2027 Medicare PFS proposed rule would upend third-party remote patient monitoring arrangements

A client alert from JD Supra warns that CMS's 2027 Physician Fee Schedule proposed rule contains provisions that would significantly restrict common third-party arrangements for remote patient monitoring and remote therapeutic monitoring. The rule targets contractual setups where third-party vendors provide RPM/RTM services and bill under the practice's NPI, raising concerns about compliance with Medicare's reassignment and supervision rules. If finalized, practices that rely on third-party vendors to manage and bill for these services could face operational disruption and potential audit risk for services rendered after January 1, 2027. Review your current RPM/RTM vendor contracts and service models now to assess compliance risk before the final rule is published later this year.