The Mississippi Telehealth Association (MTHA) is closely monitoring a significant proposed change from the Centers for Medicare & Medicaid Services (CMS) that could dramatically affect the delivery of Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) services for Medicare beneficiaries.
CMS issued its proposed Calendar Year (CY) 2027 Medicare Physician Fee Schedule in July 2026. Within the proposed rule, CMS addresses the use of clinical staff to furnish RPM and RTM services and proposes to allow Medicare payment when these services are performed by clinical staff employed by the billing practitioner or practice, rather than when the clinical work is performed by contracted third-party personnel.
CMS specifically states that it is proposing to “only allow payment for RPM or RTM services when performed by clinical staff employed by the practice and not when those services are delivered by contractors.”
This proposed change could have significant consequences for the way remote monitoring programs currently operate across Mississippi and particularly within rural and underserved communities.
MTHA Seeking Clarification on Definition of “Employee”
While CMS has clearly identified its intention to distinguish between employed clinical staff and contractors, important questions remain regarding how the agency would define and apply the term “employee” in actual healthcare delivery arrangements.
The Mississippi Telehealth Association is working with providers, national partners, and other stakeholders to gain additional clarity regarding what CMS would consider an employee of a physician or practice and which staffing relationships would remain permissible.
Healthcare organizations utilize a variety of legitimate staffing and contractual arrangements. In many remote monitoring programs, licensed clinical personnel work under the direction and supervision of the treating provider but are employed by a third-party clinical organization.
Whether some of these arrangements could satisfy CMS requirements under the final rule remains an important question requiring additional clarification.
Until that clarification is received, however, MTHA has serious concerns about the potential impact of the proposal.
As presently written and understood, MTHA believes the proposed restriction could be catastrophic for many established RPM and RTM programs serving Medicare patients, particularly those in rural communities.
Rural Providers Could Face the Greatest Impact
Small physician practices, Rural Health Clinics, Federally Qualified Health Centers, and other rural providers frequently do not have sufficient patient volume or workforce availability to directly employ dedicated monitoring nurses and other clinical staff.
Instead, many providers partner with third-party clinical organizations that supply licensed personnel to perform monitoring activities under the direction and supervision of the patient’s healthcare provider. This model allows smaller practices to provide sophisticated chronic disease monitoring services that otherwise may not be financially or operationally possible.
The distinction between employed and contracted clinical staff may therefore have a disproportionate effect on rural providers.
Mississippi already faces significant healthcare workforce shortages. For many small rural practices, the question is not simply whether they would prefer to employ monitoring personnel directly. In many communities, those personnel are difficult to recruit, and the number of patients served by an individual practice may not support a dedicated full-time monitoring team.
Third-party clinical partnerships have helped bridge that gap.
Thousands of Mississippi Medicare Patients Could Be Affected
The potential scale of the issue is substantial.
According to CMS Medicare Physician & Other Practitioners public use data reviewed by the Mississippi Rural Health Association, RPM utilization in Mississippi has grown significantly in recent years. In 2019, only six Mississippi providers billed for RPM treatment management services, with 152 total RPM services reported. By 2023, 282 Mississippi providers were billing RPM treatment management services, with approximately 87,500 RPM services delivered during the year.
Between approximately 5,000 and 6,000 Mississippi Medicare fee-for-service beneficiaries have received RPM annually in recent years. Those figures do not capture the entire remote monitoring population because they exclude Medicare Advantage beneficiaries and certain data suppressed by CMS for privacy purposes.
Remote Physiologic Monitoring is commonly used to monitor patients with conditions such as hypertension, diabetes, and heart failure. Connected devices can transmit physiologic information such as blood pressure, weight, and other measurements to the patient’s healthcare team.
Clinical monitoring personnel can then identify concerning trends and intervene before a patient’s condition progresses to an emergency.
For rural patients who may live significant distances from their healthcare providers, this capability can serve as an important extension of the traditional healthcare system into the patient’s home.
Program Integrity Without Eliminating Access
MTHA recognizes CMS’s responsibility to protect the Medicare program from fraud, waste, and abuse.
Federal oversight agencies have identified problematic practices within the rapidly growing remote monitoring industry, including concerns involving inappropriate beneficiary solicitation and billing for services that may not have been properly furnished.
Those concerns deserve appropriate enforcement.
However, program integrity efforts should distinguish between abusive billing arrangements and legitimate remote monitoring programs operating under the direction of healthcare providers.
Rather than unintentionally eliminating responsible third-party clinical partnerships, MTHA believes safeguards should focus on appropriate clinical oversight, documentation, transparency, patient engagement, accountability, and targeted enforcement against organizations demonstrating abusive practices.
A Proposed Rule, Not Yet Final
Importantly, this policy has not yet taken effect.
CMS issued the CY 2027 Medicare Physician Fee Schedule proposed rule in July, and the public comment period remains open through September 14, 2026.
CMS is specifically seeking stakeholder feedback regarding the use of third-party arrangements in remote monitoring and the potential effect of its proposal on beneficiary access.
That makes participation from Mississippi’s healthcare community particularly important.
The Mississippi Telehealth Association is continuing to evaluate the proposal and seek clarification regarding CMS’s definition of an “employee,” how the requirement would apply to various legitimate staffing arrangements, and what impact the policy could have on existing RPM and RTM programs.
MTHA will provide additional information to members as greater clarity becomes available.
For now, healthcare providers utilizing contracted clinical personnel to support RPM or RTM programs should be aware of the proposal and closely follow its development.
If CMS ultimately interprets the proposed employee requirement broadly and prohibits the third-party clinical staffing arrangements commonly used today, the change could fundamentally alter the delivery of RPM and RTM services to Medicare beneficiaries across Mississippi, with rural patients and providers likely facing some of the greatest consequences. We will keep members posted on updates.