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2027 physician fee schedule: what the proposed rule means for care management
The CY 2027 proposals and open questions that touch care management, RPM, G2211 and ACP.
Short answer: The 2027 Physician Fee Schedule is still at the proposed-rule stage in the CMS material checked on October 12, 2026. For care-management planning, CMS proposes practice-employed clinical staff and a separately reportable initiating visit for RPM and RTM. The staffing proposal names those remote-monitoring services; it should not be generalized into a new CCM contractor ban.
The 2027 Physician Fee Schedule proposed rule describes Medicare payment and Part B policy changes CMS is considering for the coming year. The remote-monitoring staffing and initiating-visit changes remain proposals, with January 1, 2027 identified as the staffing start if finalized.
Status checked October 12, 2026: the CMS rule page identifies CMS-1848-P as a Proposed Rule. Use this guide to organize the questions your practice must revisit when the final rule and implementation instructions are available. Keep current service requirements separate from conditional planning assumptions.
TL;DR: Track the proposal by service and status.
RPM and RTM: Proposed direct-employment and initiating-visit changes need final-rule review.
CCM: Do not infer a contractor ban from a proposal that names remote monitoring.
Planning: Inventory the affected work now; tie implementation to the final text and effective date.
2027 Physician Fee Schedule: what is proposed?
CMS issued the proposal on July 14, 2026; its rule page lists publication on July 16 and a September 14 comment date. That comment period has passed as of this article’s status check. A closed comment period does not itself make a proposal final or effective.
| Topic | CMS proposal or discussion | Practice review |
|---|---|---|
| RPM/RTM staffing | Payment only for services performed by clinical staff employed by the practice | Identify who employs the people doing the affected work |
| RPM/RTM initiation | Separately reportable initiating visit at the onset of services | Map current referral-to-start records |
| RTM patient relationship | RTM only for established patients | Review how the relationship is established and recorded |
| Remote-monitoring valuation | Updates to valuation; comments sought on bundling code families | Wait for final coding and payment files |
| CCM contracted staff | The cited employment-only proposal names RPM/RTM | Review existing CCM requirements without importing the remote-monitoring proposal |
| Primary-care payment | CMS seeks comments on valuation, technology and prospective payment | Distinguish a request for input from an adopted service rule |
The CMS proposed-rule fact sheet is the starting summary. Read the relevant rule section and later implementation material before changing a workflow. A headline about outsourced monitoring does not describe every care-management service.
2027 Physician Fee Schedule: proposed RPM and RTM staffing
CMS proposes allowing payment for RPM or RTM services only when clinical staff are employed by the practice, rather than when contractors deliver the services. CMS proposes direct employment by the practitioner or the practitioner’s practice. If finalized as proposed, the identified start is January 1, 2027.
For an affected arrangement, begin with the actual employer and work performed. A contract name or a general description such as care coordination does not establish which service the staff member is furnishing. Map the work to RPM, RTM or another program before assessing the proposal’s implications.
The remote patient monitoring CPT code guide explains the RPM code framework. Use that guide to identify the service your team is discussing, then return to the proposed staffing language. This article does not turn a proposal into a current code-selection rule.
Ask an external monitoring provider which entity employs the clinical staff, how that relationship is documented and which activities support the billed service. Keep the answer tied to a specific service and date. Resolve ambiguous employment arrangements against the final rule and appropriate professional guidance rather than assuming that a label settles them.
Initiating visits and other remote-monitoring proposals
CMS also proposes a separately reportable initiating visit associated with the onset of RPM or RTM services. Separately, it proposes limiting RTM to established patients. These are distinct issues from the proposed employment requirement and need their own review.
A practice can inventory how referrals become active monitoring services without implementing an unfinalized requirement. Identify where the visit date, practitioner and service decision would be recorded. Note questions about existing patients for final-rule review instead of inventing a transition rule.
CMS’s summary also describes proposed valuation updates and a request for comments on bundling RPM and RTM codes into new HCPCS G-codes. A comment request is a different status from an implemented code family. Keep current coding resources available until final codes, descriptors and dates are confirmed.
Do not collapse separate policy questions into one answer.
Employment: Who employs the clinical staff performing the affected service?
Initiation: What visit and documentation would the final policy require?
Coding: Which final code family and effective date apply to the service?
What the proposal means for CCM planning
The cited employment-only proposal names RPM and RTM. That does not support a statement that CMS has prohibited contracted CCM staff from 2027. It also does not justify promising that future CCM rules can never change.
Under the existing CMS CCM guidance, a practitioner may arrange for external clinical staff when incident-to and other requirements are met. The billing practitioner needs oversight and clinical integration and must retain a level of involvement. Outsourcing is not full delegation of the practitioner’s responsibilities.
The 2026 Physician Fee Schedule care-management guide provides the prior-year policy context. Use it alongside current CMS CCM requirements, while tracking the 2027 final rule separately. Do not apply a proposal retrospectively to a service date governed by an earlier rule.
For a mixed CCM and monitoring arrangement, make a service-by-service inventory. Record the billing practitioner, responsible team, employer relationship and supporting records for each program. The same operational team label can conceal different services and requirements.
For CCM itself, the comprehensive plan, consent, qualifying monthly work and code-specific time still need review. Clinical-staff code 99490 requires at least 20 minutes per calendar month, with 99439 for each additional 20 minutes. A remote-monitoring proposal should not distract the practice from those existing obligations.
Other primary-care changes to watch in the proposed rule
The broader CMS summary covers conversion-factor proposals, practice-expense methodology and primary-care payment questions. It continues to distinguish qualifying APM participants from practitioners who are not QPs. A conversion factor alone is not an individual code’s final payment amount.
For longitudinal visit payment, CMS proposes replacing G2211 with a modifier attached to the associated E/M base code. The summary also describes a separate proposed modifier for eligible Shared Savings Program ACO practitioners and LEAD Participant Providers. These are proposed visit-payment changes rather than replacements for a documented monthly CCM service.
CMS seeks comments on reconsidering primary-care valuation, the payment implications of technology and prospective primary-care payment. It also proposes separate coding and payment for shared medical appointments. Track those topics as separate proposals or requests for input, with their own final-rule disposition.
This guide focuses on care-management operations rather than reproducing every PFS provision. Open the CMS summary’s rate-setting section for the proposed conversion factors and its relevant service sections for the wider changes. Verify final code-specific payment files before using a 2027 amount in a practice forecast.
A monthly review process until final policy is available
1. Maintain a service inventory
List the programs actually used by the practice and the people responsible for them. Separate current policy from conditional 2027 assumptions in the working document. Give each open issue an owner who can locate the underlying source.
2. Review the official status
Check the CMS rule page and relevant final-rule publication when available. Record the document, publication status and review date. Do not treat an updated company alert as the source of an adopted Medicare requirement.
3. Compare the final disposition
When the final text is available, compare the staffing, visit, coding and effective-date provisions separately. Note whether each proposal was adopted, modified or not finalized. Resolve transition questions before applying a new workflow to existing patients.
4. Approve a dated implementation
Have the practice’s responsible clinical, operational and billing leads review the changes relevant to their work. Tie revised instructions to the applicable service date and retain the previous version for earlier records. Confirm unresolved claim-specific questions with the MAC before relying on an assumption.
For example, an inventory may show CCM outreach by one team and RPM work by another. That finding gives the practice two separate reviews, even if both activities appeared under one contract heading. The final policy determines the required response for each service.
Keep CCM responsibilities clear during policy review
Review chronic care management services when assessing support for the practice’s CCM enrollment, outreach and documentation. Keep the remote-monitoring policy review with the team responsible for those services.
Your team refers; we handle enrollment, outreach and documentation. You bill monthly under your license. Which team members’ time counts toward each code is set in your services agreement.
Key takeaways
- The checked CMS 2027 material is proposed policy.
- The cited direct-employment proposal names RPM and RTM.
- Review staffing, initiation and coding as separate questions.
- Keep current CCM requirements distinct from conditional planning.
- Recheck final text and effective dates before implementation.
Frequently asked questions about 2027 physician fee schedule
Is the 2027 Physician Fee Schedule final in this guide?
No, the CMS material checked on October 12, 2026 identifies the rule as proposed. Recheck the final publication before relying on a future requirement.
Which programs does the proposed employment requirement name?
The cited employment-only proposal names RPM and RTM. It should not be expanded into an unsupported statement about CCM.
Does the September comment deadline make the rule effective?
No, the comment deadline is a rulemaking milestone. It does not itself establish a final policy or an effective service date.
What initiating-visit change does CMS propose for monitoring?
CMS proposes a separately reportable initiating visit associated with the onset of RPM or RTM. The final text and implementation material need review before operational use.
Should a practice assume existing monitoring patients have a transition exemption?
No exemption is established by the facts used in this guide. Identify that question and resolve it against final policy rather than inventing a transition rule.
Can one staffing answer cover a mixed CCM and RPM arrangement?
Start by separating the actual services and employer relationships. Apply the relevant current or finalized rule to each service and date.
Physician practices furnish Medicare Part B chronic care management, including 99490 and 99439, while reviewing separate proposed remote-monitoring policies. Companian: Your team refers; we handle enrollment, outreach and documentation. You bill monthly under your license.
Read more: 2026 PFS care-management context · RPM CPT codes · CCM CPT codes
Plan your 2027 care management program
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Sources
- CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P), 91 FR 43842
- CMS fact sheet, CY 2027 PFS proposed rule
- CMS fact sheet, CY 2026 PFS final rule (CMS-1832-F)
- CMS MLN909188, Chronic Care Management Services
Rates & disclosures
National amounts are 2026 Medicare Physician Fee Schedule non-facility payments at the non-QP conversion factor of $33.4009, computed from CMS RVUs. Your amount depends on your Medicare payment locality; see it in the CCM/PCM revenue calculator. Actual payment depends on participation status, place of service and cost-sharing. Companian supplies Care Advocates and documentation to physician practices nationwide. Companian is not a medical practice and does not bill Medicare. The billing practitioner keeps the care plan, every clinical decision and the claim. Patients pay the usual Medicare Part B deductible and coinsurance for these services unless other coverage pays it.