CY 2027 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies (CMS-1848-P Display)

Trilogy Health opposes the proposal to limit Remote Physiologic and Remote Therapeutic Monitoring (RPM/RTM) services to clinical staff employed directly by the practice. They argue that the change would restrict access to care for rural and underserved communities, disrupt established compliant programs, and remove a viable delivery model for technology-enabled monitoring.

The commenter, an RPM vendor, opposes the proposed requirement that all clinical staff furnishing RPM and RTM services must be directly employed by the billing physician practice. They argue the mandate would impose prohibitive costs on small and rural practices, reduce patient access to services, and propose targeted regulatory alternatives to address program integrity concerns without restricting labor-market structures.

NAVIX Diagnostix, a remote care management company, opposes the proposed restriction that would limit RPM and RTM payments to services performed by practice employees rather than contractors. They argue that employment status is not a proxy for care quality and that the rule would reduce patient access to these services, particularly in rural and under-resourced settings.