CMS 2027 RPM Proposals: Who Supports and Who Opposes (109 Comment Letters)

Name: CMS-1848-P RPM comment tracker: organization positions on the CY 2027 RPM and RTM proposals
Creator: CareSimple
License: https://creativecommons.org/licenses/by/4.0/

Analysis of docket CMS-2026-2377 as of September 24, 2026. The comment period closed September 14, 2026. Last updated September 25, 2026.

The field is close to unanimous. Of the 109 organizations that took a position, 100 oppose CMS’s proposal to pay for RPM and RTM only when monitoring is done by direct employees of the billing practice. Only 3 support it: Humana, the Blue Cross Blue Shield Association and Sutter Health. Not one organization supports revaluing the RPM device code by crosswalking it to self-measured blood pressure, and only BCBSA supports collapsing 17 RPM and RTM codes into four G-codes.

The one proposal with a real debate is the initiating visit. Of the organizations that addressed it, 15 support it, 19 oppose it and 35 would accept it with conditions, most often that a visit in the past 12 months, or a hospital or emergency department discharge, should count.

Jump to the organization-by-organization tracker ↓ Primary sources: docket CMS-2026-2377 · CMS proposed rule fact sheet

109

notable organizations with an RPM position

100

oppose the outsourcing ban

support the outsourcing ban

support the crosswalk rate cut

What CMS proposed

CMS-1848-P, the proposed rule for the CY 2027 Physician Fee Schedule, contains four changes to remote patient monitoring (RPM) and remote therapeutic monitoring (RTM). In plain terms:

Outsourcing ban. Pay for RPM and RTM only when the monitoring is furnished by clinical staff who are direct employees of the billing practitioner or practice. Contracted and third-party monitoring staff would no longer qualify.
Crosswalk rate cut. Revalue the practice expense of the RPM and RTM codes, including crosswalking the device-supply codes (99454 and its RTM equivalents) to the self-measured blood pressure codes, which pay far less.
Four G-codes. A request for comment on replacing the 17 existing RPM and RTM codes with four bundled G-codes.
Initiating visit. Limit RTM to established patients and require a separately reportable practitioner visit before monitoring begins.

For a deeper read of what each provision means for your program, see our analysis of the CMS 2027 proposed rule.

The four proposals and where the field landed

1. Outsourcing ban

3 support 2 mixed 100 oppose 4 did not address

Opposed by 100 of 109 organizations; supported by Humana, BCBSA and Sutter Health.

2. Crosswalk rate cut

0 support 0 mixed 42 oppose 67 did not address

Opposed by 42 organizations and supported by none; the payers that commented did not address it.

3. Four G-codes

1 support 10 mixed 28 oppose 70 did not address

Opposed by 28, conditional for 10, supported only by BCBSA.

4. Initiating visit

15 support 35 mixed 19 oppose 40 did not address

Split: 15 support, 19 oppose and 35 would accept it with a 12-month lookback or discharge exception.

Key takeaways

The outsourcing ban is nearly friendless. Payers including UnitedHealth Group, CVS Health, Kaiser Permanente and AHIP oppose it, alongside 50 of the 55 health systems, all 11 provider groups and 35 of the 37 associations in the sample.
Nobody defends the rate cut. Every organization that addressed the crosswalk to self-measured blood pressure opposes it, including the AMA, the AHA and every health system that commented on rates. Henry Ford Health projects a loss of about $309 per patient per year at the proposed rates.
Health systems say they cannot staff monitoring alone. Duke Health, Hackensack Meridian Health and St. Elizabeth Healthcare describe programs built with contracted clinical partners and say around-the-clock monitoring is not possible entirely in-house.
The initiating visit is negotiable, the rest is not. Most health systems accept a visit for new patients, provided a visit in the past year counts and hospital or ED discharges qualify.
Most large payers stayed silent on RPM. Cigna, Elevance, BCBS of Michigan, BCBS of Massachusetts and Point32Health filed on other topics only; no filings were found for Centene, Molina, HCSC or Highmark.

In their own words

“CMS could permit vendors who are coordinated providers with a given clinician, versus having to be directly employed by that clinician, to provide RPM services.”
UnitedHealth Group

“Kaiser Permanente strongly opposes this proposal, which would create substantial barriers to the delivery of RPM and RTM services and have an outsized impact on integrated delivery systems.”
Kaiser Permanente

“We are concerned that the CMS proposal would, in effect, eliminate the capacity of providers to outsource RPM/RTM to third-party contractors.”
AHIP

“BCBSA supports limiting payment for RPM and RTM services to clinical staff who are direct employees of the billing practitioner or practice.”
Blue Cross Blue Shield Association

Organization-by-organization tracker

Each row is one organization’s comment letter, coded for its position on the four proposals. The organization name links to the letter on regulations.gov; open a row for a plain-language summary and a link you can share.

Supports Opposes Mixed or conditional Did not address

Positions of 109 organizations on the RPM and RTM proposals in CMS-1848-P, from comment letters in docket CMS-2026-2377, as of September 24, 2026.

UnitedHealth Group # Payer Details UnitedHealth Group opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. “CMS could permit vendors who are coordinated providers with a given clinician, versus having to be directly employed by that clinician, to provide RPM services.” Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
CVS Health # Payer Details CVS Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Supports
Kaiser Permanente # Payer Supports an initiating visit, with flexibility for established patients Details Kaiser Permanente opposes the outsourcing ban, did not address the crosswalk rate cut, opposes the four G-codes and takes a mixed or conditional position on the initiating visit. “Kaiser Permanente strongly opposes this proposal, which would create substantial barriers to the delivery of RPM and RTM services and have an outsized impact on integrated delivery systems.” Read the letter on regulations.gov	Opposes	Did not address	Opposes	Mixed or conditional
Humana # Payer Details Humana supports the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Supports	Did not address	Did not address	Supports
AHIP # Payer Supports consolidation only if day-count tiers and RTM categories are kept Details AHIP opposes the outsourcing ban, did not address the crosswalk rate cut, takes a mixed or conditional position on the four G-codes and opposes the initiating visit. “We are concerned that the CMS proposal would, in effect, eliminate the capacity of providers to outsource RPM/RTM to third-party contractors.” Read the letter on regulations.gov	Opposes	Did not address	Mixed or conditional	Opposes
Blue Cross Blue Shield Association # Payer Established-patient rule for RTM; initiating visit not addressed Details Blue Cross Blue Shield Association supports the outsourcing ban, did not address the crosswalk rate cut, supports the four G-codes and supports the initiating visit. “BCBSA supports limiting payment for RPM and RTM services to clinical staff who are direct employees of the billing practitioner or practice.” Read the letter on regulations.gov	Supports	Did not address	Supports	Supports
Sutter Health # Health system Details Sutter Health supports the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Supports	Did not address	Did not address	Supports
MUSC Health # Health system Details MUSC Health opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Opposes
Hackensack Meridian Health # Health system Initiating visit only for new or not-recently-seen patients Details Hackensack Meridian Health opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Mixed or conditional
Advocate Health # Health system Supports G-codes only if valued for staff time and device costs Details Advocate Health opposes the outsourcing ban, opposes the crosswalk rate cut, takes a mixed or conditional position on the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Mixed or conditional	Opposes
Essentia Health # Health system Supports G-code concept if payment and flexibility are kept Details Essentia Health opposes the outsourcing ban, opposes the crosswalk rate cut, takes a mixed or conditional position on the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Mixed or conditional	Opposes
Allina Health # Health system Details Allina Health opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Opposes
Orlando Health # Health system Wants hospital and ED discharges to count as initiating visits Details Orlando Health opposes the outsourcing ban, opposes the crosswalk rate cut, takes a mixed or conditional position on the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Mixed or conditional	Mixed or conditional
Duke University Health System # Health system Initiating visit only for new or not-recently-seen patients Details Duke University Health System opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Mixed or conditional
Yale New Haven Health # Health system No extra visit if seen within the past year Details Yale New Haven Health opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Mixed or conditional
Texas Health Resources # Health system Supports the goal; opposes duplicative visits Details Texas Health Resources opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Mixed or conditional
Rush University System for Health # Health system Initiating visit only for new or not-seen-in-a-year patients Details Rush University System for Health opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Mixed or conditional
UNC Health # Health system No separate visit if seen in the past year Details UNC Health opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Mixed or conditional
Northern Light Health # Health system Exempt patients seen within a year Details Northern Light Health opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Mixed or conditional
MemorialCare # Health system Objects to repeat visits for established patients Details MemorialCare opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Mixed or conditional
UVA Health # Health system Asks that health-system-wide employment count; discharge encounters should qualify Details UVA Health takes a mixed or conditional position on the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Mixed or conditional	Opposes	Opposes	Mixed or conditional
Trinity Health # Health system Details Trinity Health opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Did not address
Corewell Health # Health system Details Corewell Health opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Did not address
The Queen's Health Systems # Health system Details The Queen's Health Systems opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Did not address
Henry Ford Health # Health system Projects a loss of about $309 per patient per year at proposed rates Details Henry Ford Health did not address the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Did not address	Opposes	Opposes	Did not address
BJC Health # Health system Details BJC Health opposes the outsourcing ban, did not address the crosswalk rate cut, opposes the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Opposes	Supports
Nebraska Medicine # Health system Count a visit within the past year Details Nebraska Medicine opposes the outsourcing ban, did not address the crosswalk rate cut, opposes the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Opposes	Mixed or conditional
Fairview Health Services # Health system Initiating visit met if seen in the past year Details Fairview Health Services opposes the outsourcing ban, did not address the crosswalk rate cut, opposes the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Opposes	Mixed or conditional
City of Hope # Health system Consolidation only if resource differences are preserved; recent or telehealth visit should count Details City of Hope opposes the outsourcing ban, did not address the crosswalk rate cut, takes a mixed or conditional position on the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Mixed or conditional	Mixed or conditional
Johns Hopkins Medicine # Health system Backs simplification if concurrent billing is protected Details Johns Hopkins Medicine opposes the outsourcing ban, did not address the crosswalk rate cut, takes a mixed or conditional position on the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Mixed or conditional	Opposes
Michigan Medicine # Health system New codes must cover full resources Details Michigan Medicine opposes the outsourcing ban, did not address the crosswalk rate cut, takes a mixed or conditional position on the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Mixed or conditional	Did not address
University of Utah Health # Health system Backs simplification; urges caution on bundling Details University of Utah Health opposes the outsourcing ban, did not address the crosswalk rate cut, takes a mixed or conditional position on the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Mixed or conditional	Did not address
Avera Health # Health system Staff employed by the health system should qualify; supports simpler codes with 20-minute increments Details Avera Health opposes the outsourcing ban, did not address the crosswalk rate cut, takes a mixed or conditional position on the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Mixed or conditional	Supports
Beth Israel Lahey Health # Health system Details Beth Israel Lahey Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Opposes
Mount Sinai Health System # Health system Details Mount Sinai Health System opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Supports
Intermountain Health # Health system Waive the visit if an E/M visit occurred within 12 months Details Intermountain Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Mixed or conditional
Jefferson Health # Health system Initiating visit only for new or not-recently-seen patients Details Jefferson Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Mixed or conditional
Mercy Health # Health system Supports RTM established-patient limit; opposes initiating visit Details Mercy Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Mixed or conditional
Houston Methodist # Health system Exception for patients with an established relationship Details Houston Methodist opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Mixed or conditional
CentraCare # Health system Opposes a blanket initiating visit; wants ACO and hospital-at-home exceptions Details CentraCare opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Mixed or conditional
AdventHealth # Health system Exceptions for recent contact, rural and mobility-limited patients Details AdventHealth opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Mixed or conditional
UMass Memorial Health # Health system Would accept inpatient, ED or post-acute encounters Details UMass Memorial Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Mixed or conditional
MultiCare Health System # Health system Supports established-patient rule; opposes initiating visit Details MultiCare Health System opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Mixed or conditional
Ascension # Health system Supports established-patient rule; opposes initiating visit Details Ascension opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Mixed or conditional
Northwell Health # Health system Details Northwell Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Sentara Health # Health system Details Sentara Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Sanford Health # Health system Details Sanford Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Community Health Systems # Health system Details Community Health Systems opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Ballad Health # Health system Details Ballad Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Norton Healthcare # Health system Details Norton Healthcare opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
WellSpan Health # Health system Details WellSpan Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Baptist Memorial Health Care # Health system Details Baptist Memorial Health Care opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
UT Southwestern Medical Center # Health system Details UT Southwestern Medical Center opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Legacy Health # Health system Details Legacy Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Emplify Health # Health system Details Emplify Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
St. Elizabeth Healthcare # Health system Details St. Elizabeth Healthcare opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Pikeville Medical Center # Health system Details Pikeville Medical Center opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Flagler Health # Health system Details Flagler Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Harris Health # Health system Details Harris Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Memorial Sloan Kettering # Health system Asks for a carve-out for health-system-employed staff Details Memorial Sloan Kettering takes a mixed or conditional position on the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Mixed or conditional	Did not address	Did not address	Supports
University of California Health # Health system Accepts established-patient limit; opposes initiating visit Details University of California Health did not address the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Did not address	Did not address	Did not address	Mixed or conditional
VillageMD # Provider group Details VillageMD opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Did not address
Summit Medical Group # Provider group Details Summit Medical Group opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Did not address
The US Oncology Network # Provider group Details The US Oncology Network opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Opposes
UnityPoint Clinic & UnityPoint Accountable Care # Provider group Details UnityPoint Clinic & UnityPoint Accountable Care opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Opposes
Select Medical # Provider group Details Select Medical opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Supports
Powers Health Partners ACO # Provider group Asks for a practical initiating visit Details Powers Health Partners ACO opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Mixed or conditional
Physicians of Southwest Washington & MultiCare Connected Care # Provider group Supports established-patient rule; opposes initiating visit Details Physicians of Southwest Washington & MultiCare Connected Care opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Mixed or conditional
Privia Health # Provider group Details Privia Health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
agilon health # Provider group Details agilon health opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
OneOncology # Provider group Details OneOncology opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Cardiovascular Associates of America # Provider group Details Cardiovascular Associates of America opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
American Medical Association (AMA) # Association Details American Medical Association (AMA) opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Opposes
American Osteopathic Association # Association Details American Osteopathic Association opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Opposes
Vizient # Association Details Vizient opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Opposes
ATA Action # Association Details ATA Action opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Opposes
Connected Health Initiative # Association Details Connected Health Initiative opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Opposes
Multistakeholder digital health letter (17 organizations) # Association Details Multistakeholder digital health letter (17 organizations) opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Opposes
American Academy of Family Physicians (AAFP) # Association Details American Academy of Family Physicians (AAFP) opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Supports
American College of Physicians (ACP) # Association Details American College of Physicians (ACP) opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Supports
American College of Cardiology (ACC) # Association Details American College of Cardiology (ACC) opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Did not address
Federation of American Hospitals # Association Supports visit, but no duplicate post-discharge visits Details Federation of American Hospitals opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Mixed or conditional
AAMC # Association Backs established-patient rule; opposes initiating visit Details AAMC opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Mixed or conditional
Alliance for Connected Care # Association Supports visit with an exemption or transition period Details Alliance for Connected Care opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Mixed or conditional
AdvaMed # Association A recent assessment should count as the visit Details AdvaMed opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Mixed or conditional
APTA Orthopedics (RTM) # Association A physical-therapy visit should count as the initiating visit Details APTA Orthopedics (RTM) opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Opposes	Mixed or conditional
American Hospital Association (AHA) # Association Details American Hospital Association (AHA) opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Opposes
Medical Group Management Association (MGMA) # Association Details Medical Group Management Association (MGMA) opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Opposes
American Association of Nurse Practitioners # Association Initiation at existing visits Details American Association of Nurse Practitioners opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Mixed or conditional
Consumer Technology Association # Association Adopt it, with exceptions for enrolled patients Details Consumer Technology Association opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Mixed or conditional
Remote Monitoring Leadership Council # Association Reasonable guardrail if narrowly modified Details Remote Monitoring Leadership Council opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Mixed or conditional
American Occupational Therapy Association # Association Details American Occupational Therapy Association opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Supports
America's Physician Groups # Association Details America's Physician Groups opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Opposes	Did not address	Did not address
National Rural Health Association # Association Details National Rural Health Association opposes the outsourcing ban, did not address the crosswalk rate cut, opposes the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Opposes	Supports
Health Innovation Alliance # Association Details Health Innovation Alliance opposes the outsourcing ban, did not address the crosswalk rate cut, opposes the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Opposes	Did not address
National Association of Community Health Centers # Association Asks CMS to weigh health-center workflows Details National Association of Community Health Centers opposes the outsourcing ban, did not address the crosswalk rate cut, takes a mixed or conditional position on the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Mixed or conditional	Opposes
American Heart Association # Association Details American Heart Association opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and opposes the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Opposes
American Diabetes Association # Association Details American Diabetes Association opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Supports
AARP # Association Details AARP opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and supports the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Supports
AMGA # Association Opposes a visit that ignores recent E/M care Details AMGA opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and takes a mixed or conditional position on the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Mixed or conditional
American Association of Clinical Endocrinology # Association Details American Association of Clinical Endocrinology opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Premier Inc. # Association Details Premier Inc. opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Primary Care Collaborative # Association Details Primary Care Collaborative opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Digital Medicine Society (DiMe) # Association Details Digital Medicine Society (DiMe) opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
HIMSS # Association Details HIMSS opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Population Health Alliance # Association Details Population Health Alliance opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
Center for Telehealth and e-Health Law (CTeL) # Association Details Center for Telehealth and e-Health Law (CTeL) opposes the outsourcing ban, did not address the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Opposes	Did not address	Did not address	Did not address
American Nurses Association # Association Details American Nurses Association did not address the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Did not address	Opposes	Opposes	Did not address
American Academy of Physical Medicine and Rehabilitation # Association Details American Academy of Physical Medicine and Rehabilitation did not address the outsourcing ban, did not address the crosswalk rate cut, opposes the four G-codes and did not address the initiating visit. Read the letter on regulations.gov	Did not address	Did not address	Opposes	Did not address
No organizations match these filters.

Showing 109 of 109 organizations; 100 oppose the outsourcing ban, 3 support it.

Download CSV

Cite as: CareSimple, “CMS 2027 RPM proposals: who supports and who opposes (CMS-1848-P comment tracker),” data as of September 24, 2026, https://caresimple.com/blog/cms-2027-rpm-proposals-comment-tracker/

Organizations that filed comments without addressing RPM

Payers & payviders: Cigna Group, Elevance Health, BCBS of Michigan, BCBS of Massachusetts, Point32Health, Geisinger.

Health systems: UPMC, Cleveland Clinic, Mass General Brigham, Novant Health, MaineHealth, SSM Health, Baptist Health Kentucky, Penn State Health, Hartford HealthCare, Vanderbilt Health, Northwestern Medicine, OhioHealth, University of Iowa Health Care, Denver Health, Wellstar, Ochsner Health, CommonSpirit Health, MetroHealth, WVU Medicine, Carilion Clinic, Parkview Health, Adventist Health, Erlanger, Presbyterian Healthcare Services, St. Luke's Health System, Owensboro Health, Covenant Health.

Provider groups: Aledade, DaVita, Cityblock Health, Vytalize Health, Lumeris, Wellvana Health, Florida Cancer Specialists, U.S. Physical Therapy.

Associations: Heart Rhythm Society, Endocrine Society, American Society of Nephrology, American Thoracic Society, America's Essential Hospitals.

CareSimple’s position

CareSimple filed its own comments on the proposed rule. In short:

Oppose the direct-employment requirement. Fraud should be met with registration, claims identification and audits, not a ban on a care model that health systems are centralizing into virtual care units.
Oppose crosswalking RPM device supply to self-measured blood pressure. They are different services at different intensities.
Oppose consolidation into four G-codes, which would erase the differences between single-device and multi-device programs.
Support an initiating visit, with a 12-month lookback and protection for patients already enrolled.

Background on the rule and what it means for your program: CMS just proposed the biggest change to RPM since 2019. For current codes and rates, see the RPM billing guide for 2026 and what remote patient monitoring costs.

Frequently asked questions

What is CMS-1848-P?

CMS-1848-P is the proposed rule for the calendar year 2027 Medicare Physician Fee Schedule, published by CMS in summer 2026. Among many provisions, it proposes four changes to remote patient monitoring (RPM) and remote therapeutic monitoring (RTM) payment: a direct-employment requirement for monitoring staff, a practice-expense revaluation that crosswalks device codes to self-measured blood pressure, a possible consolidation into four G-codes, and an initiating visit requirement. Public comments closed September 14, 2026.

What is the RPM outsourcing ban?

The outsourcing ban is CMS’s proposal to pay for RPM and RTM services only when the monitoring is furnished by clinical staff who are direct employees of the billing practitioner or practice. Programs that rely on contracted nurses, third-party monitoring centers or vendor clinical staff would no longer be billable under the RPM and RTM codes.

Who supports the direct-employment requirement for RPM?

Only 3 of the 109 organizations we tracked support it: Humana, the Blue Cross Blue Shield Association and Sutter Health. UVA Health and Memorial Sloan Kettering took a conditional position, asking that staff employed anywhere in a health system qualify. The remaining 100 organizations that addressed it oppose it.

Which payers oppose the RPM outsourcing ban?

UnitedHealth Group, CVS Health, Kaiser Permanente and AHIP filed comments opposing the direct-employment requirement. UnitedHealth Group suggested CMS permit vendors that are coordinated with the billing clinician rather than employed by them. Kaiser Permanente said the proposal would have an outsized impact on integrated delivery systems.

Did anyone support the RPM rate cut?

No. None of the 109 organizations supported crosswalking the RPM device-supply code (99454) to the self-measured blood pressure codes. In total, 42 opposed it, including the AMA, the American Hospital Association, MGMA and every health system that commented on rates. The rest did not address it.

What do commenters say about the initiating visit?

Most accept the idea with conditions. Of the 69 organizations that addressed it, 15 support it as proposed, 19 oppose it and 35 asked for modifications, most often that any visit within the past 12 months should satisfy the requirement and that hospital or emergency department discharges should count as the initiating encounter.

Does this affect RTM as well as RPM?

Yes. The direct-employment requirement and the practice-expense revaluation apply to both RPM (physiologic data from medical devices) and RTM (therapeutic and non-physiologic data). The established-patient limit is specific to RTM, and the four G-codes proposal would replace both code families.

When will CMS finalize the 2027 rule?

CMS typically publishes the Physician Fee Schedule final rule in early November, with changes effective January 1 of the following year. We will update this page and the tracker when the CY 2027 final rule is released.

What is CareSimple’s position?

CareSimple opposes the direct-employment requirement, the crosswalk to self-measured blood pressure and the consolidation into four G-codes, and supports an initiating visit with a 12-month lookback and protection for patients already enrolled.

What happens next

CMS will weigh these comments and publish the CY 2027 Physician Fee Schedule final rule, typically in early November, with an effective date of January 1, 2027. The questions to watch are whether CMS withdraws or narrows the direct-employment requirement, whether it drops the crosswalk to self-measured blood pressure, and whether the four G-codes move from a request for comment to a proposal for 2028. We will update this page within days of the final rule with what CMS decided on each of the four proposals.

Methodology and sources

The docket (CMS-2026-2377) holds more than 40,000 comments, most from individual clinicians and patients. We searched it for about 500 of the largest U.S. health systems and provider organizations, about 65 payers and payer associations, and the major national associations, then read each organization’s filed letter. Positions reflect what each letter says about the RPM and RTM proposals; “did not address” means the letter took no position on that proposal. Organizations whose letters did not discuss RPM are listed separately. Some filers may be missing if their letter was submitted under a different name.

“Crosswalk rate cut” covers CMS’s proposed practice-expense revaluation of the RPM and RTM codes, including crosswalking device-supply codes to self-measured blood pressure. “Four G-codes” refers to CMS’s request for comment on replacing 17 RPM and RTM codes with four bundled G-codes. “Initiating visit” covers limiting RTM to established patients and requiring a separately reportable initiating visit.

Each organization name links to its letter on regulations.gov. Positions are summarized by CareSimple and may simplify nuanced letters; consult the original filings for exact language. The dataset is available as a CSV download under a CC BY 4.0 license. This page is for information only and is not legal or billing advice.

Sources: Regulations.gov docket CMS-2026-2377; CMS, CY 2027 Medicare Physician Fee Schedule proposed rule fact sheet.

Updates

September 25, 2026: Published with 109 organizations from the September 24 docket sweep.

Planning your RPM program for 2027?

Whether the final rule keeps the direct-employment requirement or not, we can help you model the staffing and economics of running RPM with your own clinical team.

Talk to our team

Who supports CMS's 2027 RPM proposals? Almost no one.