The 2027 RTM Rule: Initiating Visit, Established Patients and the 2029 Staffing Rule

On January 1, 2027, Medicare will pay for RTM only when the patient is an established patient, and only after the billing practitioner has held a face-to-face initiating visit where RTM was discussed. Patients who are already being monitored before that date do not need the visit to continue. The rule that RTM clinical staff must be direct employees is also final, but it does not take effect until January 1, 2029.

Dates at a glance

Established patients only

CMS finalized that RTM be furnished only to established patients. It used the definition from elsewhere in the fee schedule: an established patient "has received any professional services from the physician or other qualified health care professional or another physician or other qualified health care professional of the same specialty who belongs to the same group practice within the past three years."

Therapists get a different test. For physical therapists, occupational therapists and speech-language pathologists, CMS wrote that an established patient "is one who is receiving services furnished under a therapy plan of care that may extend throughout the length of that episode of care."

New patients have a way in. CMS said "a beneficiary may be considered an established patient after they have met the initiating visit requirements."

The initiating visit

CMS finalized the initiating visit as proposed. It must happen before RTM begins, with the billing practitioner, face to face, in person or by telehealth. In CMS's words: "Billing for RPM or RTM services may not begin until the initiating visit has been furnished." Consent still applies; see our RTM consent guide.

What counts

• A face-to-face visit with the billing practitioner, in person or by telehealth under section 1834(m) of the Act.
• A visit where RTM was discussed. It "does not have to be for the sole purpose of discussing remote monitoring services."
• Any gap before monitoring starts. CMS set no time limit, "as long as RPM or RTM is discussed with the patient at that visit."
• A separately billable visit. CMS said the visit "can be separately billable, but does not have to be in all scenarios," and pointed to its CY2024 discussion of remote monitoring in a global period (88 FR 78883 through 78884). See our global period guide.

What does not count

• A code with no face-to-face visit by the billing practitioner.
• A visit where RTM never came up.
• A code that is not separately payable under Medicare. CMS lists this as disqualifying, and also says the visit need not be separately billable "in all scenarios." The rule does not reconcile the two, so a separately billed visit is the safe path.

CMS did not list which visit codes qualify. It finalized no exemptions, including for ACO-aligned patients, and no extra documentation.

The visit comes once. CMS said: "A separate visit is not required for routine clinical changes, which could include, but are not limited to a change of device, clinical change, or change of billing practitioner within the same practice." Onset, it wrote, is "at the billing provider level." It did not define onset further.

One open question for groups: can another clinician in the practice furnish the visit? CMS only restated that physicians in the same group and specialty "must bill and be paid as though they were a single physician." Ask your MAC.

After December 31, 2027, absent further legislation, telehealth for the visit "will be limited by the requirements of section 1834(m) of the Act that remain in effect." For who can bill RTM at all, see our guide.

Patients you already monitor

CMS agreed that a new visit for current patients "would be particularly burdensome." Its final language: beneficiaries "who are already receiving remote monitoring services before this policy becomes effective on January 1, 2027, would not need to have an initiating visit to continue remote monitoring services, so long as all other requirements for these services are met."

Two cautions. First, CMS "discourages any misuse of enrolling beneficiaries in remote monitoring services between the publication of this rule and January 1, 2027." Read that as a warning against bulk enrollment before the date. Second, the exemption is written about the initiating visit. "All other requirements" most plausibly includes the established patient rule, though CMS does not say so.

The 2029 staffing rule

CMS proposed that RTM time count only when clinical staff are direct employees of the practitioner or practice. Commenters asked for a delay. CMS gave one: "a 2-year delay in implementation to allow for practices to hire and train staff." Beginning January 1, 2029, the codes "cannot be billed in cases where the service is not performed by clinical staff that is a direct employee of the practitioner or the practitioner's practice and contracting out to third-party companies will not be allowed after that time."

If a company's nurses or call center do your monthly management time, that is the arrangement affected. Until December 31, 2028 it is still allowed, but "all of the existing 'incident to' and other rules" must be met. Where a third party is not integrated with the billing practitioner, CMS said the practitioner "should not bill." See our incident-to guide.

Software is different. The policy "would not prohibit working with vendors who do not supply third-party staff time, but supply software, devices, technical support, etc." CMS did not define "direct employee" and will publish sub-regulatory guidance on staff arrangements before 2029.

What did not change

• The code family. The CPT codes continue, including 98975, 98977, 98985, 98979, 98980 and 98981 for musculoskeletal RTM. CMS asked for comment on four bundled G-codes (GRPM1, GRPM2, GRTM1, GRTM2) and did not adopt them. It will consider the comments "for possible future rulemaking."
• Supervision. These services stay on general supervision. CMS is "not finalizing any changes to supervision requirements or to the regulation text under § 410.26."

Valuation

There are no 2027 dollar amounts here. The final rates live in Addendum B, and the 2027 rate table will follow once the addenda are verified. The 2026 rates are in the 2026 RTM rate table.

CMS finalized its proposed practice expense inputs for setup and device supply, including 98975, 98977 and 98985. Its stated concern is that "these services are overvalued," because it has little invoice or pricing data on the devices. Plan for lower values on those codes, not higher.

CMS did not finalize its proposal to remove practice expense inputs from treatment management, 98979, 98980 and 98981. It agreed that "clinical staff are often used when furnishing treatment management services."

Some reductions will phase in. Section 1848(c)(8) of the Act spreads decreases of 20 percent or more over two years, and CMS wrote that "many of these changes will be phased in over multiple calendar years." CMS also said all 19 RPM and RTM codes will have practice expense reviewed at the January 2027 RUC meeting.

A practical checklist for December 2026

1. List every patient now in RTM, with the date monitoring started. That date supports the exemption.
2. Do not rush enrollments to beat the date.
3. Build the visit into the 2027 workflow: who holds it, and where the note says RTM was discussed.
4. Check established status before the first claim: for PT, OT or speech-language pathology, confirm the patient is receiving services under a therapy plan of care. For other practitioners, check for professional services from the practitioner or a same-specialty practitioner in the same group within the past three years. The rule also addresses patients who establish care at the initiating visit.
5. Map your staffing. For each patient, who does the monthly calls and time, an employee or a contractor?
6. Ask vendors what they supply, and send your open questions to your MAC: which visit codes qualify, and who in a group can furnish the visit.
7. Hold 2027 revenue modeling until verified rates are published. The billability gates still apply.

BoneArc is RTM software. Your own clinicians furnish and approve the care, and the software tracks RTM requirements for each patient. If you want to see how that works for a PT or orthopedic panel, you can book a demo.

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