2027 CMS Final Rule: What Changes for RTM and When?

The 2027 CMS final rule adds requirements for established patients and initiating visits for remote therapeutic monitoring (RTM). The requirement for direct employment for clinical staff is delayed until January 1, 2029. Certain service valuations change, but CMS did not adopt the proposed removal of direct practice expense inputs for treatment management or the new bundled G-codes.

For clinic owners, clinical leaders, and billing teams, the first task is to separate what starts in 2027 from what comes later. A delayed staffing requirement does not postpone the changes concerning patients and initiating visits.

This guide explains the RTM decisions and offers a practical checklist for reviewing your program, whether you operate one location or a larger clinic network. It focuses on Medicare Physician Fee Schedule (PFS) policy; it does not establish that every provider type, care setting, or insurance plan can bill RTM under the same conditions.

The 2027 RTM changes at a glance

CMS released the final rule on November 4, 2026, with Federal Register publication scheduled for November 9. The table below summarizes its RTM decisions.

Source: CMS-1848-F final rule record, CMS final rule, pp. 278–301, including the treatment management decision on p. 297.

Who qualifies as an established patient for RTM?

“Established patient” does not mean a patient must complete several appointments before starting RTM.

The general definition covers a patient who received professional services within the past three years from the physician or other qualified healthcare professional, or another professional of the same specialty in the same group practice. For physical therapists, occupational therapists, and speech-language pathologists, CMS describes the relationship through services furnished under a therapy plan of care during the episode.

CMS also clarifies that a beneficiary may be considered established after meeting the remote monitoring requirements for initiating visits. The practical step is to identify the clinical relationship and evaluation supporting RTM, rather than treating an app registration as sufficient grounds for enrollment.

Source: CMS-1848-F, 278–279, public inspection PDF.

Does every patient need a separate RTM appointment?

No. For new monitoring starts from January 1, 2027, RTM must be discussed during a qualifying visit with the billing practitioner before monitoring can be billed. The visit can cover other care; it does not need to be an extra appointment solely for RTM. Patients already receiving monitoring before that date do not need a new initiating visit just to continue, provided all other requirements are met.

The visit may take place in person or through telehealth when the applicable Medicare telehealth requirements are met. For example, the practitioner can evaluate the patient during an appropriate subsequent visit, discuss how RTM would support care between appointments, and decide whether to start monitoring.

• Timing: CMS did not set a maximum interval between the visit and activation, provided monitoring was discussed at that visit.
• Routine changes: A device change, routine clinical change, or change of billing practitioner within the same practice does not by itself require another initiating visit.
• Documentation: Existing PFS documentation requirements still apply. CMS did not add a special new requirement for documenting the initiating visit.

The rule describes a separately reportable visit but clarifies that it need not be separately billable in every scenario. Billing during a global period and other special billing situations require their own review; this is not a universal instruction to submit an additional visit claim.

Keep enrollment clinically appropriate. CMS discourages misuse of enrollment before January 1, 2027, and all monitoring services must remain reasonable and necessary.

Source: CMS-1848-F, 279–285, public inspection PDF.

Can clinics still use an outside RTM company?

The answer depends on what the company provides and when the services are furnished.

Clinical staffing: the new requirement starts in 2029

CMS finalized a requirement that clinical staff furnishing the relevant monitoring services be direct employees of the practitioner or practice, but delayed implementation until January 1, 2029.

Through December 31, 2028, arrangements with outside companies remain subject to existing billing and “incident to” requirements. “Incident to” refers to Medicare requirements for reporting services incidental to a practitioner’s care under that practitioner’s billing. The delay does not remove the billing practitioner’s responsibility for involvement, oversight, and clinical integration. CMS states that inadequate oversight or integration can mean the billing criteria are not met.

CMS also plans further guidance on clinical staffing arrangements before the requirement takes effect. Review your current model now, but avoid treating every employment or contracting question as already resolved.

Technology: outside vendors remain an option

CMS explicitly distinguishes clinical staffing from technology support. Practices may continue obtaining software, devices, connectivity, hosting, implementation support, and related technical services from outside companies.

A useful review therefore separates two questions:

1. Who performs the clinical work counted toward RTM services?
2. Which tools and technical services help that team deliver and document care?

These are different parts of the operating model. Purchasing an RTM platform does not, by itself, answer the staffing question.

Source: CMS final rule, pp. 287–291.

Will RTM reimbursement change in 2027?

The payment effect depends on the service. Valuation of setup and device supply services changes were finalized, while CMS did not adopt the proposed removal of direct practice expense inputs from treatment management. That distinction matters more than a single headline percentage.

Practice expense represents resources needed to deliver a service. Relative value units (RVUs) are the values used in calculating payment; an RVU change is not automatically the same percentage change in the final payment.

There is a specific exception to gradual implementation: 98978 and 98986 are treated as new or revised codes as they move from contractor pricing in 2027, so the same gradual transition does not apply. CMS aligns their practice expense RVUs with 98977.

For a usable budget, ask your billing team for one comparison showing the 2026 and final 2027 payment information for the codes, locality, setting, and conversion factor category that apply to your practice. Keep setup separate from recurring services and count only services whose billing requirements are met. Dollar amounts and percentage changes for individual codes have not been independently calculated for this article.

Source: CMS-1848-F, 296–297, public inspection PDF.

Did CMS replace RTM codes with bundled G-codes?

No. CMS sought comments on four potential bundled remote monitoring G-codes, but did not adopt that replacement in this final rule. It may use the comments in future rulemaking.

Do not rebuild your 2027 billing workflow around those potential bundled codes. Continue checking the requirements and payment status of the actual codes your team reports.

Source: CMS final rule, pp. 298–301.

Your clinic’s RTM readiness checklist

Use the following as an operational worklist, not a list of additional CMS requirements. Assign an owner and completion date to each deliverable. For organizations with multiple locations, use the same format across sites.

Start with enrollment and payment assumptions for 2027. Review staffing in parallel so any required changes can be planned before 2029. The delay of two years does not postpone today’s oversight responsibilities.

Frequently asked questions

Is the 2027 CMS RTM rule final or still proposed?

CMS released the final rule on November 4, 2026. As of November 6, Federal Register publication is scheduled for November 9. The RTM provisions have different implementation dates, including the 2029 staffing requirement.

Does delaying the staffing requirement postpone all RTM changes?

No. The delay applies to the requirement for direct employment for clinical staff. It does not postpone the policies for established patients or initiating visits taking effect in 2027.

Can an RTM initiating visit take place through telehealth?

Yes, when the applicable Medicare telehealth requirements are met. The billing practitioner must discuss monitoring during the visit; an app registration does not replace the required initiating visit.

Does this rule make every clinic eligible to bill RTM?

No. A clinic’s size does not establish billing eligibility. Confirm the applicable requirements for the billing professional, setting, service, and payer before starting or expanding a program.

Plan your next steps for RTM

Preparing for 2027 or reviewing your current RTM program? Tell us how your practice works and where you need support. The PhyxUp team will reach out to discuss your needs and how its documentation, monitoring, and billing capabilities may fit your workflow. Available capabilities depend on the plan; clinical decisions remain with your care team.

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