Comment on CMS-2026-2377-0002

On behalf of InVite Fitness a leading provider and distributor of cellular and Bluetooth-connected medical devices, including the Fitbit Charge 6, we appreciate the opportunity to comment on the CY 2027 Physician Fee Schedule (PFS) Proposed Rule (CMS-1848-P). We write to express serious concern regarding the proposed practice expense (PE) crosswalks for CPT 99453 and 99454, the proposal to mandate direct employment for clinical staff providing RPM services, and the potential bundling of RPM codes into all-or-nothing G-codes. If finalized, these policies will severely dismantle the remote monitoring infrastructure that over 100,000 chronic-care Medicare beneficiaries rely upon today. 1. Flawed Crosswalk for CPT 99454 & True Cost of Connected Medical Devices CMS proposes to crosswalk the practice expense inputs of CPT 99454 (RPM monthly device supply) to CPT 99474 (self-measured blood pressure monitoring), cutting monthly reimbursement from ~$47 to ~$18. This crosswalk fundamentally misapprehends the operational realities and hard technology costs of RPM hardware: •CPT 99474 represents a manual, patient-owned cuff where the patient manually reads and transcribes numbers. There is zero recurring technology cost, no cellular network access, no cloud platform, and no compliance tracking. •CPT 99454 represents an enterprise-grade, connected medical device (such as the Fitbit Charge 6 platform) requiring continuous investment. Our Hardware & Supply Chain Operating Cost Breakdown: To assist CMS in establishing accurate PE input valuation, we share our real-world cost components required to deploy and maintain these devices for Medicare beneficiaries: •Device Unit & Hardware Cost: [$X.XX149.90 / unit amortized] •Cellular Data / Bluetooth Cloud Connectivity Infrastructure: [$0.00 / subscriber / month] •Fulfillment, Individual Patient Shipping, & Packaging: [$6.50 / shipment] •Device Provisioning, Setup, & Onboarding Support: [$9.99 / unit] •Returns Processing, Device Loss, Sanitation, & Replacement: [$9.99/ active patient / year] Reducing reimbursement to ~$18/month will force device providers out of the Medicare market entirely, as it will be economically impossible to cover the raw hardware, cellular infrastructure, and shipping costs. 2. The Direct-Employment Mandate Destroys Scale for Small & Rural Practices The proposal to restrict RPM/RTM delivery exclusively to direct employees of the billing practice—banning third-party vendor partners like ChartSpan—will disproportionately harm independent, small, and rural physician practices. •Lack of Internal Capacity: Independent primary care practices lack the 24/7 staffing, software platforms, and logistics teams required to manage continuous patient monitoring panels. •Scale Advantage: Vendor-managed models provide the necessary operational scale that makes continuous care feasible. Banning these partnerships will force practices to shut down their RPM programs, stripping remote monitoring from vulnerable patients—particularly Black, Hispanic, dual-eligible, and rural beneficiaries who rely most heavily on proactive, home-based chronic disease oversight. 3. Added Administrative Friction & Bundled G-Codes Reduce Preventive Care Access Requiring a dedicated face-to-face "initiating visit" and prior established relationship for all monitoring adds unnecessary cost and barriers to care. Furthermore, collapsing the code set into bundled G-codes that pay $0 for stable, non-intervened patients penalizes practices for successfully maintaining patient health. Remote monitoring is fundamentally a preventative tool designed to keep patients out of emergency rooms; zeroing out payment when a patient remains stable disincentivizes proactive care. Recommendation 1.Maintain Current Valuation for CPT 99454: Utilize real-world device invoice and carrier connectivity data submitted by industry manufacturers during this comment window rather than applying an inaccurate crosswalk to manual cuff codes. 2.Preserve General Supervision and Outsourced Staffing: Allow practices to continue utilizing clinical staff under general supervision via contracted vendor partnerships to preserve access for small, rural, and safety-net practices. 3.Reject Code Bundling: Retain individual CPT codes for device setup, device supply, and clinical management to ensure providers are reimbursed for maintaining ongoing patient monitoring. Sincerely, Seth Grossman GM InVite Fitness