There's a lot in this issue, and it's worth naming the thread running through it: Medicare is in the middle of deciding how it pays for technology enabled care, and this summer produced more movement on that question than the past several years combined.
The 2027 physician fee schedule proposed rule is the piece drawing the most attention, and rightly so. If finalized as written, it would change who can furnish remote monitoring, what it pays, and how it's coded. My concern is concentrated on the employed-staff provision, which would fall hardest on rural clinics and small practices - exactly where these programs have done the most good. Comments are open through September 14, and the agency has said plainly that it lacks data on how these arrangements work and what devices actually cost. Providers have that data. If you're preparing a comment, we'd be glad to help.
At the same time, the ACCESS Model went live in July, testing something the fee-for-service system has never really paid for: measurable improvement in a patient's condition over time. Whatever one thinks of the design, the questions it will answer are the right ones. We're watching the early cohorts closely and will share what we learn as outcomes and participant feedback emerge. Both of those developments point the same direction, and they've shaped where we're investing.
Much of our engineering work this year has gone into the CloudCare platform - deeper workflow integration, better data handling, and the audit trail that any outcomes-based arrangement will demand. Doppler, previewed in this issue, comes out of that work. It reflects a straightforward conviction: if Medicare is moving toward paying for results, care teams need to see what's coming, not just what already happened.
The policy will settle eventually. The direction is clear enough to build toward, and that's what we intend to do.
Kent Dicks
CEO & Founder, Life365
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The CMS' proposed calendar year 2027 Physician Fee Schedule includes several changes that could significantly affect how remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) programs are staffed, reimbursed, and scaled:
Contracted clinical staff may no longer be reimbursable -services would need to be furnished by staff directly employed by the billing practitioner.
A separately reportable, face-to-face initiating visit would be required.
Remote physiologic and remote therapeutic monitoring reimbursement could be reduced.
CMS is seeking comment on consolidating the current 17 remote monitoring codes into four bundled G-codes.
The proposals arrive as Congress moves in the opposite direction. Two days after the proposed rule was released, the House Ways and Means Committee advanced legislation to expand and protect access to care in rural and underserved communities, including remote monitoring services.
Our infographic breaks down these potential changes, why CMS is reconsidering the current model, and what healthcare organizations and stakeholders can do during the public-comment period.
Rural Health Revenue and Care Delivery Through Remote Patient Monitoring
Rural healthcare organizations have a significant opportunity to expand access to care while building sustainable remote patient monitoring programs - and Rural Health Transformation Program funding puts real money behind it. Our new eBook, Maximizing Rural Health Revenue and Care Delivery Through Remote Patient Monitoring, offers a practical roadmap for rural health leaders looking to launch, strengthen, or scale a program. It covers:
Building the right care delivery model
Navigating 2026 reimbursement opportunities
Preparing a competitive Rural Health Transformation Program application
The guide was developed by Life365 Clinical Director, Donna Zazworsky, RN, MS, CCM, FAAN. Whether you're just getting started or optimizing an existing program, it's built to turn strategy into action.
Ways & Means Advances Rural Remote Monitoring Bill
The Rural Patient Monitoring Access Act (H.R. 3108) passed the House Ways and Means Committee 39-0 on July 15, 2026. The bill establishes a national floor for remote patient monitoring reimbursement, eliminates negative payment adjustments for remote monitoring in rural areas, clarifies technology and response requirements, and requires a report on hospital admissions and inpatient days for monitored patients. Specifically, it would set minimum practice expense and malpractice geographic indices of 1.00 for remote physiologic monitoring beginning January 1, 2028 through December 31, 2032, condition payment on the Secretary determining that standards for supplier response capability and real-time data transmission are met, and require a report to Congress by January 1, 2031.
The timing is notable: the committee acted the day after the Centers for Medicare & Medicaid Services released a proposed rule that would reduce remote monitoring payment.
CMS Office of Health Technology and Products: What We Know Now
Since our last issue, more detail has emerged on the office established June 9, 2026. It comprises eight divisions and more than 90 listed responsibilities, covering artificial intelligence strategy, interoperability, digital product development, Medicare.gov, provider directories, and claims system modernization. Amy Gleason will lead it as deputy administrator and chief product officer; she previously served as a strategic advisor to the agency and led its Health Tech Ecosystem initiative. The move follows a March reversal that narrowed the Office of the National Coordinator for Health Information Technology's responsibilities, meaning vendors now face a more consolidated federal counterpart on interoperability and technology policy.
The Centers for Medicare & Medicaid Services Innovation Center's Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model began July 5, 2026, and will run for 10 years. The voluntary model targets conditions affecting more than two-thirds of people with Medicare, including high blood pressure, diabetes, chronic musculoskeletal pain, and depression. Rather than paying for billable activity, it pays for measurable improvement in patient outcomes. What it means operationally:
Participants receive an Outcome-Aligned Payment in quarterly installments, with the remaining half contingent on beneficiaries achieving defined clinical outcomes at reconciliation and avoiding duplicative services.
Participation is limited to Medicare Part B-enrolled providers or suppliers by tax identification number, excluding durable medical equipment and laboratory suppliers. Health technology companies not currently Part B-enrolled would need to enroll or partner with an enrolled entity.
Participants and affiliated entities may not bill traditional fee-for-service claims for aligned beneficiaries — so overlapping chronic care management and remote monitoring billing for that condition goes away.
CMS will maintain a public directory of each participant's tracks, tools, and risk-adjusted clinical outcomes. It will also provide a vendor directory to help participants identify optional software and hardware. Applications are accepted on a rolling basis through 2033, with several cohort entry points per year.
CY2027 Proposed Rule: What Changes for Remote Monitoring
The Centers for Medicare & Medicaid Services released the CY2027 Physician Fee Schedule proposed rule on July 14, 2026. Citing two Office of Inspector General reports, it proposes significant tightening of remote physiologic and remote therapeutic monitoring, effective January 1, 2027.
Proposed:
Clinical staff must be direct employees of the billing practitioner, contracted third-party staff would not be payable.
A separately reportable, face-to-face initiating visit where RPM must be discussed.
CMS mandates an established patient relationship for RPM and RTM.
Reduced reimbursement for set-up, device supply, and treatment management codes.
Seeking comment only: consolidating the 17 existing codes into four bundled codes.
The employed-staff provision is the most disruptive, any program using a contracted monitoring team would need to restructure. CMS is also asking directly what practices actually pay for devices.
Comments are due September 14, 2026. Our infographic breaks down what these changes mean and how to comment, see it here.
📰 Quick Bytes - What We're Tracking
McDermott+ – Remote monitoring at a crossroads: CMS proposes sweeping changes in response to OIG scrutiny
McDermott+ analyzed the calendar year 2027 Medicare Physician Fee Schedule proposed rule, which would significantly reshape payment and coverage requirements for remote physiologic and remote therapeutic monitoring in response to two Office of Inspector General reports. Key proposals include limiting payment to clinical staff directly employed by the billing practitioner - effectively ending third-party staffing arrangements - along with reduced valuations for device supply and set-up codes, a new face-to-face initiating visit requirement, and extension of the established patient requirement to remote therapeutic monitoring. Comments are due September 14, 2026.
Medical Office Force – CMS ACCESS Model vs FFS: Financial Impact, ROI, and Practice Survival Guide (2026)
Medical Office Force compared the new Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) model, a 10-year Medicare initiative launched July 5, 2026, against traditional fee-for-service chronic care billing. Under ACCESS, participants receive a fixed Outcome-Aligned Payment of roughly $180 to $420 per patient per year, with up to half withheld if clinical performance targets are not met. The model also applies a fee-for-service exclusion policy: for a patient aligned to an ACCESS track, overlapping chronic care management and remote patient monitoring codes cannot be billed for that condition. The author models a complex chronic care patient at approximately $2,455 annually under fee-for-service versus a $420 ceiling under ACCESS, and argues independent practices would need five to six times the patient volume to break even.
Healthcare Dive – Physicians' wearable data use hampered by reimbursement, workflow barriers: survey
Healthcare Dive covered an AMA survey of more than 2,200 physicians across six countries showing that clinicians see value in consumer wearable data but rarely have a way to act on it. Eighty-six percent of U.S. physicians reported at least occasionally reviewing patient wearable data, and nearly 80% cited clinical advantages, yet only 6% said that data was integrated into clinical workflows such as import into the electronic health record. Just 10% reported using remote monitoring billing codes, which require devices cleared by the FDA under a clinician-directed plan of care and therefore offer no dedicated pathway for consumer wearable data. By comparison, 35% of German physicians reported using their country's reimbursement pathway for approved digital health applications.
Introducing Doppler™ - Predictive Population Radar
Most remote monitoring dashboards tell you what already happened. Doppler is built to surface what's coming - highlighting which patients on a panel are trending toward an acute event so care teams can act ahead of it rather than after. Doppler bands an entire panel by time to event - Imminent, Acute, Watch, Forecast, and Stable - so staff time goes to the patients who need it now instead of whoever is next in the queue.
What it does:
Sorts by time horizon. Signals are organized from hours out to weeks out, not collapsed into a single risk score.
Shows the financial picture next to the clinical one. Avoidable cost, revenue at risk, and open billing opportunities sit on the same screen.
Explains itself. Every signal answers "Why?" with the underlying rules and data - reviewable for compliance and audit.
Lives in the workflow. One click opens the patient, starts outreach, or captures chronic care management time. No separate portal to learn.
Discover proactive care with Life365. Our platform delivers real-time insights, enabling early intervention and personalized care that reduces costs and enhances patient outcomes. View our solutions today.
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