CMS has issued the CY 2027 Medicare Physician Fee Schedule (PFS) proposed rule , with comments open through September 14, 2026. For organizations that have built remote care–whether Remote Patient Monitoring (RPM) or Remote Therapeutic Monitoring (RTM)–into their surgical and chronic-care programs, one section deserves close reading because CMS is proposing the most significant changes to remote monitoring reimbursement since these codes were created.
The proposals arrive in response to recent Office of Inspector General (OIG) reports questioning the growth and oversight of remote monitoring. Rather than fully pulling back on remote care, CMS is tightening the conditions under which it pays for it, raising the bar on who delivers these services and how. The direction is one we at Force have long designed around: remote monitoring works best when it is an integrated extension of the patient's own care team, not a service bolted on from the outside.
What’s In The Proposed Rule?
A lower conversion factor: Other than the remote monitoring specifics, the proposal that will draw the most attention is the conversion factor. CMS proposes a CY 2027 conversion factor of $33.17 for qualifying Advanced APM participants, a decrease of 1.19%, and $32.84 for other clinicians, a decrease of 1.68%. The practical takeaway is familiar to every physician and service line leader, as Medicare is asking practices to deliver more value from a slightly smaller base, which sharpens the case for care models that improve outcomes without adding cost.
A reshaped set of remote monitoring rules: CMS established payment for two remote monitoring code families in recent years: remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM). For CY 2027, the agency proposes several changes that, taken together, reshape how these services would be delivered:
- Established patients only for RTM: CMS proposes that RTM services be furnished only to established patients, reinforcing that remote monitoring belongs inside an existing clinical relationship rather than as a first touch.
- A required initiating visit: Practitioners billing RPM or RTM would have to furnish a separately reportable initiating visit, in person or via telehealth, at the onset of services, during which the monitoring is discussed with the patient.
- In-house clinical staff, not contractors: CMS proposes to pay for RPM and RTM only when the services are performed by clinical staff employed by the practice, not when they are delivered by outside contractors.
- Revalued practice expense: CMS proposes updating how these services are valued, noting the monitoring devices may now be available at a lower cost than the agency's initial estimates assumed.
- A possible code overhaul: CMS is seeking comment on bundling the RPM and RTM CPT codes and creating four new HCPCS G-codes, a restructuring it believes would better address the OIG's recommendations than the current coding allows.
Remote Monitoring At A Crossroads
Read these proposals together, one can see that CMS wants remote monitoring anchored in a genuine, continuous clinical relationship. From the established patient requirement to the initiating visit and the employed staff condition, all of these conditions push in the same direction, away from high-volume monitoring detached from the care team, and toward monitoring owned by the clinicians already responsible for the patient.
That is precisely the model our care partners run on Force. Remote monitoring on our platform is not a separate service layered on by a third party; it is the patient's own surgical or care team staying connected across the full episode of care, using condition- and procedure-specific care plans, video-based education, and structured check-ins. When the care team owns the relationship, the initiating visit is a natural part of the workflow, the patient is already established, and the clinical staff monitoring recovery are the same people accountable for the outcome.
For organizations that had leaned on outsourced remote monitoring, the proposed rule is a prompt to reconsider the arrangement. For those who built remote care as an extension of their own teams, it reads as validation, and a reason to make sure the supporting documentation, from initiating visits to established-patient status to staffing, is airtight ahead of 2027.
How Quality Leaders Should Read This Proposal
For quality and value-based care leaders, orthopedic and specialty service lines, and the executives who oversee them, the CY 2027 PFS proposed rule is a planning document as much as a payment notice. A few implications stand out:
- Audit your remote monitoring model now: Confirm that patients are established, that initiating visits are documented, and that monitoring is performed by employed clinical staff, the three conditions CMS is proposing to enforce. If this proposal is finalized, your teams will want to move fast to ensure those remote monitoring pathways are preserved.
- Plan for a possible code change: If CMS finalizes a move to bundled G-codes, workflows and documentation built around today's CPT structure will need to adapt. Relying on a platform and team that can adapt to coding changes reduces that risk.
- Lean into integrated engagement: The rule rewards care that is continuous and clinician-owned. Extending your own care team into the home, rather than outsourcing it, aligns with both the letter and the intent of what CMS is proposing.
How Force Supports Your Remote Monitoring Program
On Force, remote monitoring is not a separate service layered on by a third party; it is the patient's own surgical or care team staying connected across the full episode of care. The initiating visit is a natural part of the workflow, the patient is already established, and the clinical staff monitoring recovery are the same people accountable for the outcome, exactly the arrangement CMS is proposing to reward.
The rule is a proposal, and the comment period runs through September 14, 2026. But its message is consistent with everything we have seen from CMS: remote and value-based care are here to stay, and the programs that endure will be the ones where digitally enabled patient engagement is woven into the care team itself. That is the model Force is designed around.
To learn more about how leading institutions are structuring compliant, integrated remote monitoring and patient engagement programs, reach out to the Force team:
