actually exist. If the answer is that it would get absorbed, you already know how that ends, because it is the same answer that produces month-three failures under the current rules.
Read the established-patient and initiating-visit language against your own enrollment workflow now, while you have time to change it. Those two changes are less dramatic than the outsourcing ban and considerably more likely to survive.
What this means for your clinic
If you run monitoring in-house today, the outsourcing ban does not touch you, but the established-patient and initiating-visit requirements probably do. Check your intake process.
If you contract monitoring out, you have roughly four months to build a contingency. Start with the staffing math, not the vendor conversation.
If you are evaluating RTM for the first time, none of this is a reason to wait. The codes are not going away and the 2026 additions are still in force. It is a reason to weight staffing capacity heavily in whichever platform you choose.
We are filing a comment before September 14 and I will publish what we send. If you want to read the rule yourself, it is Federal Register document 2026-14327.
If you want to talk through what your staffing math looks like under either outcome, request a demo and we will build the scenario using your actual patient volume. If you would rather run rough numbers yourself first, the RTM calculator is free and does not ask for your email.