Comment on CMS-2026-2377-0002

The Honorable Mehmet Oz, M.D. Administrator Centers for Medicare & Medicaid Services Attention: CMS-1848-P 7500 Security Boulevard Baltimore, MD 21244 Re: CY 2027 Medicare Physician Fee Schedule Proposed Rule (CMS-1848-P) — Remote Therapeutic Monitoring Dear Administrator Oz: My name is Koskie Gibson, OTR/L, CHT, and I am a clinical director with Drayer PT in Chapin, SC. I am writing because I am concerned that the proposed changes to Remote Therapeutic Monitoring (RTM) would reduce my patients' access to clinically meaningful support between rehabilitation visits. In outpatient rehabilitation, the success of a plan of care often depends on what happens after the patient leaves the clinic. Patients may become discouraged, misunderstand their home program, experience increased symptoms, or lose confidence that therapy will help. RTM gives our care team a structured way to catch these problems early and respond before a patient disengages. RTM will help with filling in the gaps when a patient gets discharged as they have a useful resource to further their journey to regaining function. I support CMS's efforts to prevent fraud and inappropriate billing, and I understand the concerns raised about certain remote monitoring arrangements. But the employment status of a support staff member does not, by itself, determine whether care is clinically appropriate. What matters is whether the treating practitioner determined RTM was appropriate, whether the practice controls the plan of care and clinical protocols, whether the work is supervised and documented, and whether concerns are escalated to the treating clinician. Contracted clinical staff working under a practice's supervision and protocols can meet every one of those standards. I am also concerned that reducing reimbursement for RTM services while requiring practices to absorb greater staffing and operating costs may make responsible RTM programs financially unsustainable — even those doing exactly what CMS intends. I respectfully ask CMS to reconsider the proposal requiring all RTM clinical staff to be directly employed by the billing practice; to permit contracted clinical staff when the treating practice retains meaningful supervision, clinical control, and accountability; to evaluate RTM separately from Remote Physiologic Monitoring based on evidence specific to rehabilitation care; and to reconsider reimbursement reductions that could eliminate legitimate programs. Please protect patients from inappropriate practices without removing a valuable clinical service from responsible clinicians and the patients we serve. Thank you for considering my comments. Respectfully, Koskie Gibson, OTR/L, CHT Clinical Director, Drayer PT Chapin, SC