CMS proposes to pay for remote monitoring only when the people doing the watching are employed by the practice. Here is every Medicare remote-monitoring biller in 2024, arranged by how many patients they watch. Drag the line and see how much of the program lands above it.
Buried in the CY 2027 Physician Fee Schedule proposed rule, well below the conversion-factor headline, is one sentence that reorganises an entire product category:
“…and only to 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.”
Remote physiologic monitoring pays a practice to supply a connected device, collect sixteen days of readings a month, and spend staff time on the data. In 2024 Medicare paid $251.9 million for that across 8,754 billing NPIs — up from $5.1 million in 2019, the first full year the codes were usable. Forty-nine times, in five years.
Almost none of the growth came from practices hiring monitoring nurses. It came from companies that supply the device, the platform, the dashboard and the staff who watch it, and bill under the practice’s NPI. CMS has now proposed to stop paying for that arrangement.
Each bar is a slice of panel size — how many distinct Medicare patients one NPI monitored in 2024. The top chart is money. The middle is billers. They are not the same shape, and that is the whole story.
1. Most remote-monitoring billers are tiny, and they are not where the money is. 3,964 NPIs — 45.3% of everyone billing these codes — monitored 25 patients or fewer. Together they took $21.5 million, 8.5% of the program. That is what remote monitoring looks like when a practice does it with the staff it already has: a couple of dozen heart-failure or hypertension patients, a few thousand dollars a year.
2. The dollars live in a band that nobody staffs casually. Pull the line to 100 patients. 1,134 billers — 13.0% — sit above it, holding $152.0 million, 60.3% of everything Medicare paid. A hundred patients, each needing sixteen days of transmitted readings and twenty minutes of documented interactive management a month, is roughly 33 hours of staff time monthly before anyone answers a phone call.
3. The very top is not a tail, it is a different business. Ten NPIs monitored 3,163 patients or more. They billed $29.3 million — 11.6% of the entire national program, more than the 3,964 smallest billers put together. The largest single NPI in the file is a geriatric-medicine physician credited with 28,663 monitored Medicare patients and $9.35 million — 3.7% of national remote-monitoring spending, under one person’s number.
Today’s briefing sketched a 500-patient RPM panel at roughly $50,000 a month of reimbursement. Set the line to 502 patients — where it starts: 80 billers sit above it, holding $52.4 million, and the average among them works out to $54,540 per month of Medicare payment each. The back-of-envelope was low, if anything. Those 80 NPIs are 0.9% of billers and 20.8% of the money.
Panel size is a proxy for outsourcing, not evidence of it. Four reasons to hold it loosely, and one of them is load-bearing:
Press show minutes billed per patient for the stress test. If the largest panels were simply industrial-scale versions of the same service, minutes per patient would hold roughly flat across the axis. They do not. Management time billed per monitored patient climbs from 6.24 units among panels of 25 or fewer to 10.08 in the 399–794 band, then collapses to 1.46 for the nine NPIs with panels of 1,585–3,162 and recovers only to 6.06 above that. At the very top the business reverts largely to device supply with little billed interaction attached. Whatever is happening in that band, it is not the 20-minutes-of-nurse-time service the code describes — and a rule about who performs that time may not be the instrument that reaches it.
The comment window on CMS-1848-P closes Monday, 14 September 2026. Three things worth knowing before you write: