October 13, 2026
Every conversation I have had about the CY2027 proposed rule ends at the same place. If Medicare stops paying for outsourced monitoring, what does that actually do to the money?
Here is how to answer it for your own practice, using arithmetic rather than a vendor’s projection.
Start with minutes, not dollars
RTM revenue is a function of billable events, and the binding constraint on billable events is clinical time. So start there.
CPT 98980 requires at least 20 minutes of treatment management time in a calendar month plus one interactive communication with the patient or caregiver. The device supply codes require days of transmitted data, which the platform tracks on its own, but the management codes require a person.
Take your enrolled patient count and multiply by 20 minutes. A practice with 60 active RTM patients needs 1,200 minutes a month before anyone writes a note. That is 20 hours. At 100 patients it is 33 hours. Add documentation, add the second call to the patient who did not pick up, and the honest figure is meaningfully higher than the arithmetic minimum.
That number is the same under every version of this rule. What changes is who is allowed to supply those hours and what they cost you.
The two cost structures
Under a contracted model you buy the hours. The cost is variable, scales with enrollment, and is usually expressed as a share of collections. Your exposure is limited because if the patient generates nothing, you generally pay nothing.
Under an in-house model you hire the hours. The cost is fixed, does not scale down when enrollment dips, and arrives whether or not the claims get paid. Your upside per patient is higher because you are not sharing collections.
The proposal would remove the first option for Medicare patients. So the question is not which model is better in the abstract. It is what the second model costs you specifically. MovementRx sells the contracted model, so understand that I have a commercial interest in this argument and check the arithmetic yourself.
Do this calculation
Take your loaded hourly cost for whoever would perform monitoring. Loaded means wage plus payroll taxes plus benefits plus the share of overhead that person carries, not their hourly rate. Most practices underestimate this by a third.
Multiply by the monthly hours you calculated above. That is your fixed monthly cost to run RTM in-house.
Now pull your actual RTM collections for the last three months from your billing system, not a projection. Divide by three for a monthly average.
Subtract. That difference is what RTM is worth to you under the in-house model, and it is the only number in this whole debate that matters to your practice.
Run it again at seventy percent of your current enrollment, because that is roughly where programs land when the person doing monitoring also has other responsibilities.
What the answer usually looks like
For practices above a certain enrollment, in-house wins. The fixed cost gets spread across enough patients that the per-patient economics beat a revenue share, and you keep all the collections.
Below that threshold it inverts. A part-time person costs the same whether they monitor 20 patients or 60, and at 20 the fixed cost eats the margin.
Where exactly that threshold sits depends on your loaded cost and your payer mix, which is why I am not going to give you a number. Anyone who gives you one without asking about your payer mix is guessing.
The part nobody models
There is a second cost that does not appear in the arithmetic, and it is the one that actually kills programs. Hiring takes time. Training a coordinator on RTM documentation takes longer. If the final rule lands November 1 and takes effect January 1, that is eight weeks to recruit, hire and train someone into a compliance-sensitive role over the holidays.
Practices that start the conversation now will be fine. Practices that wait for the final rule will spend Q1 running a program nobody has time to run, which is the failure mode that produces month three.
What this means for your clinic
Do the minutes calculation this week. It takes ten minutes and it is the input to every other decision.
Get your real RTM collections rather than working from projections. The gap between the two is usually instructive on its own.
If the in-house number works, start the hiring conversation now rather than in November.
If it does not work at your current enrollment, your options are to grow enrollment before January or to accept a smaller program. Possibly both.
The comment window on the proposed rule closed September 14. The filing is Federal Register document 2026-14327 if you want to read what CMS actually proposed.
If you want the calculation done with you rather than by you, request a demo and we will build it from your actual volume and payer mix. The RTM calculator will get you a directional answer in a couple of minutes if you would rather see the shape of it first.