The Remote Monitoring Leadership Council (RMLC) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the CY 2027 Physician Fee Schedule proposed rule, urging the agency not to finalize its remote physiologic monitoring (RPM) proposals as written. The Council warned that the proposed policies could end access to technology-enabled care in the home for many of the approximately 1 million Medicare beneficiaries currently served, with particularly severe consequences for rural communities and patients served by small and independent practices.
While sharing CMS’s goal of strengthening oversight of technology-enabled care, the Council cautioned that a direct employment restriction is not a proxy for clinical integration, that the proposed valuation crosswalk to self-measured blood pressure would undervalue the infrastructure required to furnish RPM, and that the changes would undermine state investments in remote monitoring made through the Rural Health Transformation Program.
In its comments, RMLC outlined an alternative approach to program integrity, including strengthened general supervision requirements, adoption of existing OIG recommendations, a modified initiating-visit requirement, and annual recertification of medical necessity. The Council also called on CMS to delay implementation, accelerate the movement of RPM toward outcome-based payment models, and collect better data on the costs of delivering high-quality RPM across conditions.
CY 2027 Physician Fee Schedule Proposed Rule Comments
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