-- Wibbi details the potential impact of CMS’s CY 2027 Physician Fee Schedule proposals on RTM for rehabilitation clinics ahead of a January 1 effective date.
Medicare paid $536 million for remote patient monitoring in 2024, representing a 31 percent increase over 2023. Now, the Centers for Medicare & Medicaid Services (CMS) plans to tighten its rules, directly affecting rehabilitation clinics billing for Remote Therapeutic Monitoring (RTM).
CMS released its CY 2027 Physician Fee Schedule proposed rule on July 14, 2026, followed by a public comment period that closed on September 14. Any regulations CMS adopts will take effect on January 1, 2027. Wibbi, a connected care platform used by more than 40,000 health specialists, recently published an informative guide titled “What CMS Is Proposing to Change About RTM in 2027.”
These proposals follow heightened scrutiny of remote monitoring by the U.S. Department of Health and Human Services Office of Inspector General (OIG). In September 2024, the OIG published “Additional Oversight of Remote Patient Monitoring in Medicare Is Needed” (OEI-02-23-00260). The report revealed that roughly 43 percent of Medicare enrollees who received Remote Patient Monitoring (RPM) in 2022 lacked medical records reflecting all three key service components: patient education and device setup, device supply and data transmission, and treatment management. Although the OIG did not mandate that all three components must be billed for every patient, it cited the frequency of missing documentation as a compelling reason for CMS to strengthen oversight.
A follow-up report in August 2025, “Billing for Remote Patient Monitoring in Medicare” (OEI-02-23-00261), documented ongoing utilization growth along with billing patterns that the OIG determined warranted closer review. Medicare spending for RPM reached $536 million in 2024, with nearly one million enrollees receiving the service. This figure represents overall RPM expenditure rather than an estimate of improper or fraudulent payments. The OIG also identified 45 practices where over 80 percent of RPM patients had no documented prior relationship with the practice, flagging this trend for further review rather than deeming the billing inherently improper.
Notably, both OIG reports investigated RPM rather than RTM. Consequently, their findings regarding utilization, spending, and billing should not be interpreted as evidence of identical patterns in RTM. Where CMS chooses to extend similar safeguards to both, this reflects a broader regulatory strategy to manage remote monitoring risks rather than specific OIG findings within the RTM population.
Four specific proposals in the CY 2027 rule stand to significantly impact active RTM workflows across most therapy practices:
- Established Patients: CMS would limit RTM services strictly to established patients.
- Initiating Visit: A separately reportable initiating visit would be required before monitoring begins.
- Direct Employment: CMS would reimburse RTM only when monitoring is performed by clinical staff directly employed by the practice, rather than outside contractors.
- Code Revaluation: CMS proposes revaluing existing codes based on findings that underlying devices cost less than previously assumed.
Separately, CMS has requested stakeholder input on collapsing the 17 existing RPM and RTM codes into four standardized HCPCS G-codes.
None of these proposals are final. CMS has yet to formally define what constitutes an "established patient" in a therapy setting or what an "initiating visit" must entail. Clarifications on both definitions are expected in the forthcoming final rule.
“The direction here is clear,” said Ethan O’Hearn, Director of RTM at Wibbi. “CMS wants remote monitoring anchored to an established clinical relationship and delivered by the professionals who directly treat the patient. That is a reasonable expectation, and it reflects how high-quality rehabilitation programs already operate.”
The staffing proposal could substantially alter how some clinics structure their RTM programs. While practices could continue using external vendors for software, hardware, and technical support, all clinical tasks counted toward billing would need to be executed by practice employees under general supervision. This structure preserves programs where a clinic’s own therapists leverage third-party technology to monitor care. However, practices that outsource clinical monitoring and patient management to third-party staff will need to evaluate their operating models. Clinics already utilizing technology to empower their internal therapists remain well-positioned ahead of these prospective mandates; platforms like Wibbi facilitate direct patient-therapist communication to improve clinical outcomes.
“Wibbi has always been the care platform built to support clinicians' treatment follow-ups as a remote presence, not a replacement,” added O’Hearn. “The therapist retains full ownership of the care plan and the patient relationship. If finalized, these proposals will align seamlessly with Wibbi’s core service model.”
Physical therapy, occupational therapy, speech-language pathology, and pediatric practices will feel the impact first, given their recent adoption of RTM. Because Medicare does not reimburse chiropractors for RTM, chiropractic clinics will be impacted indirectly as commercial insurance payers adapt to match Medicare’s updated coding standards.
Wibbi recommends that practices proactively focus on three actionable steps now:
- Review existing vendor agreements to evaluate clinical staffing structures.
- Verify that initiating-visit and established-patient documentation are properly recorded in patient charts.
- Re-evaluate RTM revenue models against the proposed fee valuations.
Additionally, therapists must maintain comprehensive monthly clinical records. Documentation gaps were the primary focus of the OIG's findings and will remain the primary target of ongoing audits. Finally, Wibbi advises practices against executing permanent operational restructurings until CMS formally publishes the CY 2027 Final Rule.
Full Analysis
Read the complete report and analysis at wibbi.com/resource/what-cms-is-proposing-to-change-about-rtm-in-2027/.
About Wibbi
Wibbi is a connected care platform serving more than 8,000 organizations and 40,000 health specialists worldwide. The platform integrates home exercise programs, remote therapeutic monitoring, patient engagement, and outcomes measurement into a unified system. RTM features are currently available in the United States.
Contact Info:
Name: Silvana Huaman
Email: Send Email
Organization: Wibbi
Website: https://wibbi.com
Release ID: 89206402
If there are any errors, inconsistencies, or queries arising from the content contained within this press release that require attention or if you need assistance with a press release takedown, we kindly request that you inform us immediately by contacting [email protected] (it is important to note that this email is the authorized channel for such matters, sending multiple emails to multiple addresses does not necessarily help expedite your request). Our reliable team will be available to promptly respond within 8 hours, taking proactive measures to rectify any identified issues or providing guidance on the removal process. Ensuring accurate and dependable information is our top priority.
