October 6, 2026
If you’ve been following the CMS proposed rule on remote therapeutic monitoring, you know the core worry. If it’s finalized as written, Medicare would stop paying for monitoring done by an outside vendor’s employees.
A lot of what you’re reading right now comes from companies with a stake in your decision. Some tell you to panic. Some tell you everything’s fine. Few give you a clear picture of your actual choices.
Here are the four real options. I’ll be honest about all of them, including the ones that have nothing to do with MovementRx. I own two PT clinics in Traverse City, Michigan and built the monitoring program that became MovementRx inside my own practice. I’ve been on a lot of calls with PT owners this year. I know what the questions sound like.
What about timing?
The rule isn’t final. CMS published it in July. The final rule is expected around November 1, and if it’s finalized as written, it takes effect January 1, 2027. If you use an outsourced vendor and your contract runs through year end, you have a window. The question is what you do with it.
What applies to everyone?
One point that often gets missed. The proposal includes an established-patient requirement and an initiating-visit requirement that apply no matter who does the monitoring. Even fully in-house programs would have to meet them. Read the final rule when it lands, whatever model you’re on.
Option one: wait and see
Some owners will hold off until the final rule drops. That’s reasonable if your model already fits the proposal. It’s risky if you depend on fully outsourced monitoring. The risk isn’t surprise. The rule has been public since July. The risk is January 1 arriving without enough time to hire, train and enroll patients on a new structure. If you wait, know exactly what you’ll do the day the rule drops.
Option two: run it with your own staff
Your licensed PTAs and COTAs are already on your payroll. On the staffing question, the proposal points this way. If you have clinical staff with real bandwidth, it’s the cleanest path.
The catch: most practices don’t have that bandwidth. One owner told me, “Time is my biggest constraint, I truly don’t have the time.” It’s the most common answer I hear. Monitoring means reviewing home program activity, monthly contact, documentation and flagging problems to the treating PT. That’s real time, and it lands on people who are already stretched. Force it onto a full schedule and you get low enrollment and spotty documentation.
Option three: stop the program
This is the right answer for some practices, and I want to say that clearly. If your Medicare volume is low, or the changes cost more disruption than the revenue is worth, stopping is a fair choice. The mistake is stopping without running the math. Plenty of owners assume the revenue is too small. Some of them are wrong.
Option four: put the monitoring person on your payroll and get outside help managing them
This is the option most owners haven’t heard about. The monitoring person is on your payroll, part time and hourly. They’re a licensed PTA or COTA working under the general supervision of your treating PT. That supervision is what makes it billable.
An outside partner, like MovementRx, handles recruiting, interviewing, training and scheduling so every hour goes to billable patient monitoring. You don’t pay for idle hours. You don’t recruit. You don’t manage their schedule.
The rule changes who signs the paycheck. It doesn’t change who does the job.
As I read the proposal, this fits what it asks for: a direct employee of the billing practice doing the monitoring. The partner’s job is to make that work without piling more onto the owner. The established-patient and initiating-visit requirements still apply here too.
How do you decide?
Ask yourself a few questions. Do you have licensed staff with real bandwidth? If yes, option two deserves a hard look. If not, you’re choosing between waiting, stopping, or option four. Does the revenue work at your patient volume? My next post walks through the numbers. And do you want to stay in but need a structure that fits the proposal? That’s what option four is for.
The practices that sort this out in October and November will be ready for January 1. The ones that wait until December will make rushed decisions.
I’m walking through every option at a free live session the week the final rule drops: the rule, what changed, and what each option looks like in practice. Save your spot for the free session.
Frequently asked questions
If the rule passes, can a PT practice still use an outside company for remote monitoring?
Yes, but the structure changes. As proposed, an outside company’s employees can’t do the monitoring and have Medicare pay for it. The practice’s own employees must do the work. An outside company can still handle recruiting, training, technology and scheduling.
Do the established-patient and initiating-visit requirements only apply to outsourced models?
No. As proposed, they apply no matter who does the monitoring.
What qualifications does the monitoring person need?
Monitoring is done by licensed clinical staff, usually a PTA or COTA, under the general supervision of a treating PT. The proposal doesn’t change that. It changes who employs them.
Can I start now and adjust after the final rule?
Yes. If you start with the monitoring person on your payroll, you’re already set up the way the proposal points on staffing. Factor the established-patient and initiating-visit requirements into how you enroll patients.
What if CMS changes the rule again later?
Medicare rules change. The strongest position is a program with real patient outcomes, solid documentation and a clinical structure that matches the rules as they stand.
Andrew Gorecki, PT, DPT