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Health Reimbursement Signals: CMS Proposes Significant Changes to RPM and RTM Requirements

By Ty Kayam, Jodi Daniel, Andrea Linna & Seamus Taylor on August 7, 2026
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The Centers for Medicare & Medicaid Services (CMS) has proposed significant changes to Medicare reimbursement for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services under the proposed calendar year (CY) 2027 Medicare Physician Fee Schedule. The changes would limit RPM and RTM to established patients, require a qualifying face-to-face visit before monitoring begins, and restrict billable monitoring work to clinical staff directly employed by the billing practitioner or practice.

The rule also proposes downward revisions to practice expense inputs for setup and device-supply codes and seeks comment on a more sweeping overhaul that would consolidate 17 existing RPM/RTM codes into four bundled monthly codes. These changes, if finalized, could require RPM and RTM vendors and providers to rework enrollment workflows, staffing arrangements, and billing models well ahead of the proposed January 1, 2027, effective date. Comments on the proposed rule are due September 14, 2026.

Read the full alert.

Photo of Ty Kayam Ty Kayam

Ty Kayam is Of Counsel in the Seattle office of Wilson Sonsini Goodrich & Rosati, where she advises companies and investors on regulatory strategy for health technology products, with a particular focus on health AI, digital health, wearables, medical robotics, and health data…

Ty Kayam is Of Counsel in the Seattle office of Wilson Sonsini Goodrich & Rosati, where she advises companies and investors on regulatory strategy for health technology products, with a particular focus on health AI, digital health, wearables, medical robotics, and health data infrastructure. She counsels clients throughout product development and commercialization and advises on health regulatory issues arising in financings, investments, partnerships, and strategic transactions.

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Photo of Jodi Daniel Jodi Daniel

Jodi is a nationally recognized leader in digital health law and policy with more than 30 years of experience in healthcare innovation. She advises healthcare organizations and technology companies on complex regulatory, policy, and ethical issues involving digital health, health data, and emerging…

Jodi is a nationally recognized leader in digital health law and policy with more than 30 years of experience in healthcare innovation. She advises healthcare organizations and technology companies on complex regulatory, policy, and ethical issues involving digital health, health data, and emerging products and services, drawing on 15 years of experience as a lawyer and senior policymaker at the U.S. Department of Health and Human Services.

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Photo of Andrea Linna Andrea Linna

Andrea is a partner and member of the digital health industry group and healthcare practice. With more than 15 years dedicated to healthcare law, she represents digital health and health tech clients on regulatory matters throughout the business life cycle, including care delivery…

Andrea is a partner and member of the digital health industry group and healthcare practice. With more than 15 years dedicated to healthcare law, she represents digital health and health tech clients on regulatory matters throughout the business life cycle, including care delivery structures, reimbursement, telehealth, healthcare transactions, and compliance with federal and state healthcare laws.

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Photo of Seamus Taylor Seamus Taylor

Seamus is an associate and member of the digital health industry group and healthcare practice. He advises companies on healthcare regulatory matters including corporate practice of medicine, fraud and abuse laws, HIPAA, Medicare and Medicaid, and state licensing requirements. He also counsels clients…

Seamus is an associate and member of the digital health industry group and healthcare practice. He advises companies on healthcare regulatory matters including corporate practice of medicine, fraud and abuse laws, HIPAA, Medicare and Medicaid, and state licensing requirements. He also counsels clients on healthcare transactions, contractual arrangements, entity formation, governance, and compliance programs.

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  • Posted in:
    Health Care and Life Sciences
  • Blog:
    The Consult
  • Organization:
    Wilson Sonsini Goodrich & Rosati
  • Article: View Original Source

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