Remote Patient Monitoring Billing in 2027: What the Final Rule Changed

What did the CY 2027 final rule change for remote patient monitoring billing?

CMS finalized three remote monitoring policies for 2027 and delayed a fourth. RTM is limited to established patients, RPM and RTM need a separately reportable initiating visit tied to the start of monitoring, and the codes were revalued; the rule that pays only for monitoring done by practice-employed clinical staff now starts January 1, 2029¹.

The rule was published on November 9, 2026 as CMS-1848-F and takes effect January 1, 2027². The rest of the fee schedule, from the conversion factor to the G2211 modifier, is in our post on the 2027 final rule.

Which RPM and RTM codes does the change touch?

All of them. The rule’s remote monitoring section covers the RPM family, including 99453, 99445, 99454, 99470, 99457 and 99458, and the RTM family, 98975 through 98981 and 98984 through 98986².

The structure you bill from is the same as 2026. Device supply follows days of data in a 30-day period: 99445 for 2 to 15 days, 99454 for 16 to 30⁵. Treatment management follows minutes in a calendar month: 99470 for the first 10, 99457 for the first 20 and 99458 for each additional 20, with at least one real-time interactive communication with the patient or caregiver in the month⁵.

What moved is value. CMS finalized the proposed work and direct PE inputs for 99445, 99453, 99454, 98975, 98976, 98977, 98984 and 98985, and crosswalked 98978 and 98986 to 98977 so all three share one PE RVU². The proposal said devices may cost less than CMS first estimated³.

But CMS backed off one cut. It did not remove direct PE inputs from 99470, 99457, 99458, 98979, 98980 and 98981, agreeing with commenters that clinical staff are often used for treatment management². And a code that is not new or revised cannot fall more than 19% in one year². All 19 RPM and RTM codes go back to the RUC for a practice expense review in January 2027, so their values may move again in a later rule².

What does the initiating visit require?

A separately reportable, face-to-face visit with the billing practitioner, in person or by telehealth, where RPM or RTM is discussed with the patient; billing for monitoring cannot start before it². The visit does not have to be about monitoring alone.

The details that decide most audits²:

• Codes that are not a face-to-face visit by the billing practitioner, or are not separately payable under Medicare, do not count.
• There is no time limit between the visit and turning the device on.
• Patients already receiving RPM or RTM before January 1, 2027 do not need one to continue.
• A device change, a clinical change or a new billing practitioner in the same practice does not trigger a new visit.
• There is no exemption for patients aligned to an ACO.

Consent rides on the same visit. Medicare already requires patient consent at the time you provide RPM⁴, and CMS framed the initiating visit as the chance to get it². So the note should show both: monitoring discussed, consent given.

What changes for RTM patients?

RTM now needs an established patient, the same as RPM. Before 2027, CMS required an established relationship for RPM but not for RTM⁴.

The rule uses the fee schedule definition: a patient who received professional services from the practitioner, or from one of the same specialty in the same group, within the past three years². For physical therapists, occupational therapists and speech-language pathologists, it is a patient receiving services under a therapy plan of care². And a patient can become established by meeting the initiating visit requirements², which is the fix for a new RTM referral.

Can you still use a third-party RPM vendor?

Yes, until the end of 2028. Contracted clinical staff remain allowed through December 31, 2028, and from January 1, 2029 the RPM and RTM codes cannot be billed when the service is not performed by clinical staff who are direct employees of the practitioner or practice².

The limit is on staff time, not on technology. The policy does not stop you working with vendors that do not supply staff time, so devices, software and technical support from outside companies are fine². CMS cited OIG findings about companies cold calling beneficiaries for monitoring they may not need, and said it will publish sub-regulatory guidance on clinical staff arrangements².

Our view: start the staffing decision in 2027, not late 2028. Two years is one contract renewal for many practices, and hiring a monitoring nurse takes longer than signing a vendor. The trade-off is real, since an in-house nurse costs money in months when enrollment is low.

How do the 2026 and 2027 requirements compare?

Most of the claim looks the same. The changes sit at the start of monitoring and in who does the work.

What should change in charge capture and audits?

Tie the first device code to a visit date. In your charge capture workflow, a new RPM or RTM enrollment should not release 99453, 99445 or 99454 until the chart shows the initiating visit, and the biller should record that visit’s claim number beside the enrollment.

Keep a list of patients monitored before January 1, 2027 with their start dates. It is your proof that the initiating visit exemption applies, and an auditor will ask for it².

Then sample monthly: five patients, checking the visit, consent note, day count, minutes with the live interaction date, and the staff member’s employment status. A medical coding service can own that sample, and a Medicare billing service works the denials it finds. The RPM billing services page covers the day and minute rules in depth.

Many monitored patients also get care management. Medicare lets you bill RPM or RTM, but not both, alongside certain care management services⁴, and the chronic care management billing page covers keeping the minutes apart.

What to do this week

1. Add an initiating visit check to RPM and RTM enrollment so no device code bills before the visit date².
2. Export the list of patients monitored before January 1, 2027, with start dates, and save it with your audit files².
3. Find every RTM patient the practice has not seen in three years and book a visit before their next period².
4. Read your RPM vendor contract for its staffing terms and renewal date against January 1, 2029².
5. Update your fee schedule for the revalued device codes when your MAC posts the 2027 file².