CMS's proposed 2027 Physician Fee Schedule (CMS-1848-P) has sparked an important conversation about the future of remote patient monitoring (RPM) and remote therapeutic monitoring (RTM) reimbursement and program design under Medicare.
Released July 14, 2026, CMS-1848-P proposes several changes to RPM and RTM, including limiting reimbursement for clinical staff to those directly employed by the billing practice, requiring an initiating visit, limiting RTM to established patients, and revaluing certain services. CMS is also seeking feedback on potential changes to the existing RPM and RTM coding structure.
CMS's proposals are intended, in part, to strengthen oversight and program integrity. Smart Meter agrees that accountability matters. The question is how best to achieve it without unnecessarily restricting the care models providers use to deliver remote monitoring. We believe there is a better path forward.
Here are three guardrails Smart Meter recommends in place of the proposed rules to help build a healthier, more accountable RPM industry.
1. A CMS-Managed Certificate Program for RPM
Smart Meter recommends a standardized certificate program managed by CMS to help establish consistency across the RPM industry. The goal should be to ensure a consistent standard of RPM delivery, an effective patient experience, and a rewarding path for providers.
Rather than focusing primarily on how a provider structures its workforce or whether clinical services are delivered by an employee or qualified partner, a certification framework could focus on whether the program itself meets established expectations for quality, patient support, and service delivery.
A strong RPM program should be measured by how well it serves patients and supports providers.
2. Annual Data Audits Focused on Accountability
Accountability should be based on what RPM programs are actually delivering. Smart Meter recommends annual audits of RPM data with a focus on patient adherence, clinical efficacy, and outcomes.
This would give CMS greater visibility into program performance and provide a clearer way to identify programs that are delivering meaningful patient care versus those that may not be meeting appropriate standards.
The focus should not be on who employs the clinical staff. It should be on whether patients are engaged, whether the service is being delivered effectively, and whether the program is contributing to better health outcomes.
This approach also responds directly to concerns raised by the HHS Office of Inspector General, which has called for additional safeguards and oversight of RPM.
3. Reimbursement That Matches the Actual Work Being Done
RPM requires more than sending a device to a patient's home. Successful programs involve collecting and reviewing patient readings, dedicating clinical time, reporting and documenting care, engaging patients, and working toward measurable improvements in health.
Smart Meter believes reimbursement should reflect the actual work involved in delivering those services. A reimbursement model that accounts for readings, clinical time, reporting, and health improvement measures would better align payment with the care being provided. It would also encourage providers and RPM organizations to focus on the outcomes and engagement that matter most.
Why We Believe This Approach Is Better
Remote patient monitoring has grown significantly, and the industry should be held to meaningful standards for quality, accountability, and patient care. But those standards should focus on what a program delivers, not simply how it is structured.
A CMS-managed certification program could establish clear expectations before a program begins. Annual data audits could provide ongoing accountability. And reimbursement tied to the work actually performed could create a stronger connection between payment, patient engagement, and outcomes.
Together, these guidelines would give CMS more meaningful visibility into the quality and effectiveness of RPM programs while allowing providers flexibility in how they structure care, encouraging the industry to improve rather than simply comply.
The Proposal Is Still Open for Comment
The 2027 Physician Fee Schedule is not final. CMS is accepting public comments on CMS-1848-P through September 14, 2026, giving providers, vendors, professional organizations, patients, and other stakeholders an opportunity to share their perspectives.
This comment period is an opportunity for the industry to help shape a framework for RPM that promotes accountability without creating unnecessary barriers to care.
Frequently Asked Questions
Is the CMS 2027 RPM and RTM rule final?
No. CMS-1848-P is a proposed rule. Current RPM and RTM billing requirements remain in effect through the end of 2026.
When is the CMS comment deadline?
Public comments on CMS-1848-P are due September 14, 2026.
What changes is CMS proposing for RPM and RTM?
Among other provisions, CMS is proposing requirements related to clinical staff employment, initiating visits, established-patient status for RTM, and the valuation of certain RPM and RTM services. CMS is also seeking feedback on potential changes to the existing coding structure.
What is Smart Meter recommending?
Smart Meter recommends three guidelines for a healthier RPM industry:
- A CMS-managed certificate program to establish consistency in RPM delivery, support an effective patient experience, and create a rewarding path for providers.
- Annual audits of RPM data focused on adherence, efficacy, and outcomes.
- Reimbursement that reflects the actual work involved in delivering remote monitoring, including readings, clinical time, reporting, and health improvement measures.
What happens next?
CMS will review public comments before issuing the final 2027 Physician Fee Schedule, expected in Fall of 2026. Any finalized changes would take effect January 1, 2027.
Learn More
CMS 2027 Physician Fee Schedule Proposed Rule: View the CMS fact sheet
CMS Physician Fee Schedule: View CMS's Physician Fee Schedule page
OIG: Additional Oversight of Remote Patient Monitoring in Medicare Is Needed: Read the OIG report
OIG: Billing for Remote Patient Monitoring in Medicare: Read the OIG billing report
