Here’s How TimeDoc Health Is Preparing, and How We’ll Help You Do the Same.
On July 14, 2026, CMS released the Calendar Year 2027 Physician Fee Schedule proposed rule, nearly 1,600 pages that, if finalized, would reshape how remote monitoring and care management services are delivered and paid for under Medicare. The proposals are significant. Some are challenging. And all of them point in the same direction: toward accountable, longitudinal, population-based primary care.
Let us be clear at the outset: these are proposed changes, not final policy. CMS is accepting public comments through September 12, 2026, and the final rule is expected by the end of October. Provisions can and often do change between proposal and finalization. But the direction is unmistakable, and organizations that wait for the final rule to begin planning will be starting a race everyone else has already begun.
Here is our honest read of what CMS has proposed, what it would mean for practices and health systems, and how we intend to adapt alongside our partners if these changes are implemented.
What CMS Has Proposed
Remote Patient Monitoring and Remote Therapeutic Monitoring face the biggest changes
The most consequential proposal for the remote monitoring industry is a direct employment requirement. Beginning January 1, 2027, Medicare would only pay for RPM and RTM services when they are furnished by clinical staff directly employed by the billing practitioner or practice. Outsourced monitoring, the model in which a third-party vendor’s clinical staff furnish monitoring services on a practice’s behalf, would no longer be billable.
Alongside the employment requirement, CMS’s proposed rule also includes:
- RTM services be limited to established patients only (RPM already carries this requirement)
- Both RPM and RTM require a separately reportable, face-to-face initiating visit (in person or via telehealth) before monitoring begins
- A solicitation of comments on RPM\/RTM code consolidation into bundled G-codes, which could affect device supply and treatment management payments
Notably, employed clinical staff are not required to be physically located within the practice – remote employment would satisfy the requirement. A significant open question is whether patients currently enrolled in RPM programs would need a new initiating visit to continue – the proposed rule does not include grandfathering language, and CMS should address this in the final rule.
CMS has framed these proposals as guardrails: responses to documented concerns about fraud, waste, and low-value monitoring in a program whose payments have grown rapidly since 2018. Whatever one thinks of the specific mechanisms, the intent is clear, CMS wants remote monitoring anchored inside an established clinical relationship.
Chronic Care Management: CMS signals increased scrutiny
The proposed rule does not restrict third-party support for CCM. However, CMS issued a Request for Information suggesting it has questions about fraud, waste, and abuse across care management services broadly, including how supervision is performed and how the program verifies that beneficiaries actually receive the services billed.
Read the signal, not just the rule text. Time-based, per-service care management billing is under a microscope, and the administrative burden of defending every logged minute is only going to grow. In our view, the era of minute-tracking as the foundation of care management revenue is drawing to a close, not overnight, and not by mandate in this rule, but steadily, through the accumulated weight of oversight, documentation requirements, and CMS’s clearly stated preference for a different model.Connect with TimeDoc Health today to see how Advanced Primary Care Management (APCM) will benefit your health organization!
Behavioral health and advance care planning are the bright spots
While CMS tightens remote monitoring, it is simultaneously investing in behavioral health. The proposed rule includes substantial payment increases for Psychiatric Collaborative Care Management (CoCM) and Behavioral Health Integration (BHI) services, including a proposed 46% increase in the work RVU value for initial Psychiatric Collaborative Care Management (CoCM) visits and a meaningful increase in the behavioral health care manager labor rate. Critically, CMS has proposed no employment mandate and no third-party restrictions for BHI services.
The rule also proposes new G-codes that separately value clinical staff time for Advance Care Planning – supplementing, not replacing, existing ACP codes – and adds these new codes to the Medicare Telehealth list, creating a delegable, telehealth-eligible service line for practices caring for aging and seriously ill populations.
The bigger picture: Medicare is moving to accountable primary care
Step back from the individual code changes and the across-the-board conversion factor reduction of approximately 1.7% for non-APM providers – a consequence of the expiration of a one-year Congressional add-on from 2026 – and a coherent strategy emerges. CMS is proposing to make ACO participation easier, phase out traditional MIPS reporting, and, most tellingly, gather input on redesigning primary care payment itself, including the role of technology-enabled care and prospective, per-member-per-month payment within the Medicare Shared Savings Program.
This is the same philosophy that produced Advanced Primary Care Management (APCM) in 2025: a monthly, bundled, risk-stratified payment for comprehensive primary care management, free of minute-by-minute time tracking. APCM is not a side program. It is the most significant step CMS has finalized toward population-based primary care – even as CMS signals it views further evolution of the model as likely.
CMS has acknowledged that first-year APCM uptake was lower than anticipated – which is exactly why the window for practices to move early, with a capable partner, remains wide open.
What This Means: The Center of Gravity Is Shifting from CCM to APCM
For years, CCM and RPM have been the workhorses of Medicare care management. They aren’t disappearing tomorrow. That said, the CY 2027 proposals, the RPM employment mandate, the CCM RFI, CMS’s solicitation of comments on RPM/RTM code consolidation into bundled G-codes, and the primary care payment RFI, all reinforce the same conclusion: fee-for-service, per-code care management is becoming harder to operate, while bundled, population-based models are being actively built up.
APCM answers nearly every concern CMS raised in this rule. It requires an ongoing practitioner relationship rather than transactional enrollment. It replaces minute-tracking with accountability for a defined set of comprehensive service elements. It stratifies payment by patient complexity. And it aligns naturally with ACO participation and quality performance, the exact destination CMS is steering toward.
That is why TimeDoc Health has made APCM the centerpiece of our care management strategy, prior to this announcement, and going into 2027, not as a hedge against regulatory risk, but because we believe it is genuinely the better model for practices, for patients, and for the sustainability of care management programs.
How TimeDoc Health Will Adapt, With You
If these proposals are finalized as written, here is how we intend to support our partners through the transition:
- APCM as the flagship care management program. We have built a complete APCM offering, patient identification and risk stratification, enrollment workflows, comprehensive service delivery infrastructure, and quality reporting, designed to help practices transition eligible CCM populations into APCM and capture the full value of the bundled payment. For most primary care organizations, this is the single highest-leverage move available before January 2027.
- A population health partnership model built for capitation. As payment shifts toward per-member-per-month and risk-based arrangements, we are formalizing tiered partnership models based on lives under management, with the ability to align our success with yours through quality-linked and upside-risk arrangements. Practices and ACOs need a partner whose economics point the same direction theirs do. TimeDoc will meet that need.
- Technology and analytics that practices run with their own teams. For organizations that continue RPM and RTM with internally employed clinical staff, as the proposed rule would require, we will provide the platform layer: device integration, patient engagement, data analytics, risk stratification, and workflow tools that make an in-house monitoring program operable and efficient. The proposed rule restricts who can furnish the clinical service; it does not restrict practices from using best-in-class technology to do it well.
- Continued strength in behavioral health. BHI and CoCM remain fully open to collaborative delivery models, and are getting meaningfully better funded. For organizations looking to expand integrated behavioral health, the CY 2027 proposals make this the right moment, and our BHI programs will continue uninterrupted.
- Compliance readiness ahead of the curve. CMS has told the industry what it will be looking for: documented initiating visits, verified service delivery, and defensible supervision. We are strengthening documentation and audit-readiness across our programs now, so our partners enter 2027 ahead of scrutiny rather than reacting to it.
What You Should Do Between Now and November
First, participate in the comment period. Comments on the proposed rule are due to CMS by September 12, 2026. If these changes would affect your patients’ access to care, particularly in rural and under-resourced communities, CMS needs to hear it, with specifics.
Second, model your 2027 care management revenue under both scenarios. Understand what your program looks like if the RPM employment mandate is finalized, and what your CCM population would look like transitioned to APCM. The organizations that do this math now will make better decisions in Q4.
Third, don’t wait for the final rule to start the APCM conversation. APCM is available today. Practices that build APCM capability in 2026 aren’t betting on a proposed rule, they’re adopting the model CMS has already finalized and is clearly committed to expanding.
The CY 2027 proposed rule asks a lot of the care management industry. We think it also clarifies something important: the future belongs to organizations that manage populations, not minutes. That’s the future TimeDoc Health is building for, and we’d welcome the chance to help you build for it too.
TimeDoc Health partners with physician practices, health systems, and ACOs to deliver comprehensive virtual care management, including Advanced Primary Care Management, Behavioral Health Integration, and population health technology. To discuss what the CY 2027 proposals mean for your organization, contact our team.
This article discusses proposed federal rulemaking that has not been finalized and is subject to change. It is provided for informational purposes and does not constitute legal, billing, or compliance advice.
