Comment on CMS-2026-2377-0002

Re: CMS-1848-P, Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule Dear Administrator: I am a practicing clinician, and I support eliminating fraud, waste, and abuse in remote care. I write to urge CMS to achieve that through oversight, the path the OIG recommended in September 2024, rather than through three provisions that would end the care itself: (1) the employed-staff-only restriction, (2) the initiating visit requirement with no protection for patients already enrolled, and (3) the re-valuation and flat G-code consolidation of the monitoring codes, on which CMS has specifically solicited comment. Remote patient monitoring company. We help catch abnormal vital signs prior to symptoms occuring. We speak to the patient before they speak to their own doctor and react with EMS or further guidance, as soon as possible. Like countless practices across the country, mine partners with a specialized clinical monitoring organization because no practice of our size can staff licensed nurses 24/7/365 to review readings, triage alerts, and intervene before an emergency. This is the long-recognized "incident to" clinical staffing model, furnished under my orders, my supervision, and my clinical responsibility. One full-time nurse (median RN salary about $94,000) can manage roughly 300 monitored patients, more than a typical practice has enrolled, and around-the-clock alert coverage cannot be staffed by one person regardless. The proposed employment restriction would not bring this staffing in-house; it would end the service. The impact falls hardest on rural and underserved communities: 92% of rural counties are primary-care shortage areas and 199 rural counties have no primary-care physician at all. The initiating visit requirement compounds the harm. My enrolled patients have established relationships, active care plans, and months of monitoring history, yet the proposal does not state whether they are exempt. Requiring each to complete a new face-to-face visit before monitoring may continue would interrupt care for patients who are stable precisely because they are monitored. At minimum, CMS must explicitly exempt patients enrolled before the effective date in any final rule. The payment provisions would independently end the benefit. Crosswalking the device-supply codes to self-measured blood-pressure inputs, removing clinical staff time from the treatment-management codes, and bundling a month of monitoring into a single flat G-code regardless of acuity would reduce payment for a typical monitored patient, device supply plus 40 minutes of monthly clinical management, from approximately $129 to approximately $35 under the proposed valuation methodology. No delivery model, employed or partnered, can furnish 24/7 clinical monitoring at that rate. The consolidation should not be adopted: a flat payment regardless of clinical time eliminates the add-on increments that fund care for the highest-acuity patients. If device costs are overvalued, the remedy is the invoice data CMS has requested, not deleting clinical labor from labor codes. CMS specifically seeks comment "on how often third-party billing currently occurs and how this policy, if finalized, could impact access to remote monitoring services." My answer from direct experience: clinical partnership is how monitoring is delivered in my practice and my community, and finalizing this restriction would end my patients' access on January 1, 2027. Remote monitoring delivers measurable results. An independent actuarial analysis by Optum of one third-party-supported program found directional per-member per-year medical cost savings of $2,467 to $3,012 across hypertension, diabetes, and CKD cohorts versus matched controls, with monitoring reimbursement excluded from the savings calculation. Peer-reviewed literature points the same direction: fewer hospitalizations and better blood-pressure control. The OIG’s 2024 recommendations point the way: safeguards, ordering-provider information on claims, visibility into monitored data, provider education, and “identify and monitor companies that bill for remote patient monitoring.” I urge CMS to adopt that path: register and credential remote care organizations, require the initiating visit prospectively while exempting already-enrolled patients, tie payment to reported outcomes, and set valuations on real cost data, instead of the employment restriction and flat-rate consolidation. Fix the rule; don’t end the care.