The 2027 Medicare Physician Fee Schedule Final Rule: What It Means for Remote Monitoring and Care Management
CMS has finalized the CY 2027 Medicare Physician Fee Schedule, and for remote care programs the final rule is gentler than the July proposal. Three decisions matter most:
- Treatment management was spared. CMS dropped its proposal to strip clinical staff time out of remote monitoring treatment management.
- The staffing rule was delayed. The requirement that RPM and RTM time come from clinical staff employed by the practice now starts January 1, 2029, not 2027.
- The initiating visit is coming as planned. New Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) starts need an initiating visit beginning January 1, 2027.
Chronic Care Management (CCM), Principal Care Management (PCM) and Advanced Primary Care Management (APCM) codes are unchanged.
The final rule (CMS-1848-F) went on public inspection at the Federal Register on November 4, 2026, with publication scheduled for November 9, 2026. Page numbers in this post refer to the public inspection copy. Percent changes are drawn from the final rule's relative value file (Addendum B), national non-facility, for practices that are not Qualifying Alternative Payment Model (APM) Participants. National dollar amounts for each code are in the 2027 rates tables below.
What changed between the July proposal and the final rule
Most of the remote monitoring package was finalized as proposed. The items below moved, ordered by their impact on a practice running a remote care program.
| July 2026 proposal | Final rule | Pages |
|---|---|---|
| Remove clinical staff practice expense from RPM and RTM treatment management (99470, 99457, 99458, 98979, 98980, 98981) | Not finalized. CMS agreed clinical staff are often used in treatment management; 99470 lands about 28% above the proposed value | 297 |
| Count RPM and RTM time only from clinical staff employed by the practice, starting January 1, 2027 | Finalized, effective January 1, 2029. Third-party clinical staff allowed through December 31, 2028 when all "incident to" rules are met | 290–291 |
| Require an initiating visit before RPM or RTM begins | Finalized as proposed, with clarifications on existing patients, timing and telehealth | 279–285 |
| Revalue Collaborative Care (CoCM) and APCM behavioral health add-ons on a blended level 3 and 4 visit basis | Finalized higher, on a level 4 visit basis | 317 |
| Comment solicitation on bundling 17 remote monitoring codes into four G-codes | Not finalized; held for possible future rulemaking | 301 |
| Revalue device supply and set-up | Finalized as proposed, with the statutory phase-in | 296 |
| Conversion factor | Finalized less than 1% below the proposal, after budget neutrality swung from positive to negative | 1971–1972 |
Treatment management: the reversal that matters most
Treatment management is where the clinical work in remote monitoring happens: reviewing readings, talking with patients and escalating to the provider. In July, CMS proposed removing clinical staff practice expense from these codes. The final rule reverses that: "we agree with commenters that clinical staff are often used when furnishing treatment management services for remote physiologic and remote therapeutic monitoring" (p. 297).
Work values hold at 0.31 for 99470 and 0.61 for 99457 and 99458 (pp. 447–448).
- Against the proposal: 99470 lands about 28% higher than CMS proposed, 99457 about 4% higher and 99458 about 2% higher.
- Against 2026: treatment management is roughly flat. 99470 rises about 2%, while 99457 and 99458 dip by less than 1%.
Who can furnish RPM and RTM time in 2027, 2028 and 2029
CMS finalized the rule that RPM and RTM clinical staff time must come from a direct employee of the practitioner or practice, but pushed the start to January 1, 2029. CMS described it as "a 2-year delay in implementation to allow for practices to hire and train staff" (p. 290). Until then, time from third-party clinical staff remains billable as long as all existing "incident to" and other billing rules are met (p. 291).
Three details should shape planning:
- Oversight matters now. Where there is "little oversight by the billing practitioner or a lack of clinical integration" between a third party and the practice, CMS says the practitioner should not bill remote monitoring (p. 291). Escalation records, practitioner acknowledgment and care plan approval carry weight in 2027 and 2028.
- Guidance comes before 2029. CMS will issue sub-regulatory guidance on "clinical staff arrangements that may be appropriate for remote monitoring services" before the requirement takes effect (p. 291).
- Technology stays open to outside partners. "Practices may obtain devices, software, connectivity, data hosting, cybersecurity, implementation support, technical assistance, and interoperability services from outside companies" (p. 287). General supervision and the regulation at 42 CFR 410.26 are unchanged (pp. 287–288).
Whether a practice runs monitoring with its own clinical staff or works with an outside clinical team that operates as an extension of the provider, nothing in the final rule changes RPM or RTM staffing on January 1, 2027. The work for the next two years is documenting oversight and clinical integration, and preparing for the 2029 requirement.
The initiating visit: remote care starts with the provider
Beginning January 1, 2027, Medicare requires a separately reportable initiating visit before RPM or RTM can begin. At that visit, in person or by telehealth, the billing practitioner must discuss monitoring with the patient and assess whether it is clinically appropriate. A routine visit where monitoring never comes up does not qualify, and monitoring cannot be billed before the visit takes place (pp. 279–281). CMS also frames the visit as the opportunity to obtain the patient's consent (p. 279).
The intent is clear: CMS wants remote patient monitoring to begin with the patient's own provider, face to face. (Sources: the CMS fact sheet, the final rule, Federal Register document 2026-22743, and AHA News, November 4, 2026.)
The final rule answers the questions practices raised during the comment period:
- Patients already on monitoring. Beneficiaries receiving remote monitoring before January 1, 2027 do not need an initiating visit to continue, provided every other requirement is met. CMS also "discourages any misuse of enrolling beneficiaries in remote monitoring services between the publication of this rule and January 1, 2027" (p. 285). Enrollment should continue in the normal course of care.
- Timing. CMS set no limit on the gap between the visit and the start of monitoring, as long as RPM or RTM was discussed at that visit (pp. 281–282).
- Telehealth. The initiating visit may be furnished by telehealth under section 1834(m) of the Social Security Act. After December 31, 2027, absent new legislation, the remaining 1834(m) limits apply (p. 282).
- Purpose of the visit. The visit does not need to be about remote monitoring alone; it needs to include the discussion (p. 283).
- Routine changes. A device change, a clinical change, or a change of billing practitioner within the same practice does not trigger a new initiating visit (p. 284).
- RTM and established patients. RTM is now limited to established patients, matching RPM. A beneficiary counts as established once the initiating visit requirements are met (p. 279).
The compliance work lives in the workflow. The provider raises monitoring during the visit and the patient gives verbal consent. Record that consent explicitly in the plan of care, for example: "Verbal consent obtained and remote monitoring requirements reviewed with the patient." The visit note should also show that monitoring was discussed, because that discussion is what makes it the initiating visit.
Enrollment paths that work under the initiating visit rule
The rule changes how RPM starts, not who can offer it. Practices can keep the enrollment path that fits their team, as long as every new RPM start from January 1, 2027 runs through a visit with the billing practitioner.
- Point-of-care enrollment. An EHR prompt reminds the provider to raise remote care during the visit, so enrollment begins where the provider already works.
- In-office enrollment by the clinic team. The provider discusses RPM at the visit, and the clinic team enrolls the patient before they leave.
- Referral after the visit. The provider discusses RPM and sends a referral (for example, by digital fax). The referral should show the visit date, whether the visit was in person or by telehealth, the billing practitioner, and that RPM was discussed.
- Remote enrollment by a care team. After a visit where the provider discussed RPM, care team staff enroll the patient remotely and handle device setup and education. Care team staff cannot hold the initiating visit themselves. Remote enrollment for CCM continues under existing CCM rules.
RPM device supply and set-up payment in 2027
Device supply and set-up payment falls in 2027: 99454 and 99445 pay about 21% less than in 2026, and 99453 about 8% less. CMS finalized the revaluation as proposed. RPM device supply (99445 and 99454) now takes its direct practice expense inputs from 99474, RTM device supply from 93270, and set-up (99453 and 98975) from 99473 (p. 296).
CMS phases large cuts in over more than one year (p. 296). By statute, the one-year cut to an existing code's relative value is capped at 19%. The lower 2027 conversion factor applies on top of that cap, which is why 99454 and 99445 come in about 21% lower in dollars.
More reductions are likely:
- CMS's final phase-in file lists 99454 and 99445, so further cuts are expected after 2027.
- The American Medical Association told CMS that all 19 RPM and RTM codes will have their practice expense reviewed at the January 2027 RUC meeting. CMS said it will review that information for future rulemaking (p. 296).
- The two RTM cognitive behavioral therapy device codes, 98978 and 98986, move to national pricing at the same practice expense value as 98977 (pp. 296–297).
The trend is clear: device supply carries less of a program's revenue each year, and the clinical work carries more. Every code also moves with the conversion factor, which falls 2.31% from 2026 for practices that are not Qualifying APM Participants (pp. 8, 1972). Current 2026 rates apply through December 31, 2026.
CCM, PCM and APCM in 2027
The care management code structure does not change for 2027. In July, CMS asked whether to consolidate the care management "family" or split it into a technology-first track and a traditional track. In the final rule, CMS reports that commenters "largely did not agree" with differentiating care management by technology, and most said aligning requirements matters more than reducing the number of codes. CMS will weigh the comments in future rulemaking (pp. 514–518).
Payment moves mostly with the conversion factor: 99490 falls about 4%, 99439 about 2%, and the APCM codes G0556, G0557 and G0558 about 2%.
Two items do move for primary care teams running APCM:
- Behavioral health add-ons rise. APCM add-ons G0568 and G0569 and CoCM codes 99492, 99493 and 99494 were revalued on a level 4 visit basis, higher than proposed. G0568 rises about 50% from 2026 and G0569 about 25%. G0570 was not revalued (pp. 317–318). CMS also notes that alcohol use disorder management "may qualify" under the APCM behavioral health add-on when all requirements are met (pp. 318–319).
- A signal on direction. CMS writes that it does "not view APCM as the end goal of primary care payment reform" (p. 532). Commenters on a related request for information called APCM a natural starting point for a monthly primary care payment (pp. 547–548).
2027 national payment rates by code
Device supply codes lose about $11 per patient per month in 2027, treatment management holds near 2026 levels, and behavioral health add-ons rise sharply. Rates below are 2027 total RVUs from Addendum B multiplied by the $32.63 conversion factor: national, non-facility, for practices that are not Qualifying APM Participants. The 2026 column uses CMS's current 2026 relative value file (RVU26D, August 2026). Local rates vary with geographic adjustment, and amounts may shift by a cent once CMS publishes the full-precision conversion factor.
Remote Patient Monitoring (RPM)
| Code | Service | 2026 | 2027 | Change |
|---|---|---|---|---|
| 99453 | Set-up and patient education | $21.71 | $19.90 | −8.3% |
| 99445 | Device supply, 2–15 days | $52.11 | $41.11 | −21.1% |
| 99454 | Device supply, 16–30 days | $52.11 | $41.11 | −21.1% |
| 99470 | Treatment management, first 10 min | $26.05 | $26.43 | +1.5% |
| 99457 | Treatment management, first 20 min | $51.77 | $51.56 | −0.4% |
| 99458 | Treatment management, each additional 20 min | $41.42 | $41.11 | −0.7% |
Remote Therapeutic Monitoring (RTM)
| Code | Service | 2026 | 2027 | Change |
|---|---|---|---|---|
| 98975 | Set-up and patient education | $21.71 | $19.90 | −8.3% |
| 98976 / 98984 | Device supply, respiratory (16–30 / 2–15 days) | $52.11 | $41.11 | −21.1% |
| 98977 / 98985 | Device supply, musculoskeletal (16–30 / 2–15 days) | $51.44 | $40.79 | −20.7% |
| 98978 / 98986 | Device supply, CBT (16–30 / 2–15 days) | Contractor-priced | $40.79 | Newly national |
| 98979 | Treatment management, first 10 min | $26.39 | $26.76 | +1.4% |
| 98980 | Treatment management, first 20 min | $54.11 | $54.17 | +0.1% |
| 98981 | Treatment management, each additional 20 min | $41.42 | $41.77 | +0.8% |
Chronic Care Management (CCM)
| Code | Service | 2026 | 2027 | Change |
|---|---|---|---|---|
| 99490 | Clinical staff, first 20 min | $66.13 | $63.63 | −3.8% |
| 99439 | Clinical staff, each additional 20 min | $50.44 | $49.60 | −1.7% |
| 99491 | Physician, first 30 min | $89.18 | $85.49 | −4.1% |
| 99437 | Physician, each additional 30 min | $63.13 | $60.37 | −4.4% |
| 99487 | Complex CCM, first 60 min | $144.29 | $140.64 | −2.5% |
| 99489 | Complex CCM, each additional 30 min | $78.16 | $76.35 | −2.3% |
Principal Care Management (PCM)
| Code | Service | 2026 | 2027 | Change |
|---|---|---|---|---|
| 99424 | Physician, first 30 min | $87.51 | $83.86 | −4.2% |
| 99425 | Physician, each additional 30 min | $61.46 | $59.71 | −2.8% |
| 99426 | Clinical staff, first 30 min | $67.80 | $66.57 | −1.8% |
| 99427 | Clinical staff, each additional 30 min | $54.11 | $53.84 | −0.5% |
APCM and behavioral health integration
| Code | Service | 2026 | 2027 | Change |
|---|---|---|---|---|
| G0556 | APCM level 1 | $16.37 | $15.99 | −2.3% |
| G0557 | APCM level 2 | $53.78 | $52.86 | −1.7% |
| G0558 | APCM level 3 | $117.24 | $114.86 | −2.0% |
| G0568 | APCM behavioral health add-on, initial month | $161.66 | $242.44 | +50.0% |
| G0569 | APCM behavioral health add-on, subsequent month | $145.96 | $183.05 | +25.4% |
| G0570 | APCM behavioral health add-on, care management | $57.78 | $57.76 | 0.0% |
| 99492 | CoCM, initial month | $160.32 | $246.68 | +53.9% |
| 99493 | CoCM, subsequent month | $144.96 | $181.75 | +25.4% |
| 99494 | CoCM, each additional 30 min | $61.46 | $86.80 | +41.2% |
What practices and RPM companies should do before January 1, 2027
- Build the initiating visit into the workflow. Decide how providers raise monitoring at the visit, how the note records the discussion, and how consent is obtained and written into the plan of care, both in person and by telehealth.
- Keep enrolling in the normal course of care. Existing patients are grandfathered, and CMS "discourages any misuse of enrolling beneficiaries" in remote monitoring between publication of the rule and January 1, 2027 (p. 285).
- Check oversight records. Escalations, practitioner acknowledgment and care plan approval should be visible in the chart for every monitored patient (p. 291).
- Rerun the device math. Device supply revenue drops in 2027 and keeps phasing down unless the January 2027 RUC review changes the inputs (p. 296).
- Keep care management moving. CCM, PCM and APCM rules did not change, and the direct employment requirement in the rule text applies to RPM and RTM codes.
- Evaluate your device supply. Rates for devices have dropped. Cellular devices are likely to provide strong longterm value. Consider a cost-effective device supplier like Continua.
For what CMS originally proposed, see the July 2026 proposed rule listed in the sources below.
Frequently asked questions
Is the 2027 Medicare Physician Fee Schedule final?
Yes. CMS filed the final rule (CMS-1848-F) for public inspection on November 4, 2026, with Federal Register publication scheduled for November 9, 2026. Most provisions take effect January 1, 2027.
Did CMS cut RPM treatment management for 2027?
No. CMS did not finalize its proposal to remove clinical staff practice expense from 99470, 99457 and 99458, and kept their work values. Compared with 2026, payment for those codes is roughly flat (p. 297).
Do current RPM patients need a new initiating visit?
No. Patients receiving remote monitoring before January 1, 2027 can continue without one, as long as all other requirements are met (p. 285).
Can the initiating visit be a telehealth visit?
Yes, when furnished under the Medicare telehealth rules in section 1834(m). The visit must be with the billing practitioner, and RPM or RTM must be discussed (pp. 281–282).
When does the direct employment requirement for RPM and RTM start?
January 1, 2029. Through December 31, 2028, third-party clinical staff time stays billable when all "incident to" rules are met, and CMS will first publish guidance on "clinical staff arrangements that may be appropriate" (p. 291).
How much does RPM device supply drop in 2027?
About 21% nationally for 99454 and 99445, from $52.11 to $41.11 per month, with further reductions phased in after 2027 unless the January 2027 RUC review changes the inputs (p. 296).
Did CMS create new bundled remote monitoring codes?
No. The four G-codes were part of a comment solicitation and were not finalized. The current CPT codes stay in place for 2027 (p. 301).
Do CCM, PCM or APCM have new requirements in 2027?
No. Code structure and requirements are unchanged. CMS collected comments on simplifying care management and will consider them in future rulemaking (pp. 514–518).
Questions about how the 2027 final rule affects your remote care program? Contact the Continua Systems team, and follow Continua Systems on LinkedIn for our weekly RPM news roundup.
Sources
- CY 2027 Payment Policies Under the Physician Fee Schedule final rule (CMS-1848-F), Federal Register public inspection document 2026-22743, filed November 4, 2026. Page numbers in this post refer to this copy.
- CMS-1848-F final rule page, CMS, displayed November 4, 2026; publication date November 9, 2026.
- CY 2027 PFS Final Rule Addenda, including Addendum B (relative value units), the source of the 2027 RVUs and rates in this post.
- RVU26D 2026 relative value file, CMS, updated August 26, 2026, the source of the 2026 rates in this post.
- Calendar Year (CY) 2027 Medicare Physician Fee Schedule Final Rule, CMS fact sheet, November 4, 2026, the source of the conversion factors.
- CMS issues CY 2027 physician fee schedule final rule, AHA News, November 4, 2026.
- CMS-1848-P: CY 2027 Physician Fee Schedule proposed rule, displayed July 14, 2026 and published July 16, 2026 (Federal Register document 2026-14327).