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 provided.
The proposal language is not final. Current Medicare RPM and RTM services remain in place. CoachCare-supported programs continue operating under existing requirements while the proposal moves through the 60-day public-comment and ruling 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 issued a proposed rule for calendar year 2027. A final ruling is expected by November 1. Current Medicare remote-monitoring services and CoachCare-supported programs continue operating as usual while CMS reviews public comments and completes the rule-making process.
What is CMS proposing?
CMS is considering changes that could affect how certain RPM and RTM services are offered, including requirements related to clinical staff and third-party support arrangements.
Healthcare providers, trade associations, nonprofit and industry organizations and policy and legal experts are reviewing the proposal to understand how the language could apply in everyday 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 with medical necessity between office visits, reinforce care plans and escalate issues to the appropriate clinician without requiring every practice to build an entirely new department.
If finalized as currently proposed, the changes could require some practices to restructure their staffing models. An increase in administrative and employment burdens and expenses can push small practices to the point of being too costly to operate. Or worse, reduce the number of patients they are able to support as America’s aging and complex care populations swell.
Does the proposal affect CoachCare customers today?
No immediate changes are required.
The proposal is not final and, if adopted, would apply to the 2027 Medicare Physician Fee Schedule. CoachCare continues to support its customers under current Medicare requirements while the rulemaking process moves forward.
CoachCare and the Remote Monitoring Leadership Council (RMLC) are actively evaluating the proposed language, working with healthcare providers, legal and policy experts, and participating in the public comment process. In June 2025, CoachCare’s co-founder and CEO testified before the House Ways & Means Health Subcommittee on behalf of the RMLC to advocate for clinically accountable remote monitoring programs that preserve patient access while supporting appropriate oversight.
Customers should continue following their existing clinical, documentation, billing, and supervision procedures.
Will practices need to employ every person involved in remote monitoring?
This question is at the center of the current policy discussion.
Clinicians, regulatory lawyers and their clinical support technology partners all seek 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 to patients deemed medically necessary for remote-monitoring programs.
The final answer and any subsequent agency guidance will depend on the feedback, questions and concerns expressed during the 60-day public comment timeframe. CoachCare will also provide customers with updates as information becomes available.
Why does CoachCare believe employment status is the wrong measure of quality?
Clinical quality and accountability depends on how care is delivered as well as the safety and compliance guardrails in place, not simply on which organization employs the individual performing a particular task.
A responsible remote-monitoring program should be evaluated based on appropriate physician oversight, qualified and licensed personnel, documented workflows, timely escalation, patient consent, data integrity, billing compliance and measurable and improved clinical outcomes.
Employment classification by itself does not establish whether a remote-monitoring program is clinically responsible, compliant or effective.
CMS is right to demand appropriate physician oversight, complete services, measurable outcomes, billing compliance, and reimbursement integrity. However, prohibiting contracted clinical support risks dismantling the clinically accountable infrastructure that enables many physician practices to deliver remote monitoring at scale.
The answer is stronger accountability, not employment status as a proxy for quality. Remote monitoring programs should be evaluated based on clinical oversight, qualified personnel, documented workflows, patient safety, compliance, and measurable outcomes. Protecting those standards while preserving access to care is a more effective path than restricting care delivery models that have demonstrated meaningful clinical value.
Does CoachCare support stronger oversight of RPM and RTM?
Yes. CoachCare supports meaningful safeguards designed to maintain compliance, hold reimbursement integrity, validate medical necessity, protect Medicare beneficiaries and ensure that remote monitoring delivers legitimate clinical value.
We believe support for tighter 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 transparency and without delivering meaningful patient support and outcomes.
Could this proposal affect patient access?
Yes. Industry experts estimate that up to 1 million rural and aging Americans could lose access to remote monitoring if the proposal is finalized without modification.
Practices with limited staffing resources, particularly independent and rural providers seeing underserved patients, 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 put small practices out of business, and make these programs more difficult or expensive to operate for other practices. Some 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 greater administrative infrastructure, shared resources, and internal staffing available to absorb new operational requirements.
Independent, rural, and community-based practices often operate with smaller teams and tighter margins. These organizations may rely more heavily on qualified technology and clinical support partners to provide remote monitoring efficiently while maintaining physician oversight, documentation, and compliance.
Requirements that significantly increase staffing or administrative burdens may create a disproportionate challenge for smaller practices. In some cases, practices may need to reduce enrollment, limit services, or reconsider whether remote monitoring remains financially sustainable.
As a result, the proposal could have a greater impact on the independent, rural, and community-based practices that care for many Medicare beneficiaries, including older adults and underserved populations.
How will CoachCare respond?
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 for compliance and transparency
- Educate healthcare providers, patients and policymakers
- Support coordinated public comments
- Share real-world evidence related to patient access, clinical accountability, improved outcomes, and compliance and reimbursement integrity
- Communicate directly with CMS and policymakers
Our goal is to support relevant oversight while protecting sustainable, clinically accountable remote-monitoring models.
What should practices that partner with CoachCare do now?
Customers should continue operating their programs as they always have under current Medicare requirements.
Customers should continue maintaining strong clinical oversight, accurate documentation, clear escalation workflows and compliant procedures 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, and timely intervention as an extension of their practice’s 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 60-day public-comment period during which individuals and organizations may submit feedback.
Your experience matters. CMS considers public comments when developing the final rule. Organizations and individuals with firsthand experience delivering or participating in remote monitoring programs are encouraged to share how the proposed changes could affect patient access, quality of care, and clinical operations.
CoachCare and its industry partners expect to provide additional information and resources to help interested organizations participate effectively. To receive this information, contact us and reference PFS resources in your message.
Should practices make staffing or contracting changes now?
Practices should continue operating their programs as they always have under current Medicare requirements. Avoid making major operational changes unless advised by legal, regulatory or reimbursement counsel. Organizations should remain informed, evaluate potential scenarios, and seek clarification as the rule making process evolves into a final policy issued.
When will the final policy be known?
CMS will review public comments before issuing a final rule for calendar year 2027, which is anticipated by November 1.
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 an online meeting with stakeholders to share current advocacy tactics, resources, and robust responses. Please join this stakeholder call on Tuesday, July 28, at 2:00 p.m. ET
Readers interested in the complete regulatory language can review the complete Calendar Year 2027 Medicare Physician Fee Schedule Proposed Rule.
