Comment on CMS-2026-2377-0002

Ron P. Linehan, M.D. President, Precision Pain Care Lancaster, Ohio July 24, 2026 Centers for Medicare & Medicaid ServicesAttention: CMS-1832-P7500 Security Boulevard, Baltimore, MD 21244 Re: CY 2027 Physician Fee Schedule Proposed Rule — RPM/RTM Direct-Employment Requirement To Whom It May Concern: I am a solo interventional pain management physician and owner of Precision Pain Care in Lancaster, Ohio. I am writing to oppose the proposal to condition RPM/RTM payment on services being furnished exclusively by direct employees of the billing practice, which would end my ability to use my contracted vendor, Prescribed Fit, for a weight-management program that helps my chronic pain patients. Clinical value Excess weight is one of the most modifiable drivers of musculoskeletal pain I treat. RPM lets my team track patients between visits and intervene early. One example: a patient in her mid-50s with lumbar radiculopathy lost roughly 30 pounds over five months in the program; her pain fell from 7/10 to 3/10 and she became an appropriate surgical candidate. Another patient reached the weight threshold his implanting specialist required before a spinal cord stimulator trial, avoiding months of delay in unmanaged pain. For many patients, this program is a genuine conservative pathway that reduces reliance on medication or repeat procedures. Why an internal team is impractical I am a solo physician with a small clinical staff already fully committed to direct patient care. RPM done properly requires daily data review, monthly interactive communication, and careful documentation. Hiring, training, and retaining dedicated in-house RPM staff, plus purchasing and maintaining a monitoring platform, is not financially feasible for a solo practice in a smaller Ohio market, especially alongside the practice-expense reductions also proposed in this rule. Effect on access If finalized, I would likely be forced to discontinue RPM rather than build an internal team I cannot staff or afford. My patients would lose a program that reduces pain, improves mobility, and helps them avoid or prepare for surgery, with no local equivalent available. This would fall hardest on patients in smaller and rural communities like ours. Oversight and compliance Using a contracted vendor has not meant losing oversight. I personally order RPM only for documented medical necessity, review flagged data myself, and reassess necessity at each visit. Vendor staff work under my general supervision, document the required monthly communication, and log monitoring days before anything is billed; my office independently reviews documentation before claims go out. Quality and compliance come from supervision and documentation, not from whether staff are direct employees or contracted. I respectfully urge CMS not to finalize the direct-employment requirement as proposed, or at minimum to allow contracted staffing where the billing practitioner maintains documented supervision and medical-necessity review. A blanket employment mandate will not improve care for patients like mine; it will end their access to a program that is working. Respectfully submitted, Ron P. Linehan, M.D.President, Precision Pain CareLancaster, Ohio