Medicare’s Proposed 2027 Changes to Remote Monitoring

Last updated October 4, 2026. This is a living document; it will be updated as Medicare publishes more.

2027 Fee Schedule Series, No. 1. This paper covers remote monitoring, which is item 48 of the 63 numbered items in the proposed rule’s section on valuing specific services. We will report on other parts of the rule in later papers.

Summary

Medicare has proposed changes for 2027 that would sharply cut what it pays for remote monitoring. The evidence it cites does not support the cut. The rule is not final, but the outlook is not promising.

Device payments fall by about three quarters or more, for both RPM and RTM. The 30-day RTM device payment for behavioral-health monitoring (CPT 98978) would go from about $46 in Arizona to about $12 on January 1, 2027. The 30-day RPM device payment (CPT 99454) and the respiratory and musculoskeletal RTM device payments would go from about $52 to about $41 in 2027, then to about $10 to $13 in 2028.
Management payments are cut as well, but how fast is not clear. The rule removes every practice-expense input from the monthly management codes. Medicare’s proposed payment file then limits the change to about 5% a year, while the rule’s text says that limit does not apply to revalued codes. For the two RTM codes covering the first 40 minutes a month (CPT 98980 and 98981), today’s total of about $96 would be about $89 in 2028 if the 5% limit holds, or about $59 if the rule’s text governs. The RPM management codes are in the same position.
The reasons Medicare gives. The rule says its changes respond to two Inspector General reports. For the payment cut itself, it cites a lack of invoices showing what the devices cost. Its fact sheet adds that the devices “may be available at a reduced cost compared to our initial estimates.”
The reports do not support a payment cut. Both cover RPM only. Both exclude RTM by name. Neither discusses device cost, and neither recommends cutting any payment.
Medicare has not shown what the devices cost. It asked for device costs mainly through its yearly rule, and it gives no figure of its own. In its own cost file, the proposed device payment counts staff time alone, with nothing for the device. Meanwhile its contractor for Arizona has set the payment for the 30-day RTM behavioral-health device code at about $46 a month. The proposed $12 is within pennies of what Medicare pays per month in its new outcome-based ACCESS program for the same conditions.

The law requires the final rule before November 1, 2026. The changes would take effect January 1, 2027.

Background

Medicare pays for two kinds of remote monitoring, and both are recent.

	Remote physiologic monitoring (RPM), often called remote patient monitoring	Remote therapeutic monitoring (RTM)
What it collects	Body measurements, such as blood pressure or weight	How a therapy is going, such as exercises done, inhaler use, or mood and sleep
How the data arrive	Sent automatically by a connected device	Sent by a device or software, and may be reported by the patient
What it covers	Any chronic or acute condition	Respiratory care, musculoskeletal care and cognitive behavioral therapy
Paid by Medicare since	January 2019 (one code, 99091, from 2018)	January 2022
Device codes	99454, 99445	98976, 98977, 98978, 98984, 98985, 98986
Management codes	99457, 99458, 99470	98980, 98981, 98979

The two are easy to confuse. The rest of this paper says in each place whether a point applies to RPM, to RTM or to both.

Each is billed in three parts: a one-time set-up, a device supply payment every 30 days, and a monthly payment for the clinician’s management time. In both cases the device must meet the Food and Drug Administration’s definition of a medical device.

The changes discussed here are in the proposed 2027 Physician Fee Schedule, published July 16, 2026, at pages 43892 to 43895 of the Federal Register. The rule was approved by the Administrator of the Centers for Medicare & Medicaid Services, Mehmet Oz, on July 10, 2026, and signed by the Secretary of Health and Human Services, Robert F. Kennedy, Jr.

What the proposed rule changes

The rule does two separate things: it adds conditions for billing, and it lowers the payments.

New conditions

Established patients only. The rule proposes “to require that RTM services also be furnished only to established patients.” RPM already has this rule.
A starting visit. RPM or RTM “must be initiated by the billing practitioner during a face-to-face (in-person or telehealth) visit.”
Employed staff only. Staff time counts only for “clinical staff employed by the practice,” and the rule “will not allow contracting out to third-party companies.”

Lower payments

For the RTM device codes, Medicare proposes “to crosswalk the direct PE inputs from CPT code 93270,” a 30-day heart-rhythm recording code. For the RPM device codes, it copies the costs of CPT 99474, a self-measured blood pressure code. Its stated reason for both is a concern that “these services are overvalued.” Neither of those codes includes the cost of a device, as the table below shows. For the management codes of both, Medicare proposes “to eliminate PE inputs.”

What the proposed device payment is built from. Medicare publishes the cost inputs behind each code: staff time, supplies and equipment. For the device codes, the proposed inputs are staff time alone.

Codes	Staff time counted	Supplies counted	Equipment counted
All six RTM device codes (98976, 98977, 98978, 98984, 98985, 98986), copied from CPT 93270	22 minutes of a technician’s time, $9.68	None	None
RPM device codes (99454, 99445), copied from CPT 99474	16 minutes of clinical staff time, $8.64	A monitoring app at $6.62 a month is listed, at a quantity of zero	A $1,000 monitoring equipment package is listed, at zero minutes of use
Set-up codes (99453, 98975), copied from CPT 99473	23 minutes of clinical staff time, $12.42	None	None
Management codes (99457, 99458, 99470, 98979, 98980, 98981)	None	None	None

So the proposed payment for supplying an RTM device counts 22 minutes of a technician’s time and no device, software or equipment. Medicare’s formula then adds an allowance for overhead, which brings the payment to about $12 to $13. The rule’s text does not spell this out. It says only that the crosswalk “may more accurately capture the resource costs associated with a typical device.”

A year earlier Medicare had pointed to these same device codes as the place where technology costs belong. In its 2026 final rule it declined to count a software enrollment fee as a cost of RTM set-up, saying that “indirect technology costs associated with RTM are better accounted for in the data transmission RTM codes” (90 FR 49401).

RTM payments

Code	What it pays for	2026	2027 proposed	2028 (our projection)
98978	RTM device, cognitive behavioral therapy, 16 to 30 days	$45.92 in Arizona (set by each regional contractor)	$12.15	$12.15
98977	RTM device, musculoskeletal, 16 to 30 days	$51.44	$41.05	$12.81
98976	RTM device, respiratory, 16 to 30 days	$52.11	$41.38	$12.81
98975	RTM set-up, one time	$21.71	$20.03, or $17.41	$19.05, or $14.12
98980	RTM management, first 20 minutes a month	$54.11	$51.56, or $43.02	$49.92, or $29.89
98981	RTM management, each further 20 minutes	$41.42	$40.07, or $32.84	$39.08, or $29.56

One RTM behavioral-health patient for one month, device plus the first 20 minutes of management: about $100 today (the Arizona device fee plus the national management rate). In 2028: about $62 if the 5% limit holds, or about $42 if the rule’s text governs.

RPM payments

Code	What it pays for	2026	2027 proposed	2028 (our projection)
99454	RPM device, 16 to 30 days	$52.11	$41.38	$9.85
99453	RPM set-up, one time	$21.71	$20.03, or $17.41	$19.05, or $14.12
99457	RPM management, first 20 minutes a month	$51.77	$49.59, or $41.38	$48.28, or $30.21
99458	RPM management, each further 20 minutes	$41.42	$40.39, or $32.84	$39.41, or $30.21
99470	RPM management, first 10 minutes a month	$26.05	$20.69	$15.11

One RPM patient for one month, device plus the first 20 minutes of management: about $104 today. In 2028: about $58 if the 5% limit holds, or about $40 if the rule’s text governs.

Where two figures are shown, the first follows Medicare’s proposed payment file, which applies the 5% limit, and the second follows the rule’s written phase-in terms. The next section explains the difference. Medicare has published no 2028 values; the 2028 column is our projection.

Some codes are not cut. One older RPM code for reviewing 30 days of data, CPT 99091, stays at about $55. Medicare’s digital mental health treatment codes (G0552 to G0554) are not mentioned in the rule. One RTM device code is treated differently in Medicare’s files: CPT 98986, for behavioral-health monitoring of 2 to 15 days. It is about $50 in Arizona today and $31.53 as proposed for 2027, and its “fully implemented” value is higher than the 30-day code’s. We cannot explain the difference.

How the cuts take effect

How fast a code falls depends on which of three rules applies to it.

The two-year phase-in in the law. When a code’s total value would fall by 20% or more, the cut is spread over two years. Medicare treats “a 19 percent reduction as the maximum 1-year reduction” and then “phases in the remainder.” This applies to the RPM device codes and to the respiratory and musculoskeletal RTM device codes. Example: CPT 98977 is valued at 1.54 today; 81% of that is 1.25, or $41.05, in 2027. The rest of the cut follows in 2028.
A proposed 5% cap. The rule proposes that the practice-expense part of a code may not move by more than 5% a year. Medicare’s proposed payment table applies this cap to the set-up and management codes, which is why its 2027 figures for them sit close to today’s.
No limit at all. The 30-day behavioral-health device code, CPT 98978, gets neither protection. It had no national value before, because each regional contractor priced it, and the rule excludes such codes from the 5% cap. Medicare’s files show no phase-in for it either. Its full cut would arrive on January 1, 2027.

An inconsistency in the rule. The rule’s text says the 5% cap “would not apply to revalued codes,” because the two-year phase-in already limits their reductions. The rule does not define “revalued,” but it removes the practice-expense inputs from the set-up and management codes, and Medicare’s proposed payment file applies the cap to them all the same. Only one of those codes, CPT 99470, is on Medicare’s phase-in list. So there are two possible paths. If the cap applies each year, CPT 98980 loses about 5% of its practice-expense value a year and is about $50 in 2028. If the final rule follows its text, those codes take the two-year path and CPT 98980 is about $30 in 2028. This paper shows both.

The 2028 figures are our projections. They use the proposed 2027 conversion factor, because the 2028 factor is not yet known.

The reasons Medicare gives

Medicare opens this part of the rule by saying its changes respond to the Inspector General. For the payment cut itself, the reason it gives is a different one.

For the changes as a whole: two Inspector General reports. The section opens, “In response to recent reports and recommendations from the Office of the Inspector General,” and says Medicare is “proposing refinements to the policies surrounding remote physiologic and remote therapeutic monitoring”. The rule cites the reports for two of the three new conditions: practices that “did not have a prior relationship” with the patients they billed for, and companies “cold calling” patients. It cites no report for the starting-visit condition. It also quotes one finding, “About 43 percent of enrollees who received remote patient monitoring did not receive all 3 components of it, raising questions about whether the monitoring is being used as intended,” when asking for comment on a further idea: replacing the current codes with four bundled codes.

For the payment cut: missing invoices. The rule says, “we have received very little invoice or pricing information from interested parties for the specific devices used in RTM and RPM services.” It says it is concerned that, “due to lack of information regarding the typical device used to perform these procedures, these services are overvalued.” It asks commenters for “robust evidence detailing what providers are actually paying for these devices.” Medicare’s fact sheet puts it differently: “we understand the devices may be available at a reduced cost compared to our initial estimates.” Neither the rule nor the fact sheet gives a figure for what the devices cost.

The two reasons should be judged separately. The next two sections take each in turn.

What the two Inspector General reports say

Both reports are about remote patient monitoring, neither examines device cost, and neither recommends reducing a payment.

	2024 report	2025 report
Title	Additional Oversight of Remote Patient Monitoring in Medicare Is Needed	Billing for Remote Patient Monitoring in Medicare
Issued	September 19, 2024	August 25, 2025
Data studied	2019 to 2022	2024
On RTM	“It does not cover monitoring of non-physiologic data (i.e., remote therapeutic monitoring).”	The same sentence
Growth found	About 55,000 patients in 2019 to more than 570,000 in 2022. Payments from $15 million to more than $300 million (traditional Medicare and Medicare Advantage together)	Nearly 1 million patients in 2024. Payments more than $500 million
Main findings	About 43% of patients did not receive all three parts of the service. For about 44% of patients, Medicare had no record of who ordered the monitoring. The Inspector General and Medicare had both raised fraud concerns, including companies cold-calling patients	Of 4,639 practices that billed routinely, the report flagged outliers on five measures: 32 had sudden jumps in new patients; 45 had no prior relationship with more than 80% of their monitored patients; for 52, more than 75% of patients never had the management service billed; 34 often billed for the same patients as two or more other practices; and about 20 often billed for two or more devices a month per patient
Recommendations	Five, all about oversight. It also repeats an earlier recommendation to make “incident to” billing more transparent	None new. It repeats the 2024 recommendations
On payment rates	Growth in traditional Medicare payments was “not attributable to changes in provider payment rates.” Medicare had “slightly decreased the rates it paid providers” in that period	Nothing
On device cost, prices or invoices	Nothing	Nothing on cost or price. One measure concerns practices billing for two or more devices a month

The five recommendations in the 2024 report were:

Add safeguards so that monitoring is used and billed appropriately.
Require that monitoring be ordered, and put the ordering provider on the claim.
Develop a way to identify what health data are being monitored.
Educate providers about billing.
Identify and monitor the companies that bill for monitoring.

The Inspector General’s tracker, read on October 3, 2026, shows four of the five still open. Only provider education is marked complete.

What this means. The reports describe problems that the new RPM conditions are aimed at, although none of the three conditions is among the Inspector General’s recommendations. The one condition that is new only for RTM, established patients, is justified in the rule by a finding about RPM. The reports do not support the payment cut, and they do not support applying anything to RTM, which neither report examined. The 2024 report’s concerns are broad: 43% of patients lacked a claim for at least one part of the service. The 2025 report flags a few dozen outlier practices on each measure, out of about 4,600, and says its measures “do not confirm that a particular medical practice is engaging in fraudulent or abusive practices”.

The invoice question

The payment cut rests on an absence of invoices. Medicare’s requests for device costs have gone out mainly through its yearly rule, and it has not reported what it learned from its own contractors.

Medicare raises device costs in its yearly fee-schedule rule, which is published in the Federal Register and addressed to “interested parties.” It also accepts invoices by email at any time, at PE_Price_Input_Update@cms.hhs.gov. The record over six rules reads as follows.

Rule	What Medicare said about device costs and invoices
2022	When RTM began, Medicare “sought public comment on the typical type of device(s) and associated costs of the device(s).” The rule records that “the only input to CPT code 98976 is a monthly fee of $25.”
2023	When the behavioral-health device code was created, specialty societies said “there were no invoices” that “could be shared.” Medicare left the price to its regional contractors and said it would work with them “to better understand the kinds of devices and device costs they are encountering.”
2024	Medicare recorded the same commitment, “to better understand the devices and device costs.”
2025	For the digital mental health codes, one party “submitted four invoices reflecting considerable variation in the cost of the DMHT treatment over 30-day and 90-day periods.” Medicare set no national price for the device code, G0552.
2026	Medicare cited a “lack of substantive invoices.” It said that “exclusively using invoices for the valuation of these PE-only services may not result in objective and accurate prices because each interested party that submits invoices has a financial stake in the process.” It said again that it would work with its contractors on device costs.
2027, proposed	Medicare said it had “received very little invoice or pricing information from interested parties for the specific devices used in RTM and RPM services,” said it was concerned the codes are overvalued, and proposed the cut. It reports nothing from its work with contractors.

Three points follow.

Medicare asks for invoices and has also said they may not be reliable. Its 2026 rule said that relying on invoices alone “may not result in objective and accurate prices,” because those who send them have a financial stake. A developer who did respond had reason to wonder whether it would count.
Medicare already had a payment amount in its own files. Its contractor for Arizona published a fee for the 30-day behavioral-health device code of $44.74 a month in 2025 and $45.92 in 2026. That is a payment amount, not a measured device cost, but it is the amount Medicare’s contractor set. The proposal replaces it with about $12.
Other routes were open. Device makers must register with the Food and Drug Administration and list their devices, so they can be identified. Medicare said in three earlier rules that it would work with its contractors to understand device costs. The 2027 proposal reports nothing from that work.

Nothing in the rule shows that a remote monitoring device costs $12 a month to supply. The figure comes from copying the costs of a different service, and Medicare’s own cost file shows that service’s inputs as staff time alone, with no device.

The same price in Medicare’s new outcome-based program

In July 2026 Medicare began a separate, voluntary program called the ACCESS model. It runs for 10 years. Instead of paying for each service, it pays an organization a fixed yearly amount per patient to manage a chronic condition with technology, “with full payment tied to achieving measurable health outcomes.” Medicare describes the difference this way: “Traditional fee-for-service payments are tied to specific activities or devices.” The new approach, it says, “rewards results, not activities”.

Two of the program’s four tracks cover the same ground as RTM: chronic musculoskeletal pain, and behavioral health (depression and anxiety). Medicare’s payment document for the program gives these amounts.

ACCESS track	Yearly allowed amount, first year	Medicare’s 80% share	Per month
Musculoskeletal	$180	$144	$12.00
Behavioral health	$180 ($90 in later years)	$144	$12.00

The proposed RTM device payment would be $12.15 a month for behavioral health in 2027 and $12.81 for musculoskeletal in 2028.

Three points about the ACCESS amount.

It is per patient, not per device. It covers managing the patient’s condition for the year. The allowed amounts “include both the Medicare program payment (80 percent) and beneficiary coinsurance (20 percent).”
Half is held back. “The sum of monthly payments may not exceed 50 percent of the Medicare portion of the annual OAP allowed amount. The remaining 50 percent will be withheld and reconciled after the 12-month care period concludes”. (“OAP” is the program’s name for its outcome-based payment.) An organization earns the full amount only if at least half of its patients meet their outcome targets.
Medicare treats RTM as an alternative to it. For the behavioral health track, the payment document lists RTM set-up (CPT 98975) and the digital mental health codes (G0552 and G0553) among the “substitute services” that reduce an organization’s payment when another provider bills them for the same patient.

The proposed rule does not mention ACCESS, and it describes its device figure as copied from a heart-rhythm recording code. We cannot say whether the match is intended. The proposed RPM device figure does not match the program’s other two tracks, which come to $24 and $28 a month. But for RTM’s two largest uses, the fee-for-service device payment would land within a dollar of what Medicare pays for a whole month of care in its outcome-based program.

What others told Medicare

The proposed rule drew more than 43,000 public comments. We read the 1,076 whose typed text mentions remote therapeutic monitoring. Two limits apply. For those 1,076 we read the text typed into the comment form; 62 of them carry attached letters, which is where organizations put their detail, and we have read only two of those letters in full. Comments that mention only RPM are not in the count. We also read in full two letters from outside that set: the American Medical Association’s, and that of the Connected Health Initiative, a trade group for connected-health technology companies.

Nine in ten were form letters. 964 of the 1,076 came from seven templates. The largest, from physical therapists, was sent 694 times.
The form letters object mainly to the new conditions. The employed-staff rule draws the most opposition. On payment they say little. The physical therapists’ letter asks Medicare to “carefully reconsider proposed reductions to RTM code values.” It also supports Medicare’s wider change to how practice expense is calculated.
None of the 1,076 typed comments gives a before-and-after dollar figure for a device payment. The word “invoice” appears in one. One attached letter does, and its figures match this paper’s: a musculoskeletal RTM company wrote that national payment for its device code “would decline from approximately $51.44 to approximately $12.81.”
About twenty individual and organization letters argue against the device valuation itself. A developer of behavioral-health RTM software wrote that “there is no hardware unit to amortize across patients” and asked for “separate practice expense inputs for non-hardware RTM devices.” A musculoskeletal software company wrote that the heart-recorder code’s “cost assumptions are built around a physical device.” A law firm writing for practices asked Medicare to “set device-supply inputs from invoice-level cost data.”
Several offered Medicare their costs. One RPM technology company offered “to share its actual costs for cellular medical devices, connectivity, logistics, and platform operations with CMS on a confidential basis.” A device supplier wrote: “Publish the cost record for the revised practice expense inputs, and solicit cost data from affected entities before finalizing.”
The physical therapists’ letter makes the same point as this paper about the Inspector General. It says “these proposals are in direct response to the Office of the Inspector General’s concerns with remote physiologic monitoring, not RTM.”
A sign-on letter asks Medicare to stop. Its cover note says “Over 200 organizations respectfully urge the Centers for Medicare & Medicaid Services (CMS) not to finalize its proposed policies” for RPM and RTM.
The American Medical Association asked Medicare to wait. Its letter “strongly urges CMS to pause the proposed reductions and establishment of G-codes while this data is gathered.” It says its valuation committee, the RUC, “is moving up its review of all 19 RPM and RTM codes to January 2027 to review practice expense only.” That review would come after the final rule takes effect.
A trade group says the reference codes contain no device. The Connected Health Initiative wrote: “It is not possible to value a device supply service using a reference code that contains no device.” Medicare’s cost file bears this out, as the table under “Lower payments” shows. The group also disputes that Medicare lacks cost information. It says Medicare has asked about device costs in most years since 2018 and “has received extensive responses.”
The behavioral-health device code was given a national price without explanation. In its 2026 final rule Medicare left CPT 98978 to be priced by its contractors, saying “there is significant pricing variability for these technologies” (90 FR 49404). The 2027 proposal gives the code a national value without discussing the change. The trade group asked Medicare to say whether that was “an inadvertent error.” It also said an advisory committee had recommended “a fifty dollar monthly per-patient price on the basis of submitted invoices.” We have not seen that recommendation ourselves.
A few commenters support the employed-staff rule.

Disclosure: the president of WES Healthcare Solutions filed a comment on August 13, 2026. It opposed the new conditions and, in general terms, the revaluation. It gave no dollar figures.

Who is affected

In our view, the changes fall hardest on independent practices and on the small companies that build monitoring tools for them.

What a practice would be paid. For one RTM behavioral-health patient monitored for one month, a practice in Arizona is paid about $100 today: $45.92 for the device (the Arizona fee) and $54.11 for the first 20 minutes of management (the national rate). In 2028 that would be about $62 if the 5% limit holds ($12.15 and $49.92), or about $42 if the rule’s text governs ($12.15 and $29.89). For one RPM patient, the same month goes from about $104 to about $58, or about $40. A practice has to pay for the monitoring tool and the staff time out of that amount.

Independent practices. A health system can spread a loss across other services. A two-clinician practice cannot.

Small developers. A developer whose software is listed with the Food and Drug Administration as a low-risk device depends on RTM payment. The codes that are not cut, for digital mental health treatment, are open only to devices the agency has cleared or authorized and classified under two specific regulations (21 CFR 882.5801 and 882.5803). That is a long and costly process, and in our experience most small developers cannot fund it.

Patients. Fewer practices offering monitoring means fewer patients followed between visits. The Inspector General’s 2025 report itself says billing oversight can help “ensure that enrollees receive the benefit of remote patient monitoring while, at the same time, minimizing program integrity risks.”

One contrast in the same rule. The rule replaces the office-visit complexity add-on with a modifier worth 16% of the visit. For practices that belong to an accountable care organization, the modifier is worth 32%. An accountable care organization is a group of doctors, hospitals and other providers that takes joint responsibility for the cost and quality of care for its Medicare patients.

What happens next

Nothing is final until Medicare publishes the final rule, which the law requires before November 1, 2026. The changes would take effect January 1, 2027.

The comment period is closed. It ended September 14, 2026. Medicare must respond to the comments it received, and final rules do sometimes differ from proposals.
Payments for 2026 are unchanged. Current rates apply to services through December 31, 2026.
The 30-day behavioral-health device code has the least protection. Its cut would arrive in full on the first day, with no phase-in.

For anyone affected, three steps are still open.

Tell your professional association what the cut would do to your practice, with numbers.
Write to your members of Congress. Congress has adjusted fee-schedule outcomes before.
If you make or buy these devices, send Medicare what it says it lacks: invoices and pricing. It accepts them by email at PE_Price_Input_Update@cms.hhs.gov. The comment period has closed, so invoices sent now may count only toward a later rule.

We will update this paper when the final rule is published.

What Medicare published, and when

Medicare has not published a proposed 2027 dollar figure for any remote monitoring code. The figures in this paper had to be worked out from data files posted alongside the rule, and those files did not all appear at once.

Date (2026)	What happened
June 23	Date inside Medicare’s “Codes Subject to Phase-In” file. It lists seven remote monitoring codes (six device codes and one management code), each with its practice-expense value with and without the phase-in.
July 10	Rule approved by the CMS Administrator.
July 14	Rule placed on public display, with a fact sheet. The fact sheet has one paragraph on remote monitoring and gives no figures.
July 16	Rule published in the Federal Register (91 FR 43842).
July 21	Addendum B, the file holding the proposed 2027 values for every code, replaced with a version marked “Updated 07/21/2026”. The earlier file’s address now redirects to the new one. We found no explanation of what changed. A radiation-services file on the same page was updated the same day.
July 27	“Fully Implemented PE RVUs” file posted. It shows each code’s practice-expense value with the proposals fully in force and none of the limits applied.
September 14	Comment period closed.
Before November 1	Final rule due under the law.
January 1, 2027	Changes take effect, if finalized.

What this meant for a reader trying to work out the effect:

The 2027 figures for every code could be worked out from the Addendum B posted on July 21. We have not been able to obtain the version it replaced, so we cannot say what that earlier file showed.
The 2028 figures for seven codes (device codes 98976, 98977, 98984, 98985, 99454 and 99445, and management code 99470) could be worked out from the phase-in list, to within a few cents. For every other code, including set-up and most of the management codes, the values with no limits applied were not available until July 27, thirteen days after the rule was announced.
Medicare’s own table of dollar effects, “Impact on Payment for Selected Procedures”, does not include a remote monitoring code.

The dates for July 21 and July 27 come from the files themselves and from the dates Medicare’s web server reports for them. All of the files are on the rule’s page on the CMS website.

Where the cut appears. The remote monitoring section of the rule has six lettered parts. The three new conditions come first. The payment cut is the fifth part, under the one-word heading “Valuation.”

Part	Heading in the rule	What it is
(a)	Background and Overview	History of the codes
(b)	Established Patient Requirements	Condition: RTM for established patients only
(c)	Initiating Visit Requirements	Condition: a starting visit
(d)	Supervision Requirements	Condition: staff must be direct employees of the practice
(e)	Valuation	The payment cut
(f)	Comment Solicitation	The idea of four bundled codes

The valuation part gives no dollar amount and no percentage. It does not use the words reduce, decrease or lower. It speaks of a “crosswalk” and of services that may be “overvalued.”

Medicare’s fact sheet of July 14 follows the same order. Its one paragraph on remote monitoring gives the three conditions first. The cut follows in a single sentence: “We also are proposing updates to how these services are valued under the PFS as we understand the devices may be available at a reduced cost compared to our initial estimates.” Neither document says how far payment would fall. A reader had to multiply out the payment files to learn that the device payments would fall by about three quarters.

The comments reflect this. Most of those we read argue about the conditions at length and give the payment cut a single sentence.

How the figures were worked out

The dollar figures in this paper are our own calculations from Medicare’s published files. Medicare publishes relative values for each code, not dollar amounts.

National amounts are the code’s total relative value multiplied by the conversion factor: $33.4009 for 2026 and $32.8409 as proposed for 2027. These are the factors for clinicians who are not in an advanced alternative payment model; the factors for those who are differ slightly ($33.5675 and $33.1693). Amounts are before local adjustment, so a given practice’s amount will differ somewhat.
2028 amounts are our projections; Medicare has published none. Where one figure is shown, it uses Medicare’s “fully implemented” practice-expense file, which shows values with the proposals fully in force and no limits applied, together with the proposed 2027 work and malpractice values. Where two are shown, the first assumes the 5% limit applies again in 2028. All use the proposed 2027 conversion factor. Where two 2027 figures are shown, the second is 81% of the 2026 total relative value, rounded to two decimals, at the proposed 2027 factor.
Arizona amounts for CPT 98978 and 98986 come from the fee file published by Medicare’s contractor for Arizona, Noridian.
Cost inputs for each code come from Medicare’s proposed input files for staff time, supplies and equipment. The dollar amount for staff time is the minutes multiplied by Medicare’s rate per minute for that type of staff.
Quotations are from the documents linked below. Rule text was read from the official govinfo.gov copies of the Federal Register.

This paper is our reading of public documents. It is not legal or billing advice.

Sources

The proposed 2027 rule

Proposed rule, 91 FR 43842, July 16, 2026. Remote monitoring is at pages 43892 to 43895; the phase-in and the 5% cap at pages 43850 to 43851; the visit add-on at pages 43898 to 43903.
Medicare’s page for the rule, with the payment files
Medicare’s fact sheet on the proposed rule
Proposed 2027 relative values (Addendum B)
Proposed 2027 fully implemented values
Codes subject to the two-year phase-in
Proposed 2027 cost inputs for each code (staff time, supplies, equipment)

Current payment

Medicare’s ACCESS model

Inspector General reports

Public comments

Docket CMS-2026-2377 on regulations.gov. We read the typed text of the 1,076 comments that mention remote therapeutic monitoring, through the site’s public data service, on October 3, 2026.

Earlier rules

Prepared by WES Healthcare Solutions.