Remote Patient Monitoring has never been just a technology program. Behind every connected blood pressure cuff, pulse oximeter, weight scale, or therapeutic monitoring platform is an operating model that determines how patients are enrolled, who reviews their data, how clinical concerns are escalated, what gets documented, and whether the services provided meet Medicare billing requirements.

Now, the Centers for Medicare & Medicaid Services has proposed a policy that could fundamentally change how many Remote Patient Monitoring and Remote Therapeutic Monitoring programs operate.

Under the proposed Calendar Year 2027 Medicare Physician Fee Schedule, CMS would generally require clinical staff whose time is counted toward billable RPM or RTM services to be direct employees of the billing practitioner or the practitioner’s practice. If finalized, practices would no longer be able to count clinical staff time furnished through third-party companies toward Medicare RPM and RTM billing.

That may sound like a technical reimbursement update; however, it is more like a potential redesign of the workforce, workflows, vendor relationships, technology, documentation, governance, and economics supporting remote monitoring instead.

What Is CMS Proposing for RPM and RTM in 2027?

CMS currently allows certain RPM and RTM treatment-management services to be furnished by clinical staff under the general supervision of the billing practitioner, provided that all applicable Medicare requirements are met.

Many healthcare organizations have built their remote monitoring programs around third-party partners that help provide some combination of:

• Patient enrollment and onboarding
• Device setup and education
• Routine patient outreach
• Monitoring support
• Interactive patient communication
• Clinical data review
• Alert triage and escalation
• Time tracking and documentation
• Billing support
• Program administration

In the proposed rule, CMS states that it does not believe RPM or RTM services provided by clinical staff contracted through a third party necessarily ensure sufficient practitioner oversight, management, collaboration, or clinical integration.

CMS is therefore proposing that clinical staff time may be counted for Medicare RPM or RTM billing only when the staff member is a direct employee of the practitioner or the practitioner’s practice.

If finalized, the policy would take effect on January 1, 2027. Clinical staff could still work remotely, and patients would not need to be physically present at the practice. The central issue is the employment relationship—not the physical location of the employee or patient.

The proposal is part of the CMS CY 2027 Medicare Physician Fee Schedule Proposed Rule. CMS is accepting public comments through September 14, 2026.

This Is a Proposed Rule, Not a Final Rule

It is important to separate what CMS has proposed from what Medicare currently requires.

As of August 2026, this direct-employment requirement has not been finalized. CMS is actively requesting feedback on how frequently third-party clinical staff support RPM and RTM programs and how the proposed policy could affect access to remote monitoring services.

The language could change before the final rule is published. CMS could revise the requirement, add exceptions, clarify which activities are affected, or decide not to finalize the proposal as written.

Healthcare organizations should not treat the proposal as settled policy. They also should not wait until the final rule is released to evaluate their exposure.

If the rule is finalized for January 1, practices may have only a limited window to hire personnel, redesign workflows, renegotiate vendor agreements, update technology, and validate new billing controls. Waiting for certainty may create a different kind of risk: not having enough time to respond.

Why Is CMS Reconsidering Third-Party Clinical Staffing?

CMS’s proposal appears to be rooted in legitimate program-integrity concerns.

Remote monitoring has expanded significantly since Medicare began covering RPM services. That growth has created opportunities to manage chronic and acute conditions between office visits, but it has also created concerns about incomplete services, insufficient clinical involvement, aggressive enrollment, and inappropriate billing.

A 2024 review from the U.S. Department of Health and Human Services Office of Inspector General found that approximately 43% of Medicare enrollees who received RPM did not receive all three core components of the service. OIG recommended additional safeguards, greater billing transparency, provider education, and increased oversight of companies involved in RPM. CMS identifies three central components of Remote Patient Monitoring:

• Education and setup: The patient receives appropriate education on using the connected medical device and transmitting accurate data.
• Device supply and data transmission: An eligible internet-connected medical device collects and digitally transmits the required physiologic data.
• Treatment and management: The healthcare provider reviews the data and uses it to manage the patient’s condition.

CMS’s concern is that remote monitoring cannot become a disconnected service in which a third party collects data and communicates with patients while the billing practitioner maintains only a limited connection to the work. Medicare expects RPM and RTM to function as part of longitudinal, patient-centered care—not simply as device distribution, data collection, or outsourced patient outreach.

Why the Proposal Is an Operational Change?

Organizations sometimes approach regulatory updates as billing-department issues. That would be a mistake here. If a practice relies heavily on contracted clinical staff, replacing those services may affect nearly every layer of the program.

1. Workforce

Practices may need to determine whether they have enough internal clinical capacity to support their current patient population.

Bringing work in-house may require recruiting, onboarding, training, supervising, scheduling, credentialing, and retaining additional employees. That could be especially difficult for rural providers, smaller physician groups, and organizations already facing clinical staffing shortages.

2. Clinical Workflows

A remote monitoring workflow can include dozens of steps across enrollment, consent, device fulfillment, education, data review, outreach, escalation, clinical decision-making, and documentation.

Organizations must understand which steps are performed by employed personnel, contracted clinical staff, technology vendors, or the billing practitioner. Without that visibility, it may be difficult to determine which services remain billable under a new model.

3. Financial Performance

Transitioning from outsourced staffing to direct employment could change:

• Labor costs
• Administrative expenses
• Program capacity
• Patient-to-staff ratios
• Reimbursement margins
• Vendor fees
• Technology costs
• Revenue-cycle processes
• Program break-even points

A program that works financially under one staffing model may not work under another.

4. Technology and Integration

Bringing clinical activities in-house does not eliminate the need for technology partners. It may increase the need for connected systems, automation, and operational visibility.

Internal teams will need efficient ways to manage patient rosters, incoming device readings, missed transmissions, abnormal results, outreach attempts, interactive communication, time thresholds, escalations, and documentation.

If those activities are spread across disconnected RPM platforms, electronic health records, spreadsheets, messaging tools, and billing systems, adding employees alone will not solve the underlying problem.

5. Vendor Relationships

The proposal does not necessarily mean practices must eliminate all remote monitoring vendors.

Technology platforms, connected-device providers, data-integration partners, implementation consultants, and vendors performing functions outside the affected clinical staff services may continue to play important roles. The exact boundaries will depend on the final rule, applicable code requirements, contractual arrangements, and legal guidance.

What could change is the ability to count time performed by third-party clinical staff toward Medicare billing. Practices should review each vendor’s responsibilities at the activity level instead of categorizing the entire relationship as simply “RPM support.”

6. Patient Access

Third-party support has enabled many organizations to launch and scale remote monitoring despite limited internal resources.

If practices cannot recruit enough direct employees or cannot operate the program economically, some may reduce enrollment or discontinue services. This could disproportionately affect patients in rural communities, people managing multiple chronic conditions, and populations with limited access to frequent in-person care.

CMS has specifically requested comments about how the proposed policy could affect access to remote monitoring.

What Healthcare Organizations Should Do Now?

The goal is not to make irreversible changes before CMS issues a final rule. The goal is to build enough operational visibility to respond quickly and intelligently.

1. Map the complete RPM and RTM workflow

Document every step from referral or patient identification through billing and ongoing treatment. For each activity, identify:

• Who performs it
• Whether that person is an employee or contractor
• Whether the work is clinical, administrative, technical, or operational
• Which billing code or service requirement it supports
• Where the activity is documented
• Who supervises or approves the work
• What happens when an exception occurs

Do not rely solely on high-level process documentation. The employment requirement may turn on who performs a specific service, so organizations need activity-level detail.

2. Inventory third-party dependencies

Review vendor contracts, statements of work, staffing arrangements, platform configurations, and billing processes. Determine exactly which vendors provide:

• Clinical personnel
• Administrative support
• Patient education
• Interactive communication
• Device logistics
• Data monitoring
• Escalation support
• Documentation
• Technology infrastructure
• Billing assistance

This exercise can reveal dependencies that may not be obvious to clinical or executive leadership.

3. Model multiple operating scenarios

Organizations should compare several potential models, including:

• Maintaining the current model if the proposal is not finalized
• Hiring third-party clinical personnel as direct employees
• Building a centralized internal monitoring team
• Distributing monitoring responsibilities across existing practices
• Using vendors for technology and administrative support while employees perform affected clinical services
• Reducing program enrollment
• Redesigning the program around higher-risk or higher-value patient populations

Each scenario should be evaluated for staffing requirements, cost, implementation time, reimbursement, compliance risk, clinical quality, and patient access.

4. Evaluate internal staffing capacity

Calculate how much work contracted clinical personnel currently perform and whether existing employees can absorb it.

Consider patient volumes, average monthly interaction time, alert frequency, escalation rates, coverage hours, employee availability, supervisory capacity, and expected program growth. A simple headcount estimate will not be enough. Organizations need a demand-and-capacity model connected to the actual workflow.

5. Strengthen documentation and auditability

CMS’s proposal reinforces the need to demonstrate who performed each service, when it occurred, what was communicated, how the practitioner remained involved, and how the activity supported the patient’s treatment plan. Systems should provide a traceable record of:

• Patient consent
• Device setup and education
• Data transmission
• Data review
• Patient or caregiver communication
• Time spent by each staff member
• Staff employment status and role
• Clinical escalations
• Practitioner decisions
• Care-plan updates
• Billing-code requirements

Documentation should be generated as part of the workflow—not reconstructed manually at the end of the month.

6. Review technology for in-house scalability

If more clinical work must be performed by employees, those employees will need tools that reduce manual workload without removing clinical judgment. Useful capabilities may include:

• Automated patient eligibility and enrollment workflows
• Connected-device and EHR integration
• Centralized work queues
• Role-based patient assignments
• Alert prioritization
• Escalation routing
• Communication tracking
• Time-threshold monitoring
• Documentation prompts
• Exception management
• Compliance dashboards
• Billing validation

Automation should support the care team, surface relevant information, and maintain a clear audit trail. It should not replace required clinical involvement.

7. Coordinate legal, compliance, clinical, financial, and operational leadership

This cannot be evaluated by one department. Compliance teams may interpret the reimbursement implications. Clinical leaders must define safe staffing and escalation models. Finance must evaluate sustainability.

Human resources may need to develop a hiring plan. Technology teams must assess system readiness. Operations must bring those pieces together into a workable program. Organizations should also consult qualified legal and reimbursement professionals before changing billing or staffing practices.

What This Means for Healthcare Technology Vendors

RPM and RTM vendors should also begin evaluating their models.

Vendors that primarily provide outsourced clinical labor may face the most significant disruption. Those offering connected devices, workflow technology, integration, analytics, automation, and administrative services may remain important—but may need to clearly separate their services from activities that must be performed by employees of the billing practice.

Forward-looking vendors should be prepared to help customers answer several questions:

• Which services are performed by vendor personnel?
• Which personnel are classified as clinical staff?
• Whose time is currently used to support Medicare claims?
• Can the platform support a customer-employed clinical team?
• Can responsibilities be reassigned without disrupting patient care?
• Does the system preserve a complete audit trail?
• Can workflows be configured differently for Medicare and non-Medicare populations?
• How quickly can the operating model be changed?

The strongest technology partners will not simply defend the existing model. They will help customers adapt.

Technology Is Only One Part of a Successful RPM Strategy

At Quandary Consulting Group, we believe digital health transformation starts with the operating model—not the software purchase.

A successful remote monitoring program requires alignment across:

• Technology
• People
• Clinical workflows
• Documentation
• Governance
• Reimbursement
• Data
• Vendor relationships
• Patient experience

Change one component, and the rest of the system may need to evolve with it. That is why the most important question is not, “Which RPM platform should we buy?”

The better question is: Does our strategy, workforce, governance, workflow, and technology stack support the clinical and financial outcomes we are trying to achieve?

How Quandary Helps Healthcare Organizations Prepare

Quandary helps healthcare organizations connect strategy, technology, data, and operations to build more resilient digital health programs.

For organizations evaluating the proposed CMS RPM and RTM changes, that may include:

• Mapping current-state clinical and operational workflows
• Identifying third-party staffing and vendor dependencies
• Modeling workforce and financial scenarios
• Designing future-state operating models
• Connecting RPM platforms with EHR, billing, communication, and analytics systems
• Automating enrollment, routing, documentation, and exception management
• Building compliance dashboards and audit trails
• Establishing human-in-the-loop governance
• Preparing systems and workflows for regulatory change

The proposed rule has not been finalized. However, its direction is clear: CMS expects remote monitoring to be clinically integrated, appropriately supervised, fully documented, and connected to the practitioner responsible for the patient’s care.

Organizations that understand their operating model now will be better positioned to respond—regardless of what CMS ultimately finalizes.

Because waiting until January is not a strategy - working with Quandary is!

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Top FAQs About the CMS 2027 RPM and RTM Proposed Rule

1. What is CMS proposing for Remote Patient Monitoring in 2027?

CMS is proposing several changes to Medicare Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) services for 2027. Most notably, CMS proposes allowing payment for certain RPM and RTM services performed by clinical staff only when those individuals are employed by the billing practitioner or practice—not supplied as contractors.

CMS is also proposing to require a separately reportable initiating visit when RPM or RTM services begin and to limit RTM services to established patients. These requirements remain proposals and have not been finalized.

CMS summarizes the proposed remote-monitoring changes here.

2. Has the CMS 2027 RPM and RTM rule been finalized?

No. As of August 2026, the RPM and RTM staffing provisions are part of the proposed Calendar Year 2027 Medicare Physician Fee Schedule. Current Medicare requirements remain in effect until CMS publishes a final rule and establishes an effective date.

Healthcare organizations should monitor the rulemaking process and avoid describing the proposed direct-employment requirement as current Medicare policy.

3. When would the proposed RPM and RTM changes take effect?

If finalized as proposed, the changes would generally take effect on January 1, 2027. CMS released the proposed rule on July 14, 2026, published it on July 16, and set September 14, 2026, as the deadline for public comments.

CMS provides the official rulemaking timeline on its CMS-1848-P page.

4. Would contracted clinical staff still be able to provide RPM and RTM services?

Contracted personnel may still be able to support some remote-monitoring activities, but under the proposal, practices could not receive Medicare payment for covered RPM or RTM services when those services are performed by contractor-supplied clinical staff.

The final impact will depend on which provisions CMS adopts, the service being performed, the billing code involved, and the individual’s role. Practices should review specific activities with qualified legal, compliance, and reimbursement professionals.

5. Does the proposal require RPM and RTM employees to work inside the practice?

No. The proposed policy focuses on whether clinical staff are employed by the billing practitioner or practice—not whether they work at a particular physical location. Employed clinical staff could potentially support patients remotely, provided all applicable Medicare supervision, documentation, billing, and clinical requirements are satisfied.

6. Would healthcare organizations have to stop using RPM and RTM vendors?

Not necessarily. The proposal would not automatically prohibit practices from using vendors for connected devices, software, integration, analytics, automation, technical support, administrative services, or other permissible functions.

The primary concern is whether contractor-supplied clinical staff perform services used to support Medicare RPM or RTM claims. Organizations should evaluate each vendor relationship at the activity level instead of assuming that every outsourced service would be prohibited.

7. Why is CMS proposing changes to RPM and RTM staffing?

CMS has raised concerns about practitioner oversight, clinical integration, program integrity, and the role of third-party companies in remote monitoring.

A 2024 HHS Office of Inspector General review found that approximately 43% of Medicare enrollees receiving RPM did not receive all three core components of the service. OIG recommended stronger safeguards, improved billing transparency, provider education, and greater oversight.

The complete findings are available from HHS-OIG.

8. What are the three core components of Remote Patient Monitoring?

The three core components of a Medicare RPM program are:

• Patient education and setup for an eligible connected medical device
• Collection and digital transmission of physiologic data
• Review and use of that data to manage the patient’s treatment

A complete RPM program should connect the device, patient, care team, treatment plan, documentation, and billing process. Distributing a device or collecting data alone does not represent the complete remote-monitoring service.

9. How could the proposed rule affect healthcare providers?

Providers that rely on third-party clinical staffing may need to reconsider their workforce, workflows, vendor agreements, technology, documentation, and financial models.

Potential effects include higher employment costs, new recruiting and training requirements, reduced patient capacity, narrower reimbursement margins, redesigned clinical workflows, and greater demand for integrated technology. Smaller practices and rural providers may face particularly significant staffing and scalability challenges.

10. How should healthcare organizations prepare for the proposed rule?

Healthcare organizations should begin with a complete assessment of their current RPM and RTM operating models. Recommended steps include:

• Mapping every clinical, administrative, technical, and billing activity
• Identifying which activities are performed by employees and contractors
• Reviewing vendor agreements and staffing arrangements
• Calculating internal staffing and supervisory capacity
• Modeling alternative workforce and financial scenarios
• Strengthening time tracking, documentation, and audit trails
• Assessing EHR, billing, device, and communication integrations
• Developing a transition plan that can be activated after the final rule

Organizations should prepare for multiple outcomes without making irreversible changes before CMS finalizes the policy.

11. What technology capabilities could help providers bring RPM and RTM operations in-house?

Providers may need technology that enables employed care teams to manage larger patient populations efficiently while maintaining clinical oversight. Important capabilities include:

• Centralized patient and work queues
• EHR and connected-device integration
• Automated enrollment and eligibility workflows
• Alert prioritization and escalation routing
• Communication and outreach tracking
• Role-based assignments
• Staff time and billing-threshold monitoring
• Documentation prompts
• Exception management
• Compliance dashboards
• Complete, traceable audit histories

Automation should organize work, surface relevant information, and reduce administrative burden without replacing required clinical judgment.

12. How can Quandary help organizations respond to the proposed CMS changes?

Quandary Consulting Group helps healthcare organizations connect the people, processes, technology, and data behind remote-monitoring programs. This can include current-state workflow mapping, vendor-dependency assessments, workforce and financial modeling, future-state operating-model design, systems integration, workflow automation, compliance dashboards, and auditable documentation.

The objective is to help healthcare organizations build clinically integrated and operationally resilient RPM and RTM programs that can adapt as Medicare requirements evolve.

Compliance note: These FAQs provide general operational information and should not be considered legal, reimbursement, coding, or billing advice.