The 2027 Medicare Final Rule: What Changes for RTM

The Short Version

For calendar year 2027, CMS finalized three of its four proposed remote monitoring policies:

• RTM only for established patients. A practice can no longer start remote therapeutic monitoring for someone it has not already been treating.
• A separately reportable initiating visit is required before RPM or RTM services begin.
• Revalued remote monitoring codes, which lower payment for some device-supply codes.

The fourth policy, paying for RPM and RTM only when the work is done by clinical staff employed by the practice, was delayed two years to January 1, 2029.

A proposal to bundle the RPM and RTM CPT codes into four new HCPCS G-codes was not finalized. CMS said it may revisit it in future rulemaking.

Source: CMS CY 2027 Physician Fee Schedule final rule fact sheet and the AHA summary.

1. RTM Is Limited to Established Patients

From January 1, 2027, RTM services may be furnished only to established patients. CMS proposed this after federal oversight findings that some remote monitoring was billed for patients who had no prior relationship with the billing practice.

For most physical therapy, orthopedic, pain, behavioral health and pulmonary practices this changes little, because RTM already starts after an evaluation or an office visit. It does close off one model: enrolling patients you have never seen, often through a third-party program that recruits them.

What to check now:

• Your enrollment workflow starts after a visit, not before.
• Any outside program that refers patients into your RTM panel only refers patients you already treat.
• Your records show the prior visit clearly for every enrolled patient.

2. An Initiating Visit Before Monitoring Begins

Practitioners reporting RPM or RTM must now furnish a separately reportable initiating visit when starting these services. In practice, remote monitoring has to be discussed with the patient at a visit before billing begins.

Analyses of the final rule, such as Prevounce's breakdown for RPM, describe the details: the visit can be in person or virtual, it doesn't have to be only about monitoring, and patients already enrolled before January 1, 2027 are grandfathered. Confirm how these details apply to RTM against the rule text and your Medicare Administrative Contractor's guidance.

The operational risk is simple: a patient enrolled without a documented initiating visit is a month of RTM you may not be able to bill. Make the visit part of the enrollment step itself rather than something staff remember afterward. Because clinIQ scheduling, check-in and RTM billing run on one platform, the visit and the enrollment sit in the same system instead of two.

3. Revalued Codes and a Lower Conversion Factor

CMS also finalized changes to how remote monitoring services are valued. Two things will move your RTM revenue in 2027.

The conversion factor. The 2027 conversion factor is $32.95 for qualifying APM participants and $32.63 for everyone else, a cut of 1.83% and 2.31% from 2026. Every RTM code is multiplied by it.

Device-supply codes. On the RPM side, the device-supply codes 99454 (16 to 30 days) and 99445 (2 to 15 days) fall about 21%, from $52.11 to $41.11, according to Prevounce's analysis. Treatment-management codes held roughly steady, moving only with the conversion factor.

Check the final RTM rates for 98975 through 98986 in the rule's Addendum B and with your MAC before you rebuild your 2027 projections. The direction is clear: device supply pays less, and the clinical time your staff spend with patients holds more of the value.

4. The Employed-Staff Requirement Is Coming in 2029

The policy with the biggest long-term effect was delayed, not dropped. Starting January 1, 2029, Medicare will pay for RPM and RTM services only when they are performed by clinical staff employed by the billing practice. CMS said the delay gives practices time to adapt, and it plans further guidance before then.

Until then, contracted clinical staff remain permitted under existing incident-to rules. After that date, the common arrangement where an outside company's nurses or therapists do the monitoring and the practice bills for it stops working for Medicare patients.

If your RTM program depends on a vendor's staff, you have two years to bring it in house. That means three things your own team needs: a way to see which patients are transmitting data and which have gone quiet, a record of the minutes each staff member spends, and code selection that matches the days and minutes each month. Those are exactly the parts that make in-house RTM feel too heavy to run without a vendor, and they are what clinIQ RTM billing automates.

What Did Not Change

The 2026 RTM code set carries into 2027. The 2-to-15-day device-supply codes (98984, 98985, 98986) and the 10-to-19-minute treatment-management code 98979 are still available, and the 16-day threshold still applies only to the full-period codes. If you haven't adapted to those yet, read RTM billing in 2026: the new 2-15 day codes.

The bundling of RPM and RTM into four new G-codes was not finalized, so you don't need to rebuild your charge master around new codes for January.

Your Checklist Before January 1, 2027

1. Audit enrollment. Confirm every RTM patient started after a visit with your practice, and that new enrollments will too. 2. Build the initiating visit into intake. Decide which visit types count, and document monitoring at that visit. 3. Re-run your 2027 RTM projections with the new conversion factor and the final device-supply rates. 4. Capture partial months. With device supply paying less, the 2-15 day codes and the 10-minute management code matter more to the total. 5. Plan for 2029 now. If a vendor's staff do your monitoring, map what moving it in house takes: who does the work, how minutes get logged, and what software tracks it. 6. Check commercial payers. Many follow Medicare's RTM policy with a lag; confirm theirs.

For the codes themselves, see RTM CPT codes explained. This article is general information, not legal or billing advice; confirm details with the final rule text and your MAC.