Industry stakeholders seek middle ground on CMS’s third-party RPM proposed rule

The proposed rule from CMS that would end Medicare payment for third-party monitoring has stirred an outpouring of responses from industry stakeholders. The public comment period for the rule remains open through Sept. 14, and hundreds of health systems, vendors and industry groups have responded.

If the rule is finalized, health care providers are faced with the prospect of bringing RPM in-house or dropping the service by Jan. 1, 2027. RPM vendors would need to reimagine their business models. 

Public comments recognize the concerns behind the payment policy change, but industry stakeholders are urging CMS to take a more balanced approach. Finding a way to address critics’ concerns about operational disruption and CMS’s desire to prevent fraud and abuse could pave the way for the future of RPM reimbursement. 

Industry stakeholders decry the anticipated operational disruption 

Approximately 1 million Medicare beneficiaries received RPM services in 2024, according to the Office of Inspector General (OIG) “Billing for Remote Patient Monitoring in Medicare” report released in 2025. Public comments raise the alarm that the proposed rule could disrupt the care those patients are receiving. 

As of Aug. 26, more than 200 organizations have signed a letter to CMS. It warns that if finalized, “providers will be forced to reduce enrollment, terminate programs or stop offering remote monitoring altogether.” 

RPM and chronic disease management company Cadence expressed similar concerns in a letter to CMS. Meryl Holt, the company’s general counsel, told DHI, “Our experience suggests that no health system and no independent provider group will be able to simply take on all of the effort and investment required to stand this up internally.”

If any providers do have the resources to bring RPM in-house to comply with the proposed rule’s direct-employment requirement, doing so by the end of the year would be a very short timeline.

“Just that process of hiring and training staff would be hard to do by the end of the year, let alone all the other steps for an institution to get internal reviews and approvals and allocation of resources to make it happen,” Seth Martin, MD, MHS, professor of medicine, division of cardiology at Johns Hopkins University School of Medicine, said.

The proposed rule sets up a potential clash with the Rural Health Transformation Program

Public comments call out the potential implications the proposed rule has for the Rural Health Transformation Program (RHTP), via which CMS awarded states funding for five goals. Among those goals is tech innovation. In the first year of funding, 22 states have announced or given approximately $240 million in funding for RPM, according to the Alliance for Connected Care.  

The Alliance warns that “CMS is potentially jeopardizing the state’s RHTP dollars with this proposal.” Many rural hospitals do not have the resources to bring RPM in-house, and states could fail to achieve RHTP goals. 

“A lot of these remote patient monitoring programs were budgeted on the presumption and the expectation that these codes are going to be operational in 2027 and beyond,” James Mault, MD, founder and executive chairman of continuous health monitoring company BioIntellisense and founding member of the Remote Monitoring Leadership Council, said. “You take these codes away and a large portion of these remote patient monitoring programs funded by the Rural Health Transformation Program. They won’t be able to operate.” 

Public comments call for a different approach to cracking down on RPM fraud

The impetus behind the proposed rule is the fraud, waste and abuse concerns raised in 2024 and 2025 OIG reports. Industry stakeholders are not denying the existence of fraud, but they are seeking a different approach than the direct-employment requirement to address it.  

“We believe that there are guardrails that are immediately available to CMS that would actually get at those legitimate concerns and be auditable. Specifically, we think that CMS should enforce its existing clinical integration standards for RPM,” Holt said.

Mault argues that the existing RPM codes have significant room for improvement.

“Let’s do that in a way that eliminates or minimizes any fraud and abuse,” he said. “Just by adding rational inclusion criteria for the right patient population, the right conditions, it’ll go a long way to suddenly showing a demonstrable ROI.”

How a middle ground could build a bridge to the future of remote care

As the industry waits for the public comment period to close, there is hope that CMS will take the feedback into consideration before finalizing the rule.

“I have a lot of confidence that CMS will take that input very seriously,” Martin said.

If CMS does decide to incorporate feedback from industry stakeholders before finalizing the rule, what could a middle ground look like?

The letter signed by hundreds of stakeholders calls for CMS to “delay the proposed remote monitoring policies and work with stakeholders on a balanced approach that protects patients, preserves clinically integrated care, and strengthens program integrity protections.”

Stakeholders want an alternative to the direct-employment requirement. Martin hopes to see greater flexibility in the final rule.

“I like the idea of having a clear team that takes ownership of the data to help support a patient in getting better and having that clinical integration,” he said. “But the exact kind of organizational structure and the way things are integrated, I think that’s where you don’t want to be too heavy-handed and disrupt models that actually can help patients.”

Whatever the outcome, CMS is signaling that RPM payment is changing. In addition to the direct-employment requirement, CMS is seeking comments on bundling codes for RPM and remote therapy monitoring (RTM) and creating new codes. 

“This represents a maturation of the field and a transition towards making sure that this is meaningful clinical care that’s being delivered to patients…not just device utilization and data collection,” Martin said.

The future of RPM, and care in general, could be more outcomes-based, but it will take time and more than this proposed rule to get there.

The ACCESS (Advancing Chronic Care with Effective, Scalable Solutions) Model offers a window into what the future could look like. The 10-year program, which began on July 5, 2026, tests the expansion of tech-supported care and payment aligned with outcomes.

Mault argued that the ACCESS Model is a starting point, not the sole answer to replacing third-party RPM. “It’s an experiment. It has to prove itself,” he said. “In the meantime, just crushing the ability to use these RPM codes for all the good that they could be used for is just…short-sighted.”

CMS has covered RPM since 2018, but the delivery of remote care is changing considerably with the evolution of medical-grade wearables and artificial intelligence. RPM could become less about monitoring and more about management.

“In a way the changes that are being proposed, as well as the work that’s happening with the CMS ACCESS program, are representing a transition to this future that I think could be very bright for patients,” Martin said. “My hope is that the proposed changes are refined in a way that ends up serving as a really nice step into this next chapter.”

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Carrie Pallardy, a Chicago-based freelance writer and editor, began her career covering healthcare more than a decade ago. Her work has taken into many different industries, but covering healthcare delivery remains a constant focus. She can be reached at [email protected] or on LinkedIn.