2027 Fee Schedule Final Rule: What CMS Changed for Remote Monitoring and Care Management

Vivo Care read the full CY 2027 Medicare Physician Fee Schedule final rule the day the Centers for Medicare and Medicaid Services (CMS) filed it, and checked every remote monitoring and care management change against the July proposal. The short answer: CMS dropped its proposed cut to clinical staff time in remote monitoring treatment management, pushed the direct employment requirement for monitoring staff to January 1, 2029, and kept the initiating visit for new Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) starts from January 1, 2027. The codes for Chronic Care Management (CCM), Principal Care Management (PCM) and Advanced Primary Care Management (APCM) did not change.

The final rule (CMS-1848-F) was placed on public inspection at the Federal Register on November 4, 2026, and is scheduled for publication on November 9, 2026. Page numbers below refer to the public inspection copy. Percent changes come from the final rule’s relative value file (Addendum B), national non-facility, for practices that are not Qualifying Alternative Payment Model (APM) Participants. Dollar amounts follow when CMS publishes its 2027 national payment amounts.

Vivo Care + Onpoint Healthcare Partners are combining. Vivo Care carries care between visits: RPM, CCM, PCM and APCM, run by licensed care teams. Onpoint runs EHR automations for the routine work behind every visit, with medical experts in the loop and clinical decisions staying with the treating care team: inbox triage, prior authorizations, lab result review and visit note drafting. Both run inside athenahealth and eClinicalWorks. Point-of-care enrollment is the bridge between them, and it matters more under the 2027 initiating visit rule, covered below. Learn more about Vivo Care and Onpoint.

What did CMS change between the proposal and the final rule?

Most of the remote monitoring package was finalized as proposed. These are the items that moved, ranked by what they mean for a practice running a program.

Why does the treatment management decision matter most?

Treatment management is the clinical work in remote monitoring: the reviews, the conversations with patients and the escalations to the provider. In July, CMS proposed removing the clinical staff practice expense from those codes. In the final rule it reversed course: “we agree with commenters that clinical staff are often used when furnishing treatment management services for remote physiologic and remote therapeutic monitoring” (p. 297). Work values stay at 0.31 for 99470 and 0.61 for 99457 and 99458 (pp. 447 to 448).

The effect against the proposal is large. 99470 lands about 28 percent above what CMS proposed, 99457 about 4 percent above and 99458 about 2 percent above. Against 2026, treatment management is roughly flat: 99470 rises about 2 percent, while 99457 and 99458 dip less than 1 percent.

Who can furnish RPM and RTM time in 2027, 2028 and 2029?

CMS finalized the requirement that RPM and RTM clinical staff time come from a direct employee of the practitioner or the practice, and moved the start to January 1, 2029. CMS called it “a 2-year delay in implementation to allow for practices to hire and train staff” (p. 290). Until then, third-party clinical staff time remains billable, provided all existing “incident to” and other billing rules are met (p. 291).

Three details shape planning:

• Oversight now. CMS says that where there is “little oversight by the billing practitioner or a lack of clinical integration” between a third party and the practice, the practitioner should not bill remote monitoring (p. 291). Escalation records, practitioner acknowledgment and care plan approval matter in 2027 and 2028.
• Guidance before 2029. CMS will publish sub-regulatory guidance on “clinical staff arrangements that may be appropriate for remote monitoring services” before the requirement takes effect (p. 291).
• Technology stays open. “Practices may obtain devices, software, connectivity, data hosting, cybersecurity, implementation support, technical assistance, and interoperability services from outside companies” (p. 287). General supervision and the regulation at 42 CFR 410.26 are unchanged (pp. 287 to 288).

The Vivo Care platform supports both Practice-Managed and Managed Clinical models. In a Practice-Managed program, the practice’s own clinical staff does the work. In a Managed Clinical program, Vivo Care’s care navigators, U.S.-based, state-licensed nurses, function as a seamless extension of the provider team. Nothing in the final rule changes staffing for RPM or RTM on January 1, 2027.

Remote care starts at the visit: the initiating visit rule

Starting January 1, 2027, Medicare requires a separately reportable initiating visit before remote patient monitoring or remote therapeutic monitoring can begin. The billing practitioner has to discuss monitoring with the patient at that visit, in person or by telehealth, and the visit is where the provider assesses whether monitoring is clinically appropriate. A routine visit where monitoring never comes up does not count. Billing for monitoring cannot begin before the visit (pp. 279 to 281), and CMS describes the visit as the opportunity to obtain the patient’s consent (p. 279). Sources: the CMS fact sheet, the final rule, Federal Register document 2026-22743, and AHA News, November 4, 2026. CMS wants remote patient monitoring to begin with the patient’s own provider, face to face.

The final rule answers the questions practices asked during comments:

• Patients already on monitoring. Beneficiaries receiving remote monitoring before January 1, 2027 do not need an initiating visit to continue, as long as every other requirement is met. CMS also says it “discourages any misuse of enrolling beneficiaries in remote monitoring services between the publication of this rule and January 1, 2027” (p. 285). Enrollment should continue in the normal course of care.
• Timing. CMS set no limit on the time between the visit and the start of monitoring, as long as RPM or RTM is discussed at that visit (pp. 281 to 282).
• Telehealth. The initiating visit may be furnished by telehealth under section 1834(m) of the Social Security Act. After December 31, 2027, absent new legislation, the remaining 1834(m) limits apply (p. 282).
• Purpose of the visit. The visit does not have to be only about remote monitoring. It has to include the discussion (p. 283).
• Routine changes. A new initiating visit is not needed for a device change, a clinical change, or a change of billing practitioner within the same practice (p. 284).
• RTM and established patients. RTM is now limited to established patients, matching RPM. A beneficiary counts as established once the initiating visit requirements are met (p. 279).

For practices, the work is in the workflow. The provider raises monitoring in the visit and the patient gives verbal consent. Write that consent into the plan of care explicitly, for example: “Verbal consent obtained and remote monitoring requirements reviewed with the patient.” The visit note should also record that monitoring was discussed, since that discussion is what makes the visit count as the initiating visit.

How practices meet the initiating visit with Vivo Care

The rule changes how RPM starts, not who can offer it. Vivo Care supports the initiating visit in more than one way, so practices keep the enrollment path that fits their team. From January 1, 2027, every path for a new RPM start runs through a visit with the billing practitioner.

• Point-of-care enrollment (new). Our EHR integration prompts the provider to raise remote care in the visit, so enrollment starts where the provider works. Live on athenahealth and eClinicalWorks, with more EHRs coming.
• In-office enrollment by the clinic team. The provider discusses RPM at the visit, and the clinic team enrolls the patient before they leave.
• Digital fax referral. The provider discusses RPM at the visit and refers the patient to Vivo Care. The referral should show the visit date, whether the visit was in person or by telehealth, the billing practitioner, and that RPM was discussed.
• Remote enrollment by the Vivo Care team. For new RPM starts, Vivo Care care navigators enroll patients after a visit where the provider discussed RPM, then handle device setup and education. Care navigators cannot hold the initiating visit. Remote enrollment for Chronic Care Management continues under the existing CCM rules.

See how the initiating visit fits your workflow. Request a demo and we will walk through how it fits your schedule and your EHR.

Your provider starts it. We carry it between visits.

What happens to RPM device supply and set-up payment in 2027?

Device supply and set-up were revalued as proposed. RPM device supply (99445 and 99454) now takes its direct practice expense inputs from 99474, RTM device supply from 93270, and set-up (99453 and 98975) from 99473 (p. 296). In 2027, 99454 and 99445 pay about 21 percent less than in 2026, and 99453 about 8 percent less.

CMS phases large cuts in over more than one year (p. 296): the statute caps the one-year cut to an existing code’s relative value at 19 percent. The lower 2027 conversion factor applies on top of that cap, which is why 99454 and 99445 show about 21 percent lower in dollars. CMS’s final phase-in file lists 99454 and 99445, so further reductions are expected after 2027. The American Medical Association told CMS that all 19 RPM and RTM codes will have their practice expense reviewed at the January 2027 RUC meeting, and CMS said it will review that information for future rulemaking (p. 296). The two RTM cognitive behavioral therapy device codes, 98978 and 98986, move to national pricing at the same practice expense value as 98977 (pp. 296 to 297).

The direction is clear: device supply carries less of a program’s revenue each year, and the clinical work carries more. Every code also moves with the conversion factor, which falls 2.31 percent from 2026 for practices that are not Qualifying APM Participants (pp. 8, 1972). Our 2026 Remote Care Billing and Coding Guide carries the current rates, which apply through December 31, 2026.

Did CCM, PCM or APCM change for 2027?

No. The care management code structure is unchanged for 2027. CMS asked in July whether to consolidate the care management “family” or split it into a technology-first track and a traditional track. In the final rule, CMS reports that commenters “largely did not agree” with differentiating care management by technology, and that most said aligning requirements matters more than cutting the number of codes. CMS will consider the comments for future rulemaking (pp. 514 to 518). Payment moves mostly with the conversion factor: 99490 falls about 4 percent, 99439 about 2 percent, and the APCM codes G0556, G0557 and G0558 about 2 percent.

Two items do move for primary care teams running Advanced Primary Care Management:

• Behavioral health add-ons rise. APCM add-ons G0568 and G0569 and the CoCM codes 99492, 99493 and 99494 were revalued on a level 4 visit basis, higher than proposed. G0568 rises about 50 percent from 2026 and G0569 about 25 percent. G0570 was not revalued (pp. 317 to 318). CMS also says alcohol use disorder management “may qualify” under the APCM behavioral health add-on when all requirements are met (pp. 318 to 319).
• A signal on direction. CMS writes that it does “not view APCM as the end goal of primary care payment reform” (p. 532). Commenters on a related request for information called APCM a natural starting point for a monthly primary care payment (pp. 547 to 548).

What should practices do before January 1, 2027?

• Put the initiating visit into the workflow. Decide how providers raise monitoring at the visit, how the note records the discussion, and how consent is obtained and written into the plan of care, in person and by telehealth.
• Keep enrolling in the normal course of care. Existing patients are grandfathered. CMS “discourages any misuse of enrolling beneficiaries” in remote monitoring between publication of the rule and January 1, 2027 (p. 285).
• Check oversight records. Escalations, practitioner acknowledgment and care plan approval should be visible in the chart for every monitored patient (p. 291).
• Rerun the device math. Device supply revenue drops in 2027 and continues to phase down unless the January 2027 RUC review changes it (p. 296). Our 99454 billing guide covers the code in detail.
• Keep care management moving. CCM, PCM and APCM rules did not change, and the direct employment requirement in the rule text applies to RPM and RTM codes.

For background on what CMS proposed in July, see our post on the 2027 Medicare Physician Fee Schedule proposal.

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Existing Vivo Care customers: your Customer Success Manager will walk through the changes with you.

Frequently Asked Questions

Source: CMS, Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule, final rule CMS-1848-F, Federal Register public inspection document 2026-22743, filed November 4, 2026 (public inspection copy). Page numbers refer to that copy. Percent changes are national non-facility amounts for practices that are not Qualifying APM Participants, calculated from the final rule’s Addendum B relative value file and the 2026 relative value file. This content is for informational purposes only and is not legal or billing advice. There is no guarantee of reimbursement.

About this summary: This reflects Vivo Care’s interpretation based on our initial review of the CY 2027 Medicare Physician Fee Schedule final rule (CMS-1848-F). We are partnering with our outside counsel, Elevare Law, on final language and updates. Payment figures are national Medicare amounts for the office (non-facility) setting for practices that are not Qualifying APM Participants, which covers most independent practices. 2027 figures are Vivo Care calculations from CMS’s final rule rate file (CMS-1848-F Addendum B), total relative value units times the 2027 conversion factor, rounded. CMS’s published amounts may differ slightly, and actual payment varies by location. This is not legal or billing advice.