Comment on CMS-2026-2377-0002

**RE: CMS-1848-P – CY 2027 Medicare Physician Fee Schedule Proposed Rule** I am the Practice Manager of **CSRA Renal Services**, an independent nephrology practice serving patients throughout Aiken, Barnwell, and Edgefield counties in South Carolina. I respectfully urge CMS **not to finalize** the proposal that would prohibit physician practices from using qualified third-party clinical staff to furnish Remote Physiologic Monitoring (RPM) services. Independent practices rely on experienced RPM partners to provide trained clinical staff, patient education, device support, and continuous monitoring under the supervision of the treating physician. These organizations do not replace physicians—they extend our ability to care for medically complex patients between office visits while all clinical decisions remain with our providers. For nephrology, RPM is especially valuable. Chronic kidney disease is often called a "silent disease" because patients may feel well while their condition worsens. Small changes in blood pressure, weight, heart rate, oxygen saturation, medication adherence, or patient-reported symptoms can signal worsening kidney disease, fluid overload, uncontrolled hypertension, or cardiovascular complications. Identifying these changes early allows our providers to intervene before patients require emergency department visits, hospitalization, or dialysis-related interventions. The proposed contractor restriction would disproportionately harm independent and rural physician practices. Unlike large health systems, most private practices do not have the financial resources or staffing capacity to build and operate an internal RPM department. Requiring practices to employ all RPM clinical staff directly will likely force many practices to reduce or eliminate RPM services entirely, leaving vulnerable Medicare beneficiaries without an important source of preventive care. This proposal also appears inconsistent with CMS's continued emphasis on value-based care, chronic disease management, prevention, beneficiary engagement, and reducing avoidable hospitalizations. RPM directly supports these goals by allowing practices to identify problems earlier and manage patients proactively rather than reactively. If CMS has concerns regarding inappropriate billing or insufficient physician oversight, those issues should be addressed through stronger program integrity requirements—not by prohibiting legitimate physician-directed partnerships. CMS could instead require: * Physician oversight and accountability for every RPM patient. * Written agreements between physician practices and RPM organizations. * Defined clinical escalation protocols. * Qualification and training standards for contracted clinical staff. * Clear documentation requirements. * Transparency regarding the role of third-party organizations. * Strong audit and compliance requirements. These safeguards would protect Medicare while preserving patient access to high-quality RPM services. We are also concerned about proposed reductions in RPM valuation and the potential creation of bundled HCPCS codes. Patients with chronic kidney disease, hypertension, diabetes, heart failure, and multiple chronic conditions require significantly more clinical oversight than lower-acuity patients. Payment should recognize the complexity of these patients and the clinical infrastructure required to successfully manage them. CMS should carefully evaluate the impact these proposals will have on independent specialty practices before implementing changes that could unintentionally reduce access to care. On behalf of our physicians, providers, staff, and Medicare beneficiaries, I respectfully request that CMS: 1. Withdraw the proposed prohibition on contracted clinical staff furnishing RPM services. 2. Preserve physician-directed partnerships with qualified third-party RPM organizations. 3. Strengthen documentation, quality, and compliance requirements instead of eliminating contractor participation. 4. Ensure any revised RPM payment structure appropriately recognizes patient complexity and clinical workload. 5. Provide a sufficient implementation period for any significant operational changes. Remote Physiologic Monitoring has become an essential tool for improving outcomes for patients with chronic kidney disease and other serious chronic illnesses. Eliminating the ability of independent physician practices to partner with qualified RPM organizations will reduce patient access, increase operational costs, widen disparities between independent practices and large health systems, and ultimately work against CMS's goals of improving quality while reducing avoidable healthcare utilization. Thank you for your consideration of these comments. Ronald Reynolds, Jr. Practice Manager