I spent the last five years building and running Medicare care management programs designed to optimize patient outcomes and decrease cost. We built the teams, the workflows, the vendor relationships, and the clinical protocols. A significant part of that infrastructure ran on remote patient monitoring and the insights it can provide when combined with a clinical model designed to act on this data.
So when I read the 2027 proposed Physician Fee Schedule rule, I did not read it as a policy document. I read it as a description of the programs I have built, and what happens to them on January 1, 2027 if this rule is finalized.
Here is what the rule says and what I think it actually means for the practices and health systems working hard to serve their Medicare populations.
What CMS Is Proposing
On July 14, 2026, CMS published the CY2027 Medicare Physician Fee Schedule proposed rule. Buried inside a 1,592-page document is a provision that would fundamentally change how remote physiologic monitoring and remote therapeutic monitoring can be billed.
The proposal: practices would be required to directly employ the clinical staff members who perform the monitoring. Outsourced vendor staffing would no longer be allowed under Medicare billing.
If finalized, the changes would become effective January 1, 2027. That is five months from the comment deadline of September 14, 2026.
CMS grounds this proposal in OIG reports finding that 43 percent of enrollees receiving RPM services did not receive all three billed components, and that some vendors engaged in unsolicited cold-calling of beneficiaries. Those are real problems worth addressing. Nobody in value-based care wants low-quality, high-volume billing driving this space.
But the proposed remedy, a blanket direct-employment requirement, does not distinguish between bad actors and the clinically integrated programs that are genuinely keeping patients out of the hospital.
What It Means on the Ground
I want to be direct about what this looks like operationally, because the policy language can obscure it.
Most practices that run effective RPM programs today do so through vendor partnerships. Remote monitoring services require providing devices to patients, data integration, machine learning and analytics capabilities to parse the data, and clinical teams to monitor the data, intervene and provide care management services. Building all of that in-house is not a realistic six-month project for the vast majority of practices.
Many providers cannot build their own RPM programs in six months given the January 1, 2027 deadline. The choice will effectively be: end these programs or build all that capability in-house. Most will end the programs.
For patients with chronic kidney disease, hypertension, heart failure, and diabetes, these are not administrative inconveniences. These programs are often the most consistent clinical touchpoint they have between office visits. Losing that between-visit monitoring and support does not make them safer. It leaves a gap.
The Shift Nobody Is Connecting Yet
Here is where I think the conversation needs to go, and where I have not seen enough people connecting the dots.
CMS is simultaneously tightening who can deliver RPM under the Physician Fee Schedule and expanding who can deliver technology-supported chronic care under ACCESS.
These two things are not moving in opposite directions. They are moving in the same direction.
The OIG's concern with outsourced RPM was always about fragmentation: vendors with no real relationship to the treating clinician, billing for services that were not fully delivered, operating outside the clinical record. Those are legitimate concerns. The problem is not technology-supported care. The problem is technology-supported care that is disconnected from the patient's actual care team.
CMS ACCESS was designed to solve exactly that problem. It pays for outcomes, requires bidirectional PCP communication, and mandates that care updates reach the referring clinician at key clinical milestones. The accountability structure is fundamentally different from fee-for-service RPM billing. ACCESS is not paying for a device supply code and a monitoring time code. It is paying for whether a patient's blood pressure actually came down over 12 months.
What CMS is signaling with the RPM proposal is not that it wants less technology in chronic care. It wants technology-supported care that is integrated, clinically accountable, and tied to a treating relationship. That is precisely what the ACCESS model is structured to reward.
What Practices Should Be Thinking About Now
If you are running an RPM program today through a vendor relationship, you need to take this proposal seriously regardless of whether it gets finalized exactly as written. The comment period closes September 14. The direction of travel is clear even if the final rule shifts the details.
Three things I would be doing right now:
Evaluate your current program against the proposed requirements. Does your vendor's clinical staff work under the general supervision of your billing practitioner? Are your monitoring workflows integrated into the patient's medical record in a meaningful way? If a CMS auditor looked at your RPM billing tomorrow, could you demonstrate clinical integration and physician oversight across every enrolled patient?
Submit comments before September 14. CMS explicitly invited feedback on how the direct-employment requirement would affect access to remote monitoring, particularly for rural and underserved populations. The agency needs to hear from the practices that have built legitimate, clinically integrated programs, not just from vendors with business models at stake. Your operational experience has more credibility in a comment letter than any policy argument.
Think seriously about ACCESS as the long-term reimbursement framework for between-visit chronic care. The RPM billing model was always a fee-for-service approximation of something closer to what ACCESS actually pays for: continuous management of a patient's chronic condition, with accountability to outcomes. If the FFS RPM codes become harder to bill and the ACCESS outcome-aligned framework is already live, the question is not whether to move toward outcomes-based between-visit care. It is how to get there without leaving your highest-risk patients unmanaged in the transition.
Why I Joined Innovaccer
I want to be transparent about where I sit in this conversation now.
I spent the last 5 years building exactly the kind of programs this rule affects. I hired the teams, managed the vendor relationships, built the workflows, and watched what happened to patients when the between-visit support was consistent versus when it was not. I joined Innovaccer because I believe the ACCESS model represents the right long-term structure for this work, and because Story Health by Innovaccer is built around the clinical accountability principle that the proposed RPM rule, however disruptive to current vendor models, is ultimately trying to enforce.
The programs that will survive this shift are not the ones that found a billing workaround. They are the ones that built real clinical relationships with patients between visits, kept referring providers in the loop, and measured whether the care they delivered actually moved outcomes.
That is the only version of this work worth doing. And it is the version CMS is increasingly paying for.