07/17/2026
There has been a lot of discussion about the proposed RTM changes in the CY 2027 Medicare Physician Fee Schedule. The key word is proposed. Nothing is final, current RTM billing rules remain in place, and any finalized changes would not take effect until 2027.
CMS is proposing several changes, including limiting RTM to established patients, requiring a separately reportable initiating visit, restricting payment for clinical staff services to staff employed by the billing practice, and reevaluating payment based on updated device cost assumptions. CMS is also seeking feedback on potentially bundling RPM and RTM codes into four new HCPCS G-codes.
These proposals could create meaningful operational and reimbursement implications, particularly for organizations that rely on outsourced monitoring. However, they do not eliminate RTM or change the value of supporting patients between visits. Clinicians will still need visibility into adherence, activity, and progress, and patients will still benefit from continued engagement throughout their care.
For now, clinics should continue operating compliant RTM programs under the current rules, assess how the proposal could affect their staffing and billing model, and consider submitting comments to CMS by September 14, 2026.
At EverEx, we are prepared to adapt to whatever CMS ultimately finalizes while continuing to support physical therapists and protect access to meaningful between-visit care. We are developing a clear path forward for our partners and will continue sharing practical guidance as the rulemaking process develops.
