On July 14, 2026, CMS released its proposed 2027 Physician Fee Schedule, known as CMS-1848-P. Inside a very long document are several proposals that would change how Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) are delivered and paid for under Medicare beginning January 1, 2027.
SynsorMed has been helping practices run remote care programs since 2014. We have read the proposal closely, we have talked with our customers about it, and we want to be clear about two things: what CMS is actually proposing, and what SynsorMed is doing to lead the industry through this moment.
First, the plain-language version of what CMS is proposing
Nothing here is final. CMS is accepting public comments through September 14, 2026, and current RPM and RTM billing requirements remain in effect through the end of 2026. The final rule is expected this fall.
- Your monitoring nurses would need to be on your payroll. Today, many practices rely on a vendor's clinical staff to review readings, call patients, and log the monthly management time behind codes like 99457 and 99458. CMS is proposing that Medicare pay for RPM and RTM services only when they are furnished by clinical staff employed by the physician or the practice.
- A separate visit before monitoring starts. CMS is proposing that practitioners billing RPM or RTM furnish a separately reportable initiating visit, in person or by telehealth, at the start of service. Remote monitoring would need to be discussed with the patient during that visit.
- RTM would be limited to established patients. The proposal would restrict RTM to patients who already have a relationship with the practice.
- Lower payment for setup and device codes. CMS believes monitoring devices are now available at a lower cost than it originally estimated and is proposing to update how these services are valued. The proposal would also remove practice expense from the treatment management codes.
- A possible new code structure. CMS is also seeking comment on bundling the RPM and RTM CPT codes and creating four new G-codes to describe remote monitoring services.
What ties these together: CMS wants to reinforce that RPM and RTM are care management services that belong inside a practice, not standalone offerings, and the changes follow OIG reports that flagged billing patterns tied to fraud risk, including heavy reliance on third-party vendors.
Our view
Accountability is good for this industry. Programs that exist only to ship a device and bill a code have hurt patients, and they have hurt the reputation of every vendor doing this the right way. We support the goal.
We also believe some of the tools CMS chose will restrict good programs as much as bad ones. A staffing rule does not measure whether a patient is engaged, whether a nurse escalated a dangerous reading, or whether blood pressure came down. That is why SynsorMed is doing three things.
1We are working with every customer, current and new, to protect the economics of their program
Our commitment to the practices we serve is simple: you should not lose money on remote care because the rules changed. For every customer, SynsorMed is doing the following now, before the final rule arrives.
- Modeling 2027 scenarios code by code, using your actual patient panel and payer mix, so you know your exposure under each proposal instead of guessing.
- Redesigning the staffing model if the direct employment rule is finalized. We will help you hire or designate in-house clinical staff, and SynsorMed will supply everything around them: the platform, cellular devices and logistics, patient onboarding, training, billing support, and Simon, our AI engagement layer that reaches patients by text to keep readings coming in. Simon absorbs the routine outreach, which means a small in-house team can manage a large panel.
- Building the initiating visit into your intake workflow so enrollment does not stall.
- Bringing in every care management pathway the patient qualifies for, including CCM, PCM, and APCM, so your program's value never rests on a single code family.
Engagement is what protects revenue under any code structure. Those numbers hold up no matter how CMS values a device.
2We are advocating for a nationwide certification program for RPM and RTM vendors
The direct employment rule tries to solve a trust problem with a payroll rule. The better answer is a national certification standard, recognized by CMS, that measures what a program actually delivers: patient adherence, documented clinical time, escalation protocols, informed consent, data security, and outcomes.
Under that model, certified vendors would be trusted partners to the practices they serve, and the vendors who cut corners would lose the ability to touch Medicare patients. Practices would keep the flexibility to choose the care model that fits them. CMS would get the visibility it is asking for, and patients would get a consistent standard of care wherever they enroll.
SynsorMed is making this case to CMS during the comment period and in conversations with our industry partners. We invite other vendors who operate with integrity to join us.
3We are advocating for more connection to seniors through new reimbursable services, including the ACCESS Model
Every month our nurses hear from seniors who tell us the monthly call is the only time someone checks on them, from caregivers managing a spouse or parent alone, and from patients who finally understood their diagnosis after a nurse took the time to explain it. The problem in Medicare is not too much remote care. It is too little connection.
CMS's own ACCESS Model, Advancing Chronic Care with Effective, Scalable Solutions, points in the right direction. It is a ten-year national test that pays participating organizations predictable, recurring amounts for helping patients manage chronic conditions, with full payment tied to measurable results like blood pressure control. That is the standard we believe in: pay for outcomes, and hold everyone to them.
SynsorMed has been building for the ACCESS Model, and we are advocating for more programs like it that reward practices for keeping seniors connected, engaged, and healthy at home.
What we are asking of you
If you are a practice
Do not pause your program. Current rules stay in effect through 2026, and the practices that model 2027 now will be the ones that come through it whole. Reach out and we will run the numbers with you.
If you are an industry peer
Submit your comments to CMS before September 14. The final rule will be shaped by who shows up.
If you are at CMS
Hold this industry accountable for outcomes. We will meet that standard, and we will help you set it.
Learn More
- CMS 2027 Physician Fee Schedule Proposed RuleView the CMS fact sheet
- CMS Physician Fee ScheduleView CMS's Physician Fee Schedule page
- OIG: Additional Oversight of Remote Patient Monitoring in Medicare Is NeededRead the OIG report
- OIG: Billing for Remote Patient Monitoring in MedicareRead the OIG billing report