--- title: What CMS Has Proposed for RPM in 2027, Ahead of the Final Rule description: CMS's 2027 proposal would require employed staff and an initiating visit, lower device-supply payment and float new G-codes. What it means for RPM programs. --- [![Logo - Dark](https://continuasystems.com/hubfs/Logo%20-%20Dark.png)](https://continuasystems.com) - [Devices](https://continuasystems.com/4g-cellular-health-devices-for-remote-patient-monitoring-rpm) - [Software](https://continuasystems.com/remote-patient-monitoring-operations-software-and-api) - [Operations](https://continuasystems.com/4g-health-device-logistics-and-operations) - [Articles](https://continuasystems.com/connected-device-strategies-for-rpm) - [Devices](https://continuasystems.com/4g-cellular-health-devices-for-remote-patient-monitoring-rpm) - [Software](https://continuasystems.com/remote-patient-monitoring-operations-software-and-api) - [Operations](https://continuasystems.com/4g-health-device-logistics-and-operations) - [Articles](https://continuasystems.com/connected-device-strategies-for-rpm) [Free Sample](https://continuasystems.com/create-account-0) [Reimbursement](https://continuasystems.com/connected-device-strategies-for-rpm/tag/reimbursement) # What CMS Has Proposed for RPM in 2027, Ahead of the Final Rule [![](https://continuasystems.com/hs-fs/hubfs/Favicon-1.png?width=50&height=50&name=Favicon-1.png)](https://continuasystems.com/connected-device-strategies-for-rpm/author/continua-systems) [Continua Systems](https://continuasystems.com/connected-device-strategies-for-rpm/author/continua-systems) Nov 2, 2026, 10:50:13 PM **Status as of November 1, 2026: proposed, not final.** CMS is expected to publish the 2027 final rule in early November 2026. We'll update this post when it does. CMS's proposed 2027 Physician Fee Schedule, released July 14, 2026, would make the biggest changes to Medicare remote patient monitoring since the RPM codes were created. As proposed, only clinical staff employed by the billing practice could furnish billable monitoring, every patient would need a face-to-face initiating visit, and payment for device supply and setup would go down. CMS also asked whether to replace the 17 RPM and RTM codes with four monthly G-codes. Below is what CMS proposed, what it would mean for programs that run devices at scale, and what to do before January. ## The proposals at a glance | Area | Today (2026) | Proposed for 2027 | | --- | --- | --- | | Who can furnish monitoring | Clinical staff under general supervision, including contracted staff | Only direct employees of the billing practitioner or practice | | Before monitoring starts | Patient must be an established patient | Established patient plus a separately reportable, face-to-face initiating visit where RPM is discussed | | Device supply (99454, 99445) | Valued on CMS's original device cost estimates | Practice expense crosswalked to 99474, a self-measured blood pressure code, lowering payment | | Setup and education (99453) | Separately valued | Practice expense crosswalked to 99473, the self-measured blood pressure setup code | | Treatment management (99457, 99458, 99470) | Work plus practice expense | Separate practice expense removed; work values kept | | RTM | No established-patient requirement | Established patient required, same as RPM | | Code structure | 17 RPM and RTM codes | Comment request on four monthly G-codes (not a firm proposal) | All of this would take effect January 1, 2027, if finalized. The proposed 2027 conversion factor is also lower: $32.84 for most clinicians, down 1.68% from 2026, partly because a one-year 2.5% increase for 2026 expires. ## 1. Monitoring staff would have to be employees CMS proposed paying for RPM and RTM only when the clinical staff time comes from direct employees of the billing practitioner or practice. Staff would still work under general supervision and meet Medicare's incident-to rules, and they wouldn't need to sit in the practice's office. This is the proposal with the most direct business impact. Many practices run RPM through a service company that supplies monitoring nurses. Under the proposal, that time would no longer support a claim. CMS was explicit that practices could still buy devices, software and technology services from vendors. The change targets who does the clinical work, not who supplies the equipment. **What it means for device programs:** if your model depends on contracted clinical staff, you'll need a plan to move those roles onto the practice's payroll or restructure the arrangement. Device ordering, shipping, returns and data delivery can stay with a device partner either way. ## 2. An initiating visit before monitoring starts RPM already requires an established patient. The proposal adds a separately reportable initiating visit, face to face in person or by telehealth, furnished by the billing practitioner, in which remote monitoring is actually discussed. A visit that doesn't address RPM wouldn't count, and neither would a visit that isn't face to face or isn't separately payable. **What it means for device programs:** enrollment through outreach alone, where a device ships before the patient has talked with their clinician about monitoring, would no longer work. Build the visit into your enrollment flow, and time device shipments so the box arrives right after it, while the conversation is fresh. ## 3. Lower payment for device supply and setup CMS said it now believes remote monitoring devices may cost less than it originally estimated. It proposed revaluing the practice expense for device supply (99454 and 99445) and setup (99453) by tying them to lower-valued self-measured blood pressure codes. CMS also asked for data on what practices actually pay for devices, after discounts, and whether that price covers hardware, software or both. **What it means for device programs:** the gap between what Medicare pays for device supply and what the device really costs you is about to narrow. That makes total device cost per patient-month, not the unit price on a quote, the number to know. ## 4. A possible switch to four monthly G-codes CMS asked for comments on replacing the current RPM and RTM codes with four HCPCS G-codes. This was a request for comment, not a formal proposal, and CMS didn't publish payment values for the new codes. - **GRPM1:** RPM initial setup and patient education - **GRPM2:** monthly RPM, combining device supply, at least 2 days of transmitted data, at least 20 minutes of treatment management, and at least one real-time interaction with the patient or caregiver - **GRTM1:** RTM initial setup and patient education - **GRTM2:** monthly RTM, with the same 2-day and 20-minute minimums Every element would have to be furnished each calendar month to bill the monthly code. **What it means for device programs:** a 2-day minimum would make the 16-day threshold far less important. The harder requirement would be 20 minutes of management and a live interaction every month, for every patient. Devices that transmit reliably still matter, because readings give staff something to act on, but the billing risk would shift from missed days to missed conversations. ## 5. RTM gets the established-patient rule Remote therapeutic monitoring, used for things like therapy adherence and musculoskeletal or respiratory status, would require an established patient, as RPM already does. RTM device supply codes would also be revalued, tied to an external cardiac event recording code. ## Why CMS is doing this The proposals follow years of scrutiny from the HHS Office of Inspector General. OIG's 2024 report found that about 43% of Medicare enrollees who received RPM didn't receive all three components of the service: setup and education, device supply and treatment management. OIG also flagged inconsistent documentation, limited relationships between patients and the practices billing for them, and Medicare's limited visibility into how RPM is delivered. CMS cited those findings in explaining the employed-staff, initiating-visit and G-code ideas. ## What to do before January 1. **Map your staffing.** List everyone whose time supports RPM claims and whether they're a direct employee of the billing practice. 2. **Add the initiating visit to enrollment.** Decide which visit qualifies, who schedules it, and how device shipping lines up with it. 3. **Know your real device cost.** Add hardware, connectivity, shipping, returns and replacements, divided by months in service. 4. **Model both payment structures.** Run your numbers under today's codes and under a monthly code with a 2-day and 20-minute minimum. 5. **Check your adherence data.** How many patients transmit on 2 or more days a month, and how many on 16 or more? 6. **Keep the device side simple.** The proposal targets clinical staff time, not devices. A device partner can still handle ordering, shipping, returns and data. ## What happens next Comments closed September 14, 2026. CMS typically publishes the final Physician Fee Schedule in early November, and the final rule will say which proposals survive, whether the G-codes are adopted for 2027, delayed or dropped, and what the new payment amounts are. We'll update this post within 48 hours of its release. ## Frequently asked questions ### What changed for remote patient monitoring in the CMS 2027 Physician Fee Schedule final rule? As of November 1, 2026, CMS hasn't released the 2027 final rule. The July 2026 proposal includes some of the largest changes to RPM in years: monitoring by employed staff only, a required initiating visit, lower payment for device supply and setup, and a possible move to monthly G-codes. When the final rule is published, we'll replace this answer with what CMS actually adopted. ### What are the RPM CPT codes for 2027? Until CMS publishes its 2027 final rule, the codes in use are the 2026 set: 99453 (setup and education), 99454 (device supply, 16 to 30 days), 99445 (device supply, 2 to 15 days), 99457 (first 20 minutes of management), 99458 (each additional 20 minutes), 99470 (first 10 minutes of management) and 99091 (physician or qualified professional data review, 30 minutes or more). CMS has asked whether to replace them with four monthly G-codes, so check back after the final rule. ### What are the new RPM G-codes for 2027, and which CPT codes do they replace? There aren't any yet. In the 2027 proposed rule, CMS asked for comments on replacing the 17 current RPM and RTM CPT codes with four HCPCS G-codes: GRPM1 and GRTM1 for setup and education, and GRPM2 and GRTM2 for monthly monitoring. The monthly codes would combine device supply and treatment management, with minimums of two days of transmitted data and 20 minutes of management time, including a real-time interaction, each month. ### Is the RPM 16-day rule still in effect, and how many days of readings are required to bill in 2027? Partly. Since January 1, 2026, the 16-day rule is no longer all or nothing. CPT 99454 still requires readings on 16 to 30 days in a 30-day period, but 99445 covers patients with 2 to 15 days. For 2027, CMS has floated a monthly code with a two-day minimum. The final rule will settle it. ### What counts as a "day" of data for RPM billing? A day counts when the device records and transmits at least one reading that day. Several readings on the same day still count as one. The days don't have to be consecutive, and they're counted per 30-day period. Readings must be collected and sent by the device itself; manually entered values don't count. ### Can practices still use contracted (third-party) clinical staff for RPM in 2027? Today, yes. Under the 2027 proposal, no: starting January 1, 2027, CMS would pay for RPM and RTM only when the clinical staff time comes from direct employees of the billing practitioner or practice. The staff wouldn't need to be on-site. The proposal targets clinical staff time, not device supply, so ordering, shipping and returns can still sit with a device partner. ### Is an initiating visit required before starting RPM? Today, RPM requires an established patient. The 2027 proposal goes further: a separately billable, face-to-face visit, in person or by telehealth, in which remote monitoring is discussed, would be required before RPM or RTM starts. Visits that aren't face to face, or aren't separately payable, wouldn't count. *Sources: [CMS fact sheet on the CY 2027 proposed rule](https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2027-medicare-physician-fee-schedule-proposed-rule); [the proposed rule in the Federal Register](https://www.federalregister.gov/documents/2026/07/16/2026-14327/medicare-and-medicaid-programs-cy-2027-payment-policies-under-the-physician-fee-schedule-and-other); analyses by [Wilson Sonsini](https://www.wsgr.com/en/insights/health-reimbursement-signals-cms-proposes-significant-changes-to-rpm-and-rtm-requirements.html) and [McDermott](https://www.mcdermottlaw.com/insights/remote-monitoring-at-a-crossroads-cms-proposes-sweeping-changes-in-response-to-oig-scrutiny/). This post is general information, not billing or legal advice.* Previous Post ###### [2026 Remote Patient Monitoring CPT Codes: What’s New and Why It Matters](https://continuasystems.com/connected-device-strategies-for-rpm/2026-remote-patient-monitoring-cpt-codes-whats-new-and-why-it-matters) [![Logo - White](https://continuasystems.com/hubfs/Logo%20-%20White.png)](https://continuasystems.com) The connected health device partner that you've been looking for. 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