A practicing clinician and owner of a practice that partners with a clinical monitoring organization opposes the proposed CMS payment policies. The commenter argues that the proposed employment restrictions, initiating visit requirements, and flat-rate payment consolidations would end remote monitoring services for their patients, particularly in rural and underserved areas.

A practicing clinician opposes the proposed CMS payment policies for remote patient monitoring, arguing that the employment restrictions and payment consolidations would end the service for rural and underserved patients. The commenter advocates for the OIG's recommendations, which focus on oversight and credentialing rather than restricting clinical staffing models.

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.

InVite Fitness, a provider and distributor of connected medical devices, opposes the proposed CY 2027 Physician Fee Schedule changes. They argue that the proposed practice expense crosswalks, direct-employment mandates for clinical staff, and bundling of RPM codes will make remote monitoring economically unfeasible and reduce access to care for rural and small practices.

Esvyda Inc., a technology vendor, opposes the proposed CY 2027 Medicare Physician Fee Schedule changes regarding Remote Patient Monitoring (RPM). They argue that reverting to "direct" supervision, bundling RPM codes, and reducing rates for clinical staff will create administrative barriers, decrease reimbursement, and ultimately harm patient access to digital health and chronic disease management.

Dr. Ron P. Linehan, owner of Precision Pain Care, opposes the proposed requirement that RPM/RTM payments be conditioned on services being furnished exclusively by direct employees. He argues that as a solo physician in a small market, he cannot afford to hire in-house staff and would be forced to discontinue the weight-management program for his patients if contracted vendors are prohibited.

SurgicalRx, a perioperative patient engagement and remote monitoring company, opposes the proposed rule that would restrict RTM and RPM payments to services performed only by practice employees. They argue that employment status is not a reliable proxy for care quality and that the restriction would disproportionately harm smaller practices and reduce patient access to monitoring services.

Justin Hawley, Chief Strategy Officer at rtNOW, LLC, opposes the proposed CMS rule that would limit RPM/RTM payments to staff employed directly by the billing practitioner. He argues that this restriction would harm rural health and respiratory care access by preventing small practices from using third-party clinical staff to manage these services.

Code Pause Inc., a digital health platform developer, supports CMS's proposed program-integrity measures for remote monitoring services. They advocate for specific clarifications on "established patient" definitions and "clinical staff" requirements while opposing certain proposed code valuations that they argue would undervalue services and hurt auditability.

Ronald Reynolds, Jr., Practice Manager of CSRA Renal Services, opposes the proposed rule prohibiting physician practices from using third-party clinical staff for Remote Physiologic Monitoring (RPM) services. He argues that this restriction would disproportionately harm independent and rural practices, reduce patient access to preventive care, and suggests that CMS should instead implement stronger oversight and documentation requirements.