CMS Is Drawing a Line Around RTM in 2027. Orva Was Built on the Right Side of It.
Everything described here comes from the CY 2027 Medicare Physician Fee Schedule proposed rule, issued July 14, 2026. It is not final policy. CMS is accepting comments through September 14, 2026, and may finalize, modify, or drop any of these provisions. If finalized as proposed, the changes take effect January 1, 2027.
For remote therapeutic monitoring, the most important change CMS proposed for 2027 is not a new code or a different threshold. It is a much more fundamental question. Who is actually taking care of the patient?
The short version
- Medicare would only pay for RTM furnished by clinical staff employed by the billing practitioner or practice. Time from a third-party contractor's clinical staff would no longer count.
- RTM would be limited to established patients, and a separately reportable initiating visit would be required before monitoring begins.
- CMS is reconsidering how these services are valued, which could put downward pressure on reimbursement.
- CMS is separately seeking comment on consolidating the RPM and RTM code families into four G-codes. That is a question, not a proposal for 2027.
- For clinics whose own therapists deliver the care, almost nothing changes. For clinics relying on vendor-supplied clinical staff, the model itself is in question.
Under the proposed rule, Medicare would pay for RTM and RPM services only when they are furnished by clinical staff employed by the billing practitioner or practice. Clinical work performed by staff supplied through a third-party contractor would no longer count toward the service. CMS is also proposing that RTM be limited to established patients, and that a separately reportable initiating visit occur when remote monitoring begins.
For some RTM companies, this would require a fundamental change to their business model.
For Orva, it reinforces the model we have used from the beginning.
RTM was never supposed to mean outsourcing your patients
A large part of the RTM market has developed around a simple pitch. The clinic enrolls the patient. An outside company supplies clinical staff to perform much of the monitoring and management work. The vendor handles the operational burden, and the clinic participates in the reimbursement.
It made RTM easier to start. It also separated the person monitoring the patient from the person actually treating the patient.
CMS is now questioning that model directly. In the proposed rule, CMS says third-party arrangements may not provide enough practitioner oversight, management, collaboration, or clinical integration to satisfy the intent of remote monitoring, and proposes that clinical staff whose time counts toward RTM or RPM be direct employees of the practitioner or practice.
Software can be outsourced. The clinical relationship should not be.
That has always been Orva's position.
What CMS is proposing for 2027
-
Established patientRTM would be limited to patients who already have a clinical relationship with the billing practitioner before monitoring begins.
-
Initiating visitA separately reportable initiating visit, in person or through a qualifying telehealth encounter, would be required at the start of RTM.
-
Direct employmentClinical staff furnishing billable RTM would need to be directly employed by the billing practitioner or practice. Vendors could still supply technology and nonclinical services.
-
ValuationCMS is proposing changes to the practice expense assumptions used to value remote monitoring, based partly on its view that the underlying technology now costs less than originally assumed.
-
Code structureCMS is seeking comment on consolidating the RPM and RTM code families into four HCPCS G-codes. It has not proposed replacing the existing codes for January 1, 2027.
RTM would be limited to established patients
A patient would need an existing clinical relationship with the billing practitioner before RTM begins. For physical therapy practices, we think this makes sense. RTM should extend a real plan of care. It should not be a mechanism for enrolling Medicare beneficiaries who have little or no relationship with the clinician ultimately billing for the service.
CMS says the requirement is intended in part to address concerns about beneficiaries being contacted and enrolled in remote monitoring without a meaningful prior relationship with the practice.
An initiating visit would be required
The practitioner would use that encounter to determine whether monitoring is appropriate, discuss it with the patient, and initiate the service. It could happen in person or through a qualifying telehealth encounter.
For a therapy practice already treating the patient, this is not an entirely new clinical workflow. The patient is already in front of the therapist. The change is making the decision to initiate RTM explicit and properly documented.
Outsourced clinical staff would no longer count
This is the biggest change. Clinical staff furnishing billable RTM or RPM would need to be directly employed by the billing practitioner or practice. A third-party company could still provide technology, software, infrastructure, and other nonclinical services, but time furnished by the vendor's contracted clinical staff would no longer support Medicare payment under these codes.
The staff do not have to physically sit inside the clinic. The proposal still allows remote work under general supervision. The distinction is who employs the person doing the clinical work, and how integrated that person is with the treating practice.
CMS is also reconsidering reimbursement
CMS is proposing changes to the practice expense assumptions used to value remote monitoring services, based partly on its view that the technology and devices used to furnish them now cost less than originally assumed. That could put downward pressure on payment across parts of the RTM and RPM code families.
For clinics, that makes operational efficiency more important, not less. A model that splits reimbursement across the clinic, the technology vendor, and an outsourced clinical workforce gets harder to sustain as payment tightens.
Why CMS is doing this now
Remote monitoring has grown quickly, and that growth has attracted scrutiny. The HHS Office of Inspector General found that roughly 43% of Medicare beneficiaries receiving remote patient monitoring did not receive all three components of the service. OIG has also raised concerns about Medicare's ability to identify who ordered monitoring, what was being monitored, and whether certain billing patterns warrant additional review.
That does not mean CMS is turning against remote care. Our read is close to the opposite.
CMS appears to be drawing a line between technology that helps a treating provider extend care beyond the clinic, and a remote monitoring business operating alongside the treating provider.
For musculoskeletal care, that is an important distinction.
Orva was built around the treating therapist
Orva has never outsourced RTM care management. We made that decision deliberately. The therapist who knows the patient should be the therapist reviewing how that patient is doing, communicating with them, adjusting their home program, and deciding what happens next.
Orva handles the technology around that relationship. The patient uses Orva for their home exercise program, outcome measures, messaging, symptoms, and adherence. The clinic can see what is happening between visits and respond when something needs attention. The platform tracks RTM requirements alongside that work, so the clinic can identify what qualifies for reimbursement without standing up a parallel clinical operation.
The software does not replace the therapist. It makes the therapist more present during the hundreds of hours each month when the patient is not in the clinic.
The established-patient rule describes the model
Orva is not designed around finding Medicare beneficiaries and enrolling them into a monitoring program. It starts with a patient already receiving care from a clinic. The therapist assigns the home program. The patient activates Orva. The therapist remains responsible for the plan of care. RTM extends that existing relationship into the time between appointments.
If CMS finalizes an established-patient requirement, Orva clinics would not need to reinvent their model. The requirement describes it.
So does the initiating visit
When a patient begins using Orva for RTM, the treating therapist is already involved. There is no handoff to an outside monitoring team after enrollment, and no need to manufacture a clinical relationship around a reimbursement opportunity. The therapist can explain how Orva will be used, why monitoring is appropriate, and what to expect, as part of the care they are already providing.
The documentation requirements may change. The underlying clinical model does not.
And the most consequential proposal changes nothing about who delivers care
If CMS finalizes the direct-employment requirement as proposed, practices relying on vendor-employed clinical teams face a hard transition. Someone still needs to review the data. Someone still needs to communicate with the patient. Someone still needs to make clinical decisions and document the work. The difference is that those people would need to be part of the practice.
Rebuild the program on a deadline
Bring the clinical work in house, hire or reassign for it, and rewrite the vendor relationship, all before the effective date. The revenue stops until the staffing model matches the rule.
Change almost nothing
A practice whose own therapists already deliver the care satisfies the employment condition today. What is left is documentation work for a team already treating the patient.
That also matters if reimbursement comes down
We have always believed RTM needs to make economic sense for the clinic delivering the care. That becomes more important if CMS reduces payment.
Orva does not require a second clinical organization sitting behind the first one. The clinic already has the clinical expertise. The job of the technology is to make using that expertise between visits efficient enough that better care and better economics can coexist.
Surfacing the patients who need attention instead of asking therapists to watch dashboards. Tracking RTM thresholds automatically. Keeping messaging, adherence, outcome measures, home exercise activity, and treatment management in the same patient record.
It means helping the clinician capture work they are actually doing rather than manufacturing work to satisfy a billing code. And it means giving the billing team a clear record of the month without asking them to reconstruct it afterward.
That is a fundamentally different cost structure than outsourcing the clinical work itself.
RTM should be a clinical model first and a reimbursement model second
This is the part of the 2027 proposal we think matters most. RTM works best when reimbursement follows better care, rather than when care is designed around reimbursement.
- A patient does their exercises at home
- They report pain or difficulty
- Their therapist sees it
- The therapist checks in
- The program changes
- The patient keeps progressing
- There is now a record of that work
Medicare created RTM codes because meaningful care happens between appointments too. Orva's job is to make that care easier to deliver, easier to see, easier to document, and easier to bill. The reimbursement is attached to the clinical relationship. It should not replace it.
What to ask your RTM vendor now
The rule is not final, but January 2027 is close enough that practices should understand how their current program actually works. Five questions get you most of the way there.
- Who is actually performing the clinical monitoring and management? If those people are supplied by your RTM vendor, understand exactly how the proposed direct-employment requirement would affect you.
- Does RTM begin with patients your clinicians are already treating? CMS is proposing to make the established relationship explicit rather than assumed.
- Could your own therapists run the program if outsourced staffing disappeared tomorrow? If the answer is no, you may not have an RTM technology platform. You may have outsourced an entire clinical service.
- Who owns the patient relationship and the clinical record? Your therapists should be able to see what happened, what was communicated, what changed, and why.
- Does the program still make sense if reimbursement changes? RTM should improve the patient experience and give the therapist better visibility even before the claim is submitted.
Those are worth asking regardless of what CMS ultimately finalizes.
Practices and professional associations can submit comments on the proposed rule through the federal rulemaking portal. If the direct-employment provision would affect how your clinic delivers RTM, this is the window in which that perspective counts.
We think CMS is moving RTM in the right direction
There will be legitimate debate about parts of this rule, particularly the direct-employment restriction and its effect on practices that built programs around contracted staff. Those clinics made a reasonable decision under the rules as they existed, and a hard transition is a real cost.
But the principle underneath the proposal is difficult to argue with. Patients should know who is taking care of them. The clinician billing for remote management should be meaningfully involved in that management. Technology should strengthen the relationship between patients and their providers rather than inserting another layer between them.
That is the future we built Orva for. Home exercise programs, patient-reported outcomes, messaging, adherence, RTM tracking, and billing support should not exist as disconnected products. They are all parts of the same recovery, and the therapist should remain at the center of it.
CMS may change the rules around RTM in 2027. Orva clinics will not need to change who takes care of their patients.
See how in-house RTM works
If your practice is evaluating RTM for 2027, or currently relies on an outsourced monitoring model, we can show you what it looks like when your own therapists deliver the care without taking on another administrative burden.
Keep the care. Keep the patient relationship. Keep the revenue in your practice.
The CY 2027 Medicare Physician Fee Schedule provisions discussed above are proposed and are not final policy. CMS issued the proposed rule on July 14, 2026, and comments are due September 14, 2026. This article is provided for general informational purposes and is not legal, coding, or billing advice. Practices should review final CMS guidance, applicable Medicare Administrative Contractor guidance, payer policies, and their own legal and billing requirements before making reimbursement decisions.