Could a Rule Meant to Protect Remote Monitoring End Up Weakening Connected Care?

This article presents Hoss Care’s perspective on connected-care policy. It is not an independent news report and does not suggest that CMS, HHS-OIG or any other government, regulatory or healthcare organization endorses Hoss Care.

Imagine a patient whose blood pressure begins rising between office visits.

The physician may not recognize the pattern for weeks. The practice is already understaffed, the care team is managing hundreds of patients, and building a complete remote-monitoring department internally may not be financially or operationally realistic.

That is the gap connected care was designed to close.

Remote patient monitoring can help practices identify concerning changes earlier, maintain contact between visits and manage chronic conditions using information collected in the patient’s daily environment.

A new proposal from the Centers for Medicare & Medicaid Services raises an important question: Can the government eliminate low-value remote-monitoring arrangements without also making legitimate connected care more difficult to deliver?

A proposed rule aimed at a real problem

In the Calendar Year 2027 Medicare Physician Fee Schedule proposed rule, CMS proposed that payment for specified remote patient monitoring and remote therapeutic monitoring services furnished by clinical staff would be available only when those staff are direct employees of the billing practitioner or practice.

If finalized, the proposed restriction would begin January 1, 2027. Practices would no longer be able to rely on clinical time furnished through third-party contracting arrangements for the affected services.

The policy remains a proposal. CMS has not finalized it. The public comment period for CMS-1848-P closes September 14, 2026.

The concern behind the proposal is legitimate.

In the Federal Register discussion of the proposed rule, CMS describes remote-monitoring arrangements in which third-party personnel may have a limited relationship with the patient, insufficient interaction with the treating practice and weak integration into the patient’s clinical care.

Federal oversight findings reinforce the need for stronger safeguards.

In 2024, HHS-OIG reported that remote patient monitoring use in Medicare had increased dramatically. It also found that approximately 43 percent of enrollees receiving RPM did not receive all three components of the service, raising questions about whether the monitoring was being used as intended.

HHS-OIG also identified missing information that limited Medicare’s ability to oversee how remote monitoring was ordered and delivered.

A subsequent HHS-OIG review found that Medicare payments for remote patient monitoring exceeded $500 million in 2024. The report identified billing patterns that could help regulators and payers determine which practices may warrant additional scrutiny.

Opaque call centers, indiscriminate patient enrollment, poorly documented activity and services performed without meaningful clinical involvement damage patient trust. They also weaken the credibility of legitimate connected-care programs.

Those practices should be confronted directly.

Employment status is not the same as accountability

The weakness in the proposed approach is that a payroll relationship does not automatically demonstrate clinical control.

An employee can still operate within a fragmented process marked by weak supervision, incomplete documentation and limited provider visibility.

Conversely, a qualified contracted clinical team can work under provider-controlled protocols while every patient interaction, task, decision and escalation remains visible to the responsible practice.

The employment relationship is not necessarily the same as the care relationship.

A stronger policy test would focus on practical questions:

• Who contacted the patient?

• What readings and clinical information did that person review?

• What action was taken?

• How much time was actually spent performing the service?

• Was the individual qualified and authorized to perform the work?

• Was the activity consistent with the provider’s protocols and the patient’s care plan?

• Was a concerning change escalated to the responsible provider?

• Can the practice verify that the documentation supports both the service and the submitted claim?

When those questions cannot be answered, the service should not be billable, regardless of whether the individual performing it is an employee or a contractor.

What meaningful accountability could look like

Technology should make remote care more visible, not more distant.

At Hoss Care, we believe connected-care technology should support structured workflows, clear documentation and provider oversight.

The objective should not be to shield contractors from scrutiny. It should be to hold every person performing work under a practice’s name whether employed internally or working through an authorized external organization to the same auditable standard.

A credible accountability framework could require:

• Named and authorized personnel attached to every patient interaction

• Time-stamped activity supported by appropriate documentation

• Provider-controlled protocols, permissions and escalation pathways

• Visibility into patient readings, outreach, care-plan tasks and interventions

• Clear identification of the individual who reviewed information or contacted the patient

• Reconciliation between documented work, recorded clinical time and submitted billing

• Routine quality, compliance and performance reporting

• The ability for the billing provider to review, supervise and audit the work being performed

These controls address the underlying problem: remote-monitoring arrangements in which the responsible provider cannot confidently verify the care being delivered under the practice’s name.

Independent practices may carry the greatest burden

Large health systems may have the capital, personnel and administrative resources required to employ complete connected-care teams internally.

Many independent and community practices do not.

Consider an independent primary care practice serving a large population of older adults with hypertension, diabetes and other chronic conditions.

The practice may have the clinical expertise to direct a remote-monitoring program but lack the resources to recruit, train and manage a dedicated internal monitoring department.

An appropriately structured external team may allow that practice to extend follow-up between visits while the provider maintains responsibility for protocols, clinical decisions and escalation.

A blanket contractor restriction could force smaller practices to choose between building expensive internal infrastructure and withdrawing from remote-monitoring programs altogether.

The people most affected may be patients who benefit from regular follow-up but already face limited access to care.

Oversight does not require an all-or-nothing choice

CMS does not have to choose between unrestricted outsourcing and eliminating contractor-supported care.

A third option is available: require meaningful clinical control, complete documentation, individual attribution and end-to-end auditability.

This approach would allow CMS to target the arrangements that create the greatest risk while preserving responsible care-delivery models that smaller practices may need.

The same accountability requirements should apply regardless of staffing structure.

If the work cannot be documented, supervised and verified, it should not support a Medicare claim. If the billing provider can demonstrate clinical control and complete accountability, employment status alone may add little additional protection.

The better policy test

The central question should be:

Can the billing provider demonstrate that it supervised the service, understood what was happening with the patient and maintained complete accountability for the care delivered?

CMS is right to protect patients and Medicare from fraudulent, fragmented and low-value operations.

But the strongest safeguard is not simply identifying which organization issued a worker’s paycheck. It is ensuring that every action affecting the patient is visible, attributable, clinically supervised and auditable.

Connected care does not need weaker oversight.

It needs smarter oversight designed to protect both program integrity and patient access.

About this article

This article is Hoss Care thought leadership and represents the company’s perspective on the CY 2027 Medicare Physician Fee Schedule proposed rule.

It is provided for general informational purposes and is not legal, clinical, coding or billing advice.

References to CMS, HHS-OIG and other organizations do not imply their endorsement of Hoss Care, its products or the views expressed in this article.

Primary sources

• CMS-1848-P: CY 2027 Medicare Physician Fee Schedule Proposed Rule

• Federal Register: CY 2027 Medicare Physician Fee Schedule Proposed Rule

• HHS-OIG: Additional Oversight of Remote Patient Monitoring in Medicare Is Needed

• HHS-OIG: Billing for Remote Patient Monitoring in Medicare

Author bio

The Hoss Care Editorial Team develops company perspectives on connected care, clinical operations and healthcare technology.

Hoss Care is focused on care-execution infrastructure, structured clinical workflows, patient engagement and greater visibility into ongoing care.