Most weeks, the 26 companies on this page compete with one another, and with us, for the same health systems, practices and health plans. This time we found ourselves on the same side. Each company wrote to CMS on its own, and the letters say much the same thing: remote patient monitoring works for patients, and the way to protect it is to hold every program to clear standards rather than to rule out one way of staffing it. It is not often that our industry speaks this clearly together, so we wanted to show what it said, company by company.
Analysis of docket CMS-2026-2377 as of . Companion to our tracker of 110 payers, health systems, provider groups and associations. Last updated .
CareSimple is one of the 26 companies and filed its own comments. Every position and quote links to the letter on regulations.gov.
Of the 26 remote patient monitoring and digital-health companies that commented on the RPM provisions of CMS-1848-P, 24 oppose paying for RPM and RTM only when the monitoring staff are direct employees of the billing practice. None supports it; iRhythm Technologies and Teladoc Health did not address it. Nineteen oppose crosswalking the device-supply code to self-measured blood pressure, and none supports that either.
The industry did not stop at objecting. Twenty-one of the 26 companies proposed at least one specific safeguard against RPM fraud: registering or accrediting monitoring organizations (8 companies), naming the furnishing organization on every claim (12), auditing outliers with claims data (8), banning cold-calling and vendor-originated enrollment (5), and setting standards for supervision and clinical integration regardless of who employs the staff (11).
See the five safeguards ↓ Primary sources: docket CMS-2026-2377 · CMS proposed rule fact sheet
The five safeguards the industry proposed
CMS based the proposal on Office of Inspector General reports on RPM billing. The companies that wrote in share the goal of proper billing. They argued that employment status is the wrong test, because it says nothing about how a program is run, and they put forward specific safeguards that address the conduct CMS is concerned about directly, whoever employs the staff.
Register or accredit monitoring organizations
Create an enrollment, registration or accreditation category for companies that furnish RPM, so CMS knows who they are and can revoke bad actors.
8 companies: CareSimple, Cadence, Health Recovery Solutions, Accuhealth, Salvo Health, ThoroughCare, Smart Meter, RemetricHealth
Name who furnished the service
Put the ordering practitioner and the furnishing organization on every claim through NPIs or modifiers, or require disclosure of the monitoring partner.
12 companies: CareSimple, Cadence, Prevounce Health, Health Recovery Solutions, ChartSpan, 1bios, ResMed, ThoroughCare, Carematix, Welby Health, Unika Health, Wellinks
Audit the outliers
Use claims data, the method OIG itself used, to target practices billing without a prior relationship or with aberrant patterns, instead of banning a whole care model.
8 companies: CareSimple, Prevounce Health, Health Recovery Solutions, ChartSpan, Salvo Health, Limber Health, Unika Health, Boston Scientific
Ban the abusive practices directly
Prohibit cold-calling and unsolicited or vendor-originated enrollment, and require the practitioner to order or affirm enrollment.
5 companies: CareSimple, Health Recovery Solutions, Accuhealth, Carematix, TOCA Health
Set standards for supervision and integration
Require written agreements, escalation protocols, documentation in the practice’s record and practitioner oversight, whoever employs the staff.
11 companies: ChartSpan, ResMed, Health Recovery Solutions, Welby Health, Unika Health, Carematix, Philips, Wellinks, RemetricHealth, Medtronic, 1bios
CareSimple’s own letter proposed the first four. Name who furnished the service (12 companies) and set standards for supervision and integration (11) are the two that appear most often across the 21 letters.
What’s at stake
Scale. Health Recovery Solutions says it has monitored more than 2 million patients across 250+ provider organizations. Smart Meter's devices support more than 300,000 patients. Cadence serves more than 80,000 Medicare beneficiaries on RPM, and 1bios more than 30,000 patients each month. These figures overlap and are not additive, but they show how much of Medicare RPM runs through partners.
Outcomes. Cadence cites a peer-reviewed study of its program showing a $1,302 reduction in total annual cost of care per patient, driven by 27% fewer hospitalizations. HRS cites Frederick Health claims data showing roughly $19,500 in avoided Part A spend per patient over six months.
Small practices. 1bios says 57% of its client practices are solo practices. Smart Meter writes that for many small, rural and resource-constrained practices, outsourced clinical monitoring is the only practical way to offer RPM at scale.
Patients who would lose monitoring. Remote Care Partners, which manages more than 8,000 RPM patients for about 15 clinics, told CMS it believes 80% of those patients would be dropped from monitoring by their practices if the rule is finalized.
In their own words
“Clinical integration and physician accountability are determined by the oversight, protocols, and supervision exercised by the treating practitioner rather than by the employment status of clinical staff.”
Boston Scientific
“A direct-employment test would leave those actors untouched while eliminating the compliant arrangements that legitimate practices and health systems rely on.”
CareSimple
“An employed nurse can cold-call a beneficiary. A contracted nurse cannot, if the program requires a documented order and an established patient relationship.”
Health Recovery Solutions
“The non-compliant conduct is real but narrow. The categorical claim about outsourcing is broad and, in our direct experience, mistaken.”
Prevounce Health
“The central defect is that the employment test does not distinguish good actors from bad ones.”
Unika Health
“Employment relationship establishes a legal relationship. It does not, standing alone, establish a clinical relationship.”
1bios
Where vendors don’t agree
The initiating visit. Vendors are as split as health systems. Ten want changes, often a 12-month lookback so patients seen recently don't need a new visit, six oppose it, and one (Unika Health) supports it.
Bundled G-codes. Most oppose collapsing 17 codes into four, but 1bios, Precision Recovery, Unika Health and Welby Health are open to simplification if payment still reflects intensity and effort.
Vendor-by-vendor positions
The table below shows each company’s position on the four proposals and the safeguards it proposed; click a safeguard card above to see only the companies that proposed it.
Safeguards: Register or accredit monitoring organizations Name who furnished the service Audit the outliers Ban the abusive practices directly Set standards for supervision and integration
1bios # Open to bundling with intensity tiers; visit with 12-month lookback and grandfathering Details1bios 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. Its letter proposes naming the furnishing organization on the claim and setting standards for supervision and integration. “Employment relationship establishes a legal relationship. It does not, standing alone, establish a clinical relationship.” | Opposes | Opposes | Mixed or conditional | Mixed or conditional | 2Name on claim: Name who furnished the service5Supervision standards: Set standards for supervision and integration |
Accuhealth # DetailsAccuhealth opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and opposes the initiating visit. Its letter proposes registering or accrediting monitoring organizations and banning the abusive practices directly. | Opposes | Opposes | Opposes | Opposes | 1Register: Register or accredit monitoring organizations4Ban abuses: Ban the abusive practices directly |
Boston Scientific # DetailsBoston Scientific opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and did not address the initiating visit. Its letter proposes auditing outliers with claims data. “Clinical integration and physician accountability are determined by the oversight, protocols, and supervision exercised by the treating practitioner rather than by the employment status of clinical staff.” | Opposes | Opposes | Opposes | Did not address | 3Audit outliers: Audit the outliers |
Cadence # Asks that patients seen in the past year be exempt from a new visit DetailsCadence 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. Its letter proposes registering or accrediting monitoring organizations and naming the furnishing organization on the claim. | Opposes | Opposes | Opposes | Mixed or conditional | 1Register: Register or accredit monitoring organizations2Name on claim: Name who furnished the service |
Carematix # DetailsCarematix opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Its letter proposes naming the furnishing organization on the claim, banning the abusive practices directly and setting standards for supervision and integration. | Opposes | Opposes | Did not address | Did not address | 2Name on claim: Name who furnished the service4Ban abuses: Ban the abusive practices directly5Supervision standards: Set standards for supervision and integration |
CareSimple # Supports an initiating visit with a 12-month lookback and grandfathering of enrolled patients DetailsCareSimple 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. Its letter proposes registering or accrediting monitoring organizations, naming the furnishing organization on the claim, auditing outliers with claims data and banning the abusive practices directly. “A direct-employment test would leave those actors untouched while eliminating the compliant arrangements that legitimate practices and health systems rely on.” | Opposes | Opposes | Opposes | Mixed or conditional | 1Register: Register or accredit monitoring organizations2Name on claim: Name who furnished the service3Audit outliers: Audit the outliers4Ban abuses: Ban the abusive practices directly |
ChartSpan # Accepts established-patient rule; opposes a new initiating visit DetailsChartSpan 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. Its letter proposes naming the furnishing organization on the claim, auditing outliers with claims data and setting standards for supervision and integration. | Opposes | Opposes | Opposes | Mixed or conditional | 2Name on claim: Name who furnished the service3Audit outliers: Audit the outliers5Supervision standards: Set standards for supervision and integration |
Health Recovery Solutions (HRS) # Supports RTM established-patient rule; opposes initiating visit as drafted DetailsHealth Recovery Solutions 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. Its letter proposes registering or accrediting monitoring organizations, naming the furnishing organization on the claim, auditing outliers with claims data, banning the abusive practices directly and setting standards for supervision and integration. “An employed nurse can cold-call a beneficiary. A contracted nurse cannot, if the program requires a documented order and an established patient relationship.” | Opposes | Opposes | Opposes | Mixed or conditional | 1Register: Register or accredit monitoring organizations2Name on claim: Name who furnished the service3Audit outliers: Audit the outliers4Ban abuses: Ban the abusive practices directly5Supervision standards: Set standards for supervision and integration |
InVite Fitness # DetailsInVite Fitness opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and opposes the initiating visit. Its letter does not propose a specific safeguard. | Opposes | Opposes | Opposes | Opposes | –None proposed |
iRhythm Technologies # Asks that any valuation change rest on invoice-based data DetailsiRhythm Technologies did not address the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Its letter does not propose a specific safeguard. | Did not address | Opposes | Did not address | Did not address | –None proposed |
Limber Health (RTM) # Backs established-patient rule; opposes a separate billable visit DetailsLimber 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. Its letter proposes auditing outliers with claims data. | Opposes | Opposes | Opposes | Mixed or conditional | 3Audit outliers: Audit the outliers |
Medtronic # Backs the relationship; opposes a mandatory separate visit DetailsMedtronic 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. Its letter proposes setting standards for supervision and integration. | Opposes | Did not address | Opposes | Mixed or conditional | 5Supervision standards: Set standards for supervision and integration |
Philips # Backs an established relationship; a recent visit should count DetailsPhilips 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. Its letter proposes setting standards for supervision and integration. | Opposes | Opposes | Opposes | Mixed or conditional | 5Supervision standards: Set standards for supervision and integration |
Precision Recovery # Suggests bundling device and management codes DetailsPrecision Recovery 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. Its letter does not propose a specific safeguard. | Opposes | Did not address | Mixed or conditional | Did not address | –None proposed |
Prevounce Health # Two letters: staffing (19656) and valuation (11538) DetailsPrevounce Health opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and opposes the initiating visit. Its letter proposes naming the furnishing organization on the claim and auditing outliers with claims data. “The non-compliant conduct is real but narrow. The categorical claim about outsourcing is broad and, in our direct experience, mistaken.” | Opposes | Opposes | Opposes | Opposes | 2Name on claim: Name who furnished the service3Audit outliers: Audit the outliers |
RemetricHealth # Backs established patient; initiating visit need not be separate DetailsRemetricHealth 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. Its letter proposes registering or accrediting monitoring organizations and setting standards for supervision and integration. | Opposes | Did not address | Opposes | Mixed or conditional | 1Register: Register or accredit monitoring organizations5Supervision standards: Set standards for supervision and integration |
Remote Care Partners # DetailsRemote Care Partners 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. Its letter does not propose a specific safeguard. | Opposes | Did not address | Did not address | Did not address | –None proposed |
ResMed # DetailsResMed opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and opposes the initiating visit. Its letter proposes naming the furnishing organization on the claim and setting standards for supervision and integration. | Opposes | Opposes | Opposes | Opposes | 2Name on claim: Name who furnished the service5Supervision standards: Set standards for supervision and integration |
Salvo Health # DetailsSalvo Health opposes the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and opposes the initiating visit. Its letter proposes registering or accrediting monitoring organizations and auditing outliers with claims data. | Opposes | Opposes | Opposes | Opposes | 1Register: Register or accredit monitoring organizations3Audit outliers: Audit the outliers |
Smart Meter # DetailsSmart Meter opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and did not address the initiating visit. Its letter proposes registering or accrediting monitoring organizations. | Opposes | Opposes | Did not address | Did not address | 1Register: Register or accredit monitoring organizations |
Teladoc Health # DetailsTeladoc Health did not address the outsourcing ban, opposes the crosswalk rate cut, opposes the four G-codes and did not address the initiating visit. Its letter does not propose a specific safeguard. | Did not address | Opposes | Opposes | Did not address | –None proposed |
ThoroughCare # DetailsThoroughCare opposes the outsourcing ban, opposes the crosswalk rate cut, did not address the four G-codes and opposes the initiating visit. Its letter proposes registering or accrediting monitoring organizations and naming the furnishing organization on the claim. | Opposes | Opposes | Did not address | Opposes | 1Register: Register or accredit monitoring organizations2Name on claim: Name who furnished the service |
TOCA Health # DetailsTOCA 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. Its letter proposes banning the abusive practices directly. | Opposes | Did not address | Did not address | Did not address | 4Ban abuses: Ban the abusive practices directly |
Unika Health (formerly iHealth) # G-codes acceptable only with a lower data-day threshold DetailsUnika 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. Its letter proposes naming the furnishing organization on the claim, auditing outliers with claims data and setting standards for supervision and integration. “The central defect is that the employment test does not distinguish good actors from bad ones.” | Opposes | Did not address | Mixed or conditional | Supports | 2Name on claim: Name who furnished the service3Audit outliers: Audit the outliers5Supervision standards: Set standards for supervision and integration |
Welby Health # Would implement G-codes but says they were never proposed with descriptors; opposes an added encounter DetailsWelby 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. Its letter proposes naming the furnishing organization on the claim and setting standards for supervision and integration. | Opposes | Opposes | Mixed or conditional | Mixed or conditional | 2Name on claim: Name who furnished the service5Supervision standards: Set standards for supervision and integration |
Wellinks # DetailsWellinks 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. Its letter proposes naming the furnishing organization on the claim and setting standards for supervision and integration. | Opposes | Did not address | Did not address | Did not address | 2Name on claim: Name who furnished the service5Supervision standards: Set standards for supervision and integration |
| No companies match these filters. | |||||
Showing 26 of 26 companies; 24 oppose the outsourcing ban, 0 support it.
Cite as: CareSimple, “What the RPM industry proposed in response to CMS’s 2027 RPM proposals: 5 fraud safeguards (Part 2 of 2)” (CMS-1848-P vendor comments, 26 companies), data as of September 27, 2026, https://caresimple.com/blog/rpm-industry-cms-2027-comments/
Vendors that filed without addressing RPM, or with no filing found
Filed on other topics: Abbott, Baxter, eClinicalWorks.
No filing found under their names: CopilotIQ, HealthSnap, Tenovi, BioIntelliSense, CoachCare, Biofourmis, Validic, Omron, Withings, Dexcom, Masimo, Hinge Health, SWORD Health, Omada, Glooko.
Commented on RPM but proposed no specific safeguard: InVite Fitness, iRhythm Technologies, Precision Recovery, Remote Care Partners, Teladoc Health.
A note from our CEO
CareSimple has been building remote patient monitoring since 2009. Over those years, health systems, physician groups, payers and technology partners have built these programs together, one practice and one patient at a time. The letters on this page show how much of that work depends on partnership: specialized clinical teams that let a small practice monitor patients around the clock, and connected devices that reach people in their homes. We share CMS's goal of stopping abuse, and we proposed registration, claims identification and audits ourselves. But a test based on who signs a nurse's paycheck would not stop bad actors. It would dismantle programs that work, and the patients in them would pay the price. The industry is not asking CMS to look away. It is asking CMS to target the conduct, not the care model, as more than 100 payers, health systems, provider groups and associations also urged.
Most of the companies on this page are our competitors, and we will keep competing for every program. On this rule, and on the case for remote patient monitoring itself, we are on the same side. We would welcome working alongside them, and with CMS, to put these safeguards in place.
Michel Nadeau, President & CEO, CareSimple
Frequently asked questions
What did RPM vendors say about CMS’s proposed outsourcing ban?
Of the 26 remote patient monitoring and digital-health companies that commented on CMS-1848-P, 24 oppose the requirement that monitoring staff be direct employees of the billing practice, and none supports it. Two companies, iRhythm Technologies and Teladoc Health, filed on other RPM provisions without addressing the ban. The common argument is that employment status does not distinguish good actors from bad ones, because a fraudulent practice can employ a nurse as easily as a legitimate one can contract with one.
What did vendors propose instead of the ban?
Twenty-one of the 26 companies proposed at least one specific safeguard. The five that recur across the letters are: register or accredit monitoring organizations; name who furnished the service on every claim, through NPIs, modifiers or disclosure; audit the outliers using claims data; ban the abusive practices directly, such as cold-calling and vendor-originated enrollment; and set standards for supervision and clinical integration regardless of who employs the staff. Naming the furnishing organization on the claim was the most common proposal, made by 12 companies.
Which companies commented?
The 26 are 1bios, Accuhealth, Boston Scientific, Cadence, Carematix, CareSimple, ChartSpan, Health Recovery Solutions, InVite Fitness, iRhythm Technologies, Limber Health, Medtronic, Philips, Precision Recovery, Prevounce Health, RemetricHealth, Remote Care Partners, ResMed, Salvo Health, Smart Meter, Teladoc Health, ThoroughCare, TOCA Health, Unika Health (formerly iHealth), Welby Health and Wellinks. Abbott, Baxter and eClinicalWorks filed on other topics. No filing was found under the names of CopilotIQ, HealthSnap, Tenovi, BioIntelliSense, CoachCare, Biofourmis, Validic, Omron, Withings, Dexcom, Masimo, Hinge Health, SWORD Health, Omada and Glooko.
Did any vendor support the crosswalk to self-measured blood pressure?
No. Nineteen companies oppose revaluing the RPM device-supply code by crosswalking it to the self-measured blood pressure codes, and the other 7 did not address it. iRhythm asked that any valuation change rest on invoice-based cost data.
Do vendors agree with each other on the initiating visit?
No more than health systems do. Ten companies would accept an initiating visit with changes, most often a 12-month lookback so that patients seen recently do not need a new visit, and grandfathering of patients already enrolled. Six oppose it and one, Unika Health, supports it. Nine did not address it.
How does the industry’s position compare with payers and health systems?
It is the same position, held more uniformly. In our companion tracker, 100 of 110 payers, health systems, provider groups and associations oppose the direct-employment requirement and 3 support it. Among vendors, 24 of 26 oppose it and none supports it. The difference is that the vendor letters spend more of their length on what CMS should do instead.
Is CareSimple one of the 26?
Yes. CareSimple filed its own comments, opposing the direct-employment requirement, the crosswalk and the four G-codes, supporting an initiating visit with a 12-month lookback, and proposing registering or accrediting monitoring organizations, naming the furnishing organization on the claim, auditing outliers with claims data and banning the abusive practices directly. CareSimple’s positions are shown in the table like every other company’s, and every quote and figure on this page links to the filed letter.
What happens next
CMS is expected to publish the CY 2027 Physician Fee Schedule final rule in early November, effective January 1, 2027. We will update this page and the tracker of 110 payers, health systems, provider groups and associations with what CMS decided, and whether any of the safeguards proposed here made it into the final rule.
Methodology and sources
We searched docket CMS-2026-2377 for about 120 RPM and digital-health vendors by name and read each letter that addressed the RPM and RTM proposals. Positions reflect what each letter says; “did not address” means the letter took no position on that proposal. Safeguards are grouped by CareSimple from the letters' own proposals, and a company is listed only where its letter makes that proposal. Quotes and figures are taken word for word from the filed letters; figures are as reported by each company and were not independently verified. CareSimple is one of the 26 companies and filed its own comments.
Each company 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; CareSimple’s comment letter. For current codes and rates, see the RPM billing guide for 2026.
Updates
- : Published with 26 companies from the September 27 docket sweep.
Company names and trademarks are the property of their respective owners. They are used here only to identify the organizations that filed comments and do not imply any affiliation with, or endorsement by, those organizations.
This article was designed and edited by CareSimple. AI language models assisted with the docket research, the reading of comment letters and the drafting; every position, quote and figure was checked by CareSimple staff against the filed letters.
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