Frequently Asked Questions
CMS has issued a proposed rule for calendar year 2027 that includes potential changes affecting how certain remote patient monitoring and remote therapeutic monitoring services may be furnished.
The proposal is not final. Current Medicare RPM and RTM services remain in place, and CoachCare-supported programs continue operating under existing requirements while the proposal moves through the public-comment and rulemaking process.
What is the current status of Medicare coverage for RPM and RTM?
Medicare coverage for remote patient monitoring and remote therapeutic monitoring remains in place.
CMS has issued a proposed rule for calendar year 2027, but the proposed policies are not yet final. Current Medicare remote-monitoring services and CoachCare-supported programs continue operating under existing requirements while CMS reviews public comments and completes the rulemaking process.
What is CMS proposing?
CMS is considering changes that could affect how certain RPM and RTM services are furnished, including requirements related to clinical staff and third-party support arrangements.
Healthcare providers, industry organizations and policy experts are reviewing the full proposal to understand how the language could apply in real-world clinical settings and what operational changes might be required if the proposal is finalized.
Why are healthcare organizations concerned?
Many medical practices rely on a combination of internal clinical leadership, qualified clinical teams and specialized technology or service partners to operate remote-monitoring programs efficiently.
These models help practices monitor patients between visits, respond to concerning readings, reinforce care plans and escalate issues to the appropriate clinician without requiring every practice to build an entirely new internal department.
If finalized as currently proposed, the changes could require some practices to restructure their staffing models, increase administrative and employment burdens, or reduce the number of patients they are able to support.
Does the proposal affect CoachCare customers today?
No immediate changes are required.
The proposal is not final and would apply to future Medicare payment policy. CoachCare is continuing to support customers under current requirements while carefully evaluating the proposed language and participating in the policy and advocacy process.
Customers should continue following their existing clinical, documentation, billing and supervision procedures unless authoritative guidance changes.
Will practices need to employ every person involved in remote monitoring?
That question is at the center of the current policy discussion.
Stakeholders are seeking greater clarity regarding which personnel arrangements CMS would allow, which activities may be supported by external clinical teams and how any employment or supervision requirements would apply in practice.
The final answer will depend on the language CMS adopts in the final rule and any subsequent agency guidance. CoachCare will provide customers with updates as authoritative information becomes available.
Why does CoachCare believe employment status is the wrong measure of quality?
Clinical accountability depends on how care is delivered, not simply on which organization employs the individual performing a particular task.
A responsible remote-monitoring program should be evaluated based on factors such as appropriate physician oversight, qualified and licensed personnel, documented workflows, timely escalation, patient consent, data integrity, billing compliance and measurable clinical outcomes.
Employment classification by itself does not establish whether a remote-monitoring program is clinically responsible, compliant or effective.
Does CoachCare support stronger oversight of RPM and RTM?
Yes. CoachCare supports meaningful safeguards designed to prevent abuse, protect Medicare beneficiaries and ensure that remote monitoring delivers legitimate clinical value.
We believe standards should focus on measurable accountability, appropriate supervision, patient engagement, transparent documentation, clear escalation protocols, data integrity and quality outcomes.
Oversight should distinguish between clinically responsible programs that extend a practice’s care capacity and arrangements that generate billing activity without delivering meaningful patient support.
Could this proposal affect patient access?
Potentially.
Practices with limited staffing resources—particularly independent, rural and underserved providers—may depend on integrated external clinical support to make remote monitoring available at scale.
Requirements that significantly increase fixed staffing, employment or administrative burdens could make these programs more difficult or expensive to operate. Some practices could be forced to reduce enrollment, limit services or discontinue remote-monitoring programs altogether.
Could smaller and independent practices be affected differently?
Yes. Larger health systems may have more internal staffing and administrative infrastructure available to absorb new operational requirements.
Independent and community-based practices often operate with smaller teams and tighter margins. These organizations may rely more heavily on qualified partners for technology, patient outreach, clinical support, documentation workflows and operational infrastructure.
A requirement that may be manageable for a large health system could create a disproportionate burden for a small cardiology practice, rural clinic or community provider.
What is CoachCare doing in response?
CoachCare is working with industry associations, healthcare providers, legal and policy experts, customers and other stakeholders to:
- Evaluate the proposed language and its potential operational impact
- Identify areas requiring clarification or modification
- Develop constructive policy alternatives
- Educate healthcare providers, patients and policymakers
- Support coordinated public comments
- Share real-world evidence related to patient access, clinical accountability and outcomes
- Communicate directly with CMS and policymakers
Our goal is to support appropriate oversight while protecting sustainable, clinically accountable remote-monitoring models.
What should CoachCare customers do now?
Customers should continue operating their programs under current Medicare requirements. No immediate program restructuring is required based solely on the proposed rule.
Customers should continue maintaining strong clinical oversight, accurate documentation, clear escalation workflows and compliance with existing billing and supervision requirements.
Organizations may also wish to identify clinical leaders, practice administrators, patients or other representatives who can explain how remote monitoring supports access, outcomes, timely intervention and practice capacity.
Additional advocacy tools and educational resources will be shared as they become available.
Can healthcare providers comment directly to CMS?
Yes. CMS proposed rules include a formal public-comment period during which individuals and organizations may submit feedback.
Comments are often most effective when they include specific, real-world information about how a proposed policy would affect patients, clinical operations, staffing, access to care and healthcare costs.
CoachCare and its industry partners expect to provide additional information and resources to help interested organizations participate effectively.
Should practices make staffing or contracting changes now?
Practices should avoid making major operational changes based solely on proposed language unless advised to do so by their own legal, compliance or reimbursement counsel.
The proposal may change before the final rule is issued, and additional clarification may emerge through the rulemaking process.
Organizations should remain informed and evaluate potential scenarios without assuming that every element of the proposal will become final policy.
When will the final policy be known?
CMS will review public comments before issuing a final rule for calendar year 2027.
The final policy may differ from the initial proposal. CoachCare will update this page as CMS releases additional information, including the final rule and any relevant implementation guidance.
Where can I get updates?
CoachCare will update this page as the policy process develops.
Customers may also contact their CoachCare representative with questions about their programs. Additional policy updates, advocacy resources and educational materials will be shared as they become available.
The Alliance for Connected Care is hosting a large group meeting with stakeholders to share our current advocacy tactics, resources, and coordinate a robust response. Please join a stakeholder call on Tuesday, July 28, at 2:00 p.m. ET
