On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) released the 2027 Medicare Physician Fee Schedule (PFS) Proposed Rule. The rule outlines potential changes to Medicare payments, quality reporting, remote patient monitoring (RPM), and other programs beginning January 1, 2027.

While the proposal still requires review and public comment, several specific provisions could have meaningful implications for  care management organizations. Here are some of the biggest takeaways.

1. CMS is proposing changes to third-party RPM services

One of the most significant proposals involves who may furnish certain RPM services under a billing practitioner’s supervision.

Some practices currently partner with third-party vendors whose clinical staff monitor patient data, communicate with patients, and document care. CMS is proposing to require clinical staff furnishing these services be employed by the billing practitioner or practice.

If finalized, the change could require organizations using outsourced clinical services to review or restructure their RPM programs. It would not necessarily prevent practices from working with partners for connected devices, patient data, workflow automation, or billing support. Instead, it could place greater responsibility for clinical care delivery with the billing organization.

Evaluating workflow and patient clinical care will be crucial feedback to CMS during the open comment period – especially for practices that rely on these vendor partners to monitor their patients. An in-house or hybrid model may provide greater control over:

  • Patient communication and clinical decisions
  • Escalation protocols
  • Documentation standards
  • Coordination with the patient’s broader care plan
  • Compliance and billing oversight

However, the right approach will depend on each organization’s staffing, workflows, patient population, and existing vendor relationships. Because this is still a proposed rule, practices should monitor the final policy before making major operational changes.

2. Proposals to Bundle RPM and RTM codes

To address concerns of administrative burden of the RPM and RTM families of codes and to implement recommendations from the OIG, CMS has proposed bundling all remote monitoring codes (RPM and RTM)  together into 4 new G-codes.  

This proposal has a specific call to solicit comment from stakeholders – CMS wants to hear feedback regarding this bundling consideration.

  • All current code conditions will still need to be met
  • Proposals for established patient, initiating visit, and supervision will still apply if finalized
  • This new structure would reduce the current number of RPM/RTM codes from 17 to 4
  • Proposed codes would bundle continuous month time and device readings as one code

These proposals directly address many of the concerns the OIG raised in 2024 and are important to review and make comment on, as this is specifically what CMS is requesting.

3. CMS is continuing its shift toward value-based care

Across the proposed payment and quality changes, CMS continues to emphasize prevention, coordinated care, and better management of chronic disease.  These conditions require ongoing management that extends well beyond periodic appointments.

This direction reinforces the role of care management and remote monitoring as part of everyday healthcare delivery. Effective programs give care teams the information needed to recognize changes earlier, contact the right patients, and intervene before a developing issue becomes an emergency.

CMS is proposing adjustments to how accountable care organizations earn shared savings and manage financial benchmarks. The rule also includes policies intended to support participation and improve the accuracy of performance calculations.

For practices, this continued shift increases the value of staying connected with patients between office visits. Remote monitoring and care management can help organizations:

  • Identify rising-risk patients earlier
  • Support medication and treatment-plan adherence
  • Improve coordination across care teams
  • Reduce avoidable emergency department visits and hospitalizations
  • Maintain a more complete view of a patient’s health

Care delivered between visits can play an important role in both patient outcomes and value-based performance.

4. Quality reporting would undergo major changes

CMS is also proposing significant updates to the Quality Payment Program, including a future transition away from the Merit-based Incentive Payment System’s traditional reporting structure.

The proposed changes are intended to reduce reporting burden and create a more focused approach to measuring quality. CMS is also proposing additional MIPS Value Pathways related to diabetes, hypertension, and hospital-based care, along with new core quality measures.

These proposals suggest that CMS wants quality reporting to align more closely with meaningful clinical outcomes and preventive care.

For organizations managing patients with chronic conditions, the ability to collect longitudinal health information could become even more valuable. Connected devices, patient-reported information, and documented care activity can provide a clearer picture of what happens outside the exam room.

5. Physician payment rates would decrease slightly

CMS is proposing two separate 2027 conversion factors, depending on whether a clinician qualifies as an Advanced Alternative Payment Model participant.

The proposed conversion factors represent a slight decrease from 2026 levels. While the percentage changes may appear modest, even small reductions can affect organizations already facing higher staffing, technology, and operating costs.

This makes operational efficiency increasingly important. Practices may need to look beyond visit volume and identify ways to:

  • Reduce unnecessary administrative work
  • Capture qualifying care activity more consistently
  • Improve documentation and billing accuracy
  • Support more patients without adding staff at the same rate
  • Participate effectively in value-based payment models

For care management programs, reliable activity capture and efficient workflows can help organizations protect the financial value of work their teams are already performing.

What the proposed rule means for care management programs

The 2027 PFS Proposed Rule reflects two important themes: CMS continues to recognize the importance of care delivered between visits, while also increasing expectations around accountability, oversight, and measurable value.

Healthcare organizations should use the proposed rule as an opportunity to evaluate their current programs, including:

  • How clinical responsibilities are divided between the practice and outside partners
  • Whether care activity is documented consistently
  • How easily records can be produced for billing or audit review
  • Whether patient information is centralized or divided across platforms
  • How well RPM and care management workflows support quality goals
  • Whether the program can scale without creating more manual work

The goal is not simply to change where the work happens. It is to ensure that the practice maintains appropriate clinical oversight while giving its team the tools to deliver care efficiently.

Preparing for 2027

The proposed rule is not final, and its policies may change through the public comment and rulemaking process. CMS is accepting comments through September 14, 2026.   The final ruling by CMS is expected mid-November 2026 and only the proposals that make it to the final rule will be instituted.  

Practices do not need to redesign their programs immediately, but they should begin reviewing how the proposals could affect their payment, quality reporting, and remote care operations.

ChronicCareIQ helps organizations operate scalable care management programs with connected devices, prioritized patient insights, automated activity capture, and audit-defensible documentation. Whether your organization uses an in-house, via  third party partner, or hybrid staffing model, the platform helps keep clinical control and program visibility with your team.

See how ChronicCareIQ can support a more connected and adaptable care management program. Book a demo.

The 2027 Medicare Physician Fee Schedule is a proposed rule and may change before it is finalized. Organizations should consult their legal, compliance, and billing advisors when evaluating its potential impact.

Sources: CMS 2027 PFS Proposed Rule fact sheet, CMS Quality Payment Program, HHS OIG RPM billing report, CY 2027 Physician Fee Schedule: Proposals