Comment on CMS-2026-2377-0002

Re: File Code CMS-1848-P — Calendar Year 2027 Medicare Physician Fee Schedule Proposed Rule Strong Opposition to Proposed Restriction on RPM/RTM Services Furnished by Third-Party Clinical Staff I am writing to strongly oppose CMS’s proposal to limit payment for Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) services solely to clinical staff employed by the billing practitioner’s practice. This change would severely undermine access to these high-value services, particularly in rural and underserved communities already grappling with critical workforce shortages. My expertise is specifically related to respiratory care. Harm to Rural Health and Respiratory Care Access Rural America faces acute and worsening shortages of respiratory therapists and related clinical staff. Over 5.6 million Americans live in “pulmonology deserts,” where residents must drive more than an hour for specialized lung care, with the problem growing. Rural areas have significantly fewer health care workers per capita than urban ones — 44% fewer patient-facing workers overall. These shortages directly impact both inpatient and outpatient respiratory services. Rural counties experience higher rates of COPD and other chronic respiratory conditions, yet lack the on-site expertise to manage them effectively. Projections show these gaps will widen due to retirements, recruitment challenges, and limited training pipelines. Restricting RPM/RTM to employed staff would force many small and rural practices to abandon or severely scale back these programs, leading to: Increased preventable hospitalizations. Higher emergency department utilization for manageable conditions. Worsened health outcomes and higher costs for Medicare. Practices Lack Capacity to Build and Manage Internal Programs Most independent and rural practices simply do not have the time, expertise, infrastructure, or financial resources to rapidly hire, train, credential, and manage dedicated clinical staff for RPM/RTM programs. Building such capabilities internally would require significant upfront investment in technology, compliance, data review workflows, and 24/7 patient support — resources that are already stretched thin. Third-party contracted clinical staff provide essential specialized expertise, scalability, and efficiency that allow practices to focus on direct patient care while ensuring high-quality remote monitoring. Evidence from real-world implementations shows that partnering with experienced third-party vendors enables faster program launch, better patient adherence, and effective data triage — without overburdening local staff. Eliminating this flexibility would disproportionately harm smaller practices that rely on these partnerships to offer RPM/RTM at all. Recommendation CMS should withdraw this proposal and instead maintain (or expand) flexibility for qualified third-party clinical staff under appropriate supervision. This approach best supports the goals of improving access, reducing costs, and enhancing chronic care management — especially for vulnerable rural Medicare beneficiaries. Thank you for considering these critical concerns. I urge CMS to prioritize patient access and rural health equity in the final rule. Submitted by: Justin Hawley Title/Organization: Chief Strategy Officer, rtNOW, LLC Date: July 20, 2026