Comment on CMS-2026-2377-0002
ProteusDx by FirstVitalsOpposeBusiness
Summary: FirstVitals Inc. opposes the proposed "employed-staff-only" requirement for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM), arguing that it unnecessarily restricts referral-based models. The company proposes a "Qualified Practice-Integrated Remote Care Organization" (QPIRCO) framework that allows Medicare-enrolled practices to use qualified contracted personnel while maintaining clinical oversight and billing integrity.
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