On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2027 Medicare Physician Fee Schedule (PFS) proposed rule, filed as CMS-1848-P. The proposed rule sets out how Medicare would pay physicians and other practitioners under Medicare Part B beginning January 1, 2027, if finalized.
It touches nearly every part of Medicare payment policy, from the annual conversion factor to remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM). For healthcare organizations that operate Remote Patient Monitoring (RPM) and Chronic Care Management (CCM) technologies, several proposed provisions are directly relevant to day-to-day billing and program design.
Jul 14, 2026 Proposed rule released | Sep 14, 2026 Comment period closes | 3 New RPM and RTM requirements | Jan 1, 2027 Proposed effective date, if finalized |
Below is a summary of what CMS proposed, why, and what happens next.
CMS Released the 2027 Physician Fee Schedule Proposed Rule in July 2026
Since 1992, Medicare has paid physicians and other billing professionals under the Physician Fee Schedule (PFS) for services delivered in physician offices, hospital outpatient departments, and other settings. Each year, CMS proposes updates to this payment system through notice and comment rulemaking.
CMS describes the CY 2027 proposed rule as part of a broader administration-wide effort to shift Medicare toward outcomes and efficiency rather than volume of services. The rule covers Medicare Part B payment policy, the Medicare Shared Savings Program for Accountable Care Organizations (ACOs), and the Quality Payment Program (QPP), among other topics.
If finalized, most provisions would take effect January 1, 2027. Before that happens, CMS is accepting public comments, and the proposed policies described in this article could change in the final rule.
The Proposed Rule Would Lower the 2027 Medicare Conversion Factor
Medicare payment rates under the PFS are calculated by applying a conversion factor, a dollar amount, to the relative value units (RVUs) assigned to each service. For CY 2027, CMS proposed two separate conversion factors, as required by statute.
One conversion factor applies to clinicians who qualify as participants in Advanced Alternative Payment Models (APMs). The other applies to clinicians who do not.
Size of the proposed cut, by clinician group Percent decrease from the CY 2026 conversion factor. Bars are scaled to a 2 percent maximum. | ||||
| ||||
|
| Clinician group | CY 2026 | CY 2027 proposed |
|---|---|---|
| Qualifying APM participants | $33.57 | $33.17 |
| Non-qualifying APM participants | $33.40 | $32.84 |
These proposed reductions reflect a one-year, 2.5 percent conversion factor increase under the Working Families Tax Cut legislation that expires at the end of 2026. That expiration is only partly offset by a smaller statutory update and an adjustment tied to proposed changes in work RVUs.
Practices that operate RPM, RTM, or CCM programs billed under the PFS would feel the effect of this broader conversion factor change alongside the monitoring-specific proposals described below.
Remote Monitoring Services Would Face New Program Integrity Requirements
CMS proposed a significant set of changes to remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM). These are the two Medicare code families that cover the collection, analysis, and clinical use of patient-generated physiologic and therapy data.
According to CMS, these proposals respond to two 2024 reports from the U.S. Department of Health and Human Services Office of Inspector General (OIG). In its own words, OIG found that “the use of remote patient monitoring in Medicare increased dramatically from 2019 to 2022,” and that some services were billed for patients who did not receive all required components.
Three proposed changes stand out for practices that offer these services.
Requirement 1 Initiating visit A separately billable visit would be required before RPM or RTM begins. | Requirement 2 Established patient RTM would require an established patient relationship, the same standard that already applies to RPM. | Requirement 3 Employed staff RPM and RTM would need to be furnished by clinical staff employed by the billing practice. |
An Initiating Visit Would Be Required Before RPM or RTM Begins
CMS proposed that practitioners furnish a separately billable initiating visit before starting RPM or RTM for a patient. During this visit, the billing practitioner would need to discuss monitoring with the patient, confirm it is clinically appropriate, and obtain the patient’s consent.
A visit that does not include this discussion could not count as the initiating visit. Encounters that are not separately payable under Medicare, or that do not involve a face-to-face encounter with the billing practitioner, would not qualify either.
This proposal aims to verify that a billing practitioner conducts an evaluation and establishes a patient-practitioner relationship prior to initiating monitoring services.
RTM Services Would Be Limited to Established Patients
RPM already requires an established patient relationship, meaning the billing practitioner has previously examined and diagnosed the patient. CMS proposed extending this same requirement to RTM.
Under the proposal, a practitioner could not bill RTM for a patient with no prior relationship to the practice. This closes a gap that OIG identified when some remote monitoring companies billed for patients they had not previously treated.
CMS reasons that an established relationship gives the practitioner the clinical history needed to determine whether ongoing monitoring is appropriate for that patient.
RPM and RTM Would Need to Be Furnished by Practice-Employed Staff
CMS also proposed to allow payment for RPM and RTM only when the clinical staff performing the service are direct employees of the billing practice, rather than staff supplied by an outside vendor under contract. In the agency’s own language, payment would apply only when services are performed by clinical staff “employed by the practice and not when those services are delivered by contractors.”
CMS explained that outsourced monitoring arrangements can separate the billing practitioner from the day-to-day delivery of the service. This structure can also make it harder for CMS and OIG to identify who is performing the monitoring.
Key insight Of everything CMS proposed, the staffing restriction is the one most likely to force practices to rethink their programs. Practices that currently rely on a third-party monitoring vendor’s staff would need to bring that function in-house, or lose the ability to bill for it. |
Would still be billable Monitoring performed by nurses, medical assistants, and other clinical staff who are direct employees of the billing practice, working under the billing practitioner. | Would not be billable Monitoring performed by clinical staff supplied by an outside vendor under contract, even when the vendor reports data back to the practice. |
Separately, CMS is seeking comment on consolidating the current RPM and RTM CPT codes into new HCPCS G-codes, and on updating how these services are valued to reflect device costs that CMS believes are now lower than its original estimates.
None of these proposals are final. CMS is asking for public comment on each before deciding how to proceed.
New Codes Would Support Longitudinal and Preventive Chronic Care
Several other CY 2027 proposals focus on chronic disease and preventive care, an area CMS has flagged as a top priority given how widespread chronic conditions are among Medicare beneficiaries.
| Proposal | What CMS proposed | Who it applies to |
|---|---|---|
| E/M complexity add-on (G2211) | Change from a flat payment to a percentage-based modifier that increases payment for the associated office visit by 16 percent. | Clinicians billing qualifying office visits |
| ACO longitudinal care modifier | A second, related modifier increasing payment by 32 percent for the added work of coordinating care over time. | Shared Savings Program ACO and LEAD Model clinicians only |
| Behavioral health | Complete a four-year transition that increases payment for smoking and tobacco cessation counseling and for SBIRT services. | Clinicians furnishing these services |
| Advance care planning (ACP) | Two new codes separating ACP work by clinical staff under direct supervision from time the billing practitioner spends personally with the patient. | Practices furnishing ACP |
| Shared medical appointments | Create a new code, since no current code describes this group-visit format. | Practices serving patients with similar chronic conditions |
Proposed payment increase, by modifier Percentage added to the associated visit payment. Bars are scaled to a 40 percent maximum. | ||||
| ||||
|
Combined, these proposals point toward a payment system that increasingly recognizes coordination and non-visit care, the same kind of work that RPM and CCM programs are designed to support.
Rural Health Clinics and Federally Qualified Health Centers Would Gain New Flexibilities
CMS proposed several changes specific to Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs).
| Provision | What would change | Through |
|---|---|---|
| DSMT and MNT | Diabetes Self-Management Training and Medical Nutrition Therapy would become separately billable, all-inclusive-rate visits under the RHC benefit, matching how FQHCs and physician offices are already paid. | Permanent, if finalized |
| Mental health visits | RHCs and FQHCs would keep the waiver of the in-person visit requirement under the Consolidated Appropriations Act, 2026. | December 31, 2027 |
| Non-behavioral health visits | Authority to bill for visits delivered by telecommunications technology would be extended. | December 31, 2027 |
These proposed provisions aim to expand access to preventive and behavioral healthcare services in rural and medically underserved populations.
For practices operating under a Rural Health Transformation Program (RHTP) grant, or planning an RPM program in an RHC or FQHC setting, these proposed billing changes are worth watching alongside RHTP-funded initiatives.
The Public Comment Period Closes on September 14, 2026
July 14, 2026 CMS issues the CY 2027 PFS proposed rule, file code CMS-1848-P. | September 14, 2026 The 60-day public comment period closes on regulations.gov. | January 1, 2027 Proposed effective date for most provisions, if finalized. |
CMS opened a 60-day public comment period when it published the CY 2027 PFS proposed rule, and that window closes on September 14, 2026. Comments can be submitted through regulations.gov using file code CMS-1848-P.
CMS reviews public comments before publishing a final rule, typically in the fall. The final rule may adopt, modify, or drop any of the provisions described above.
Healthcare organizations that operate RPM, RTM, or CCM programs, particularly those that currently rely on outside vendors for monitoring staff, may want to review the proposed rule in full and consider submitting comments before the deadline.
How DrKumo Supports Providers Navigating Medicare Policy Changes
For practices that already operate Remote Patient Monitoring (RPM) programs, the proposed initiating-visit, established-patient, and employed-staff requirements described above are primarily workflow and staffing questions, not reasons to pause a program.
DrKumo provides the secure, HIPAA-compliant technology infrastructure, including connected medical devices and a provider-facing data platform, that a practice’s own clinical staff use to collect, review, and act on physiologic data. DrKumo is not a clinical entity, does not employ clinical staff on behalf of a billing practice, and does not make monitoring or billing decisions. Those responsibilities remain with the practice and its licensed providers.
The same proposed rule also touches Chronic Care Management (CCM) indirectly, through new coding for longitudinal and preventive care. It also proposes new flexibilities for Rural Health Clinics and Federally Qualified Health Centers that build on the Rural Health Transformation Program funding already reaching many rural practices.
DrKumo supports healthcare organizations building or scaling RPM and CCM technologies in these settings with configurable device kits designed around current CMS billing requirements. Practices weighing how these proposed changes intersect with related policy, such as the CMS ACCESS Model or the proposed elimination of the CCM copay under H.R.8261, can find additional context in DrKumo’s related coverage of those topics.
Key Takeaways for Healthcare Providers
CMS’s CY 2027 Physician Fee Schedule proposed rule is not final, but it signals clear direction on several fronts: a lower 2027 conversion factor, tighter program integrity requirements for RPM and RTM, new coding for longitudinal chronic care, and expanded flexibilities for rural health clinics and FQHCs.
Practices that operate remote monitoring or chronic care programs should review the initiating-visit, established-patient, and staffing proposals closely, since these would directly affect how monitoring services are delivered and billed if finalized. The comment period runs through September 14, 2026, giving healthcare organizations a window to weigh in before CMS issues a final rule.
DrKumo is a digital health technology company, not a clinical entity, and does not provide clinical services, make coverage determinations, or replace a licensed provider’s clinical judgment. Remote patient monitoring is intended to support, not substitute for, in-person or emergency medical care.
Plan ahead of the 2027 Physician Fee Schedule Build a compliant RPM and CCM program before the rule is finalized. To learn how DrKumo’s digital health technology can support your organization’s remote monitoring and chronic care programs under evolving CMS requirements, contact us today. Our team is ready to help you plan for what’s next. |
Frequently Asked Questions About the 2027 Physician Fee Schedule Proposed Rule
Questions about the proposed rule and what it means for remote monitoring and chronic care programs.
When would the 2027 Physician Fee Schedule changes take effect?
If CMS finalizes the proposed rule as written, most provisions would take effect January 1, 2027. The rule is not yet final, and CMS could revise any proposal in response to public comments before the final rule is published.
How would the proposed rule change RPM and RTM billing?
CMS proposed requiring a separately billable initiating visit before RPM or RTM begins, extending the established-patient requirement to RTM, and limiting payment to services furnished by clinical staff employed directly by the billing practice rather than outside contractors.
Is the Medicare conversion factor going down in 2027?
As proposed, yes. CMS proposed a 2027 conversion factor of $33.17 for qualifying APM participants and $32.84 for other clinicians, decreases of 1.19 percent and 1.68 percent from 2026, largely because a temporary statutory increase in effect for 2026 is set to expire.
How can a practice submit a comment on the proposed rule?
Comments are submitted through regulations.gov using file code CMS-1848-P. The 60-day comment period opened when CMS published the rule on July 14, 2026 and closes September 14, 2026. CMS reviews submitted comments before issuing a final rule.
What does the proposed rule mean for Rural Health Clinics and FQHCs?
CMS proposed making Diabetes Self-Management Training and Medical Nutrition Therapy separately billable all-inclusive-rate visits under the RHC benefit. It also proposed extending the waiver of the in-person requirement for mental health visits, and the authority to bill non-behavioral health visits delivered by telecommunications technology, through December 31, 2027.
References
Centers for Medicare & Medicaid Services. (2026). Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule. CMS.gov.
Centers for Medicare & Medicaid Services. (2026). Physician Fee Schedule. CMS.gov.
U.S. Department of Health and Human Services, Office of Inspector General. (2024). Additional Oversight of Remote Patient Monitoring in Medicare Is Needed. OIG.HHS.gov.
U.S. Department of Health and Human Services, Office of Inspector General. (2025). Billing for Remote Patient Monitoring in Medicare. OIG.HHS.gov.
Regulations.gov. (2026). Public comment docket, file code CMS-1848-P. Regulations.gov.
Disclaimer: This article summarizes selected provisions of a proposed rule that has not been finalized and may change based on public comments. It is provided for informational purposes only, does not constitute medical, legal, billing, or financial advice, and is not affiliated with or endorsed by CMS or the U.S. Department of Health and Human Services. DrKumo is a digital health technology company and is not a clinical entity. It does not provide clinical services or replace a licensed provider’s clinical judgment. Providers should consult the full proposed rule, official CMS guidance, and their own legal or compliance counsel before making billing or operational decisions, and should always consult a licensed healthcare provider for guidance on diagnosis, treatment, or medical decisions. |
