CMS is asking what RPM devices cost. Physicians must answer.

Remote patient monitoring depends on practices supplying patients with a connected medical device, cellular blood pressure cuff, pulse oximeter or scale that transmits readings automatically. The proposed calendar year (CY) 2027 Medicare Physician Fee Schedule has drawn the most attention for a provision that restricts who can staff remote patient monitoring (RPM) programs. A quieter provision may do more damage: The Centers for Medicare & Medicaid Services (CMS) proposes to reduce Medicare payments for that device by roughly 80%, with the cuts spread over two years. The current $47 per code reimbursement would drop to around $42 in CY 2027 and then to around $10 in CY 2028.

CMS' logic doesn't hold. Practices that can no longer afford to supply devices will stop running these programs, and patients who would have been monitored won't be.

Related coverage: CMS' proposed ban on contracted RPM staff should not survive the comment period

What CMS is proposing

RPM billing codes separate the service into components. Current Procedural Code (CPT) 99453 pays a one-time setup and education fee of about $22. CPT 99454, and its newer companion 99445, pay roughly $47 per 30-day period to supply the device and transmit daily readings. Neither code carries physician work value; both exist solely to recover a practice's cost of buying, provisioning, connecting, shipping and replacing monitoring hardware. For 2027, CMS proposes to revalue 99454 and 99445 by crosswalking them to the self-measured blood pressure (SMBP) codes, 99473 and 99474, citing sparse invoice and pricing data on RPM devices.

When CMS uses one set of codes to value another, that crosswalk imports a flawed assumption. SMBP codes are built around the patient purchasing their own unconnected device and simply reporting readings back. RPM codes exist for the opposite reason. The practice purchases a connected device and incurs recurring, associated costs. Pricing one as though it were the other assumes away the exact costs the RPM codes are designed to cover.

What device codes actually pay for

A practice that runs RPM the way CMS says it wants buys, connects and maintains devices for its own patients. Doing so carries as many as five distinct cost layers, as follows:

• Hardware: Connected monitoring devices, amortized over a typical enrollment period, with an allowance for loss and replacement
• Data transmission: Recurring fees covering cellular connectivity or Bluetooth app usage
• Software connectivity: Recurring fees for the software that monitors incoming data, triages cautionary readings and manages the device fleet
• Support: Patient-facing device troubleshooting
• Logistics: Shipping devices to patients and processing returns

RPM hardware spans a wide range of products, from blood pressure cuffs to scales to spirometers, connected via cellular, Bluetooth or Wi-Fi, with unit costs that vary widely by device category and build quality. Devices are chosen based on patient fit, not the price tag. For example, cellular devices require no pairing, app or broadband, which makes them the clinically appropriate choice for less tech-savvy patients. This population skews toward the oldest, most rural and lowest-income beneficiaries. And hardware is only the entry cost. Once connectivity, monitoring software, patient support, shipping and replacement are factored in, no device on the market can be supplied at anything close to the proposed monthly rate.

Since the SMBP codes contain no device input, the proposed rate prices every device, whatever it costs and however it connects, the same way: at zero. When the payment for supplying a device falls below the cost of supplying it, practices stop supplying devices, and patients who would have been enrolled aren't monitored at all.

The clinical and economic case for remote monitoring is well established elsewhere; this piece is about something narrower. CMS' proposal asks how to accurately value these codes. The honest answer is that no borrowed code can price this market correctly, and actual cost data from actual programs can.

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A reversed methodology and an unresolved data gap

CMS resolved this exact valuation last year, in the opposite direction, using a methodology it built for the purpose and defended at length. In the CY 2026 rulemaking, the American Medical Association's RVS Update Committee recommended a per-click vendor fee, supported by invoices, to capture the recurring cost of device supply and transmission. CMS rejected that specific input over concerns about pricing based on a limited number of invoices, but it didn't conclude that the underlying costs were illusory. Instead, it built its own methodology, pricing the device based on Medicare hospital outpatient claims data, reasoning that hospital claims more accurately reflect actual cost. Applying that methodology, CMS raised the 2026 payment for code 99454 to roughly $47, concluding that the code had been underpaid. One year later, with no new cost evidence in the record, CMS proposes to conclude the opposite, adopting a different methodology without explaining why.

CMS' stated justification for that reversal is that it now lacks sufficient invoice and pricing data on RPM devices. That gap, if real, isn't inevitable. Per-unit device prices aren't secret. A substantial share of the market sells monitoring hardware at published or documentable prices, and cellular data contracts are ordinary invoiceable transactions. CMS prices supplies and equipment across the fee schedule from exactly this kind of documentation every year. Where its own submissions are thin, Congress already gave CMS the tool to close that gap: Section 220(a) of the Protecting Access to Medicare Act of 2014 authorizes the agency to collect resource cost information from any source, including manufacturers and vendors. CMS also scheduled a more durable fix. Several remote monitoring codes are due for resurvey, with the entire code family expected before the CPT Editorial Panel in January 2028. Cutting the device payment by roughly 80% now preempts a process CMS itself put in motion.

The proposal also collides with the rest of the rule. The same rulemaking would require RPM services to be furnished by clinical staff the practice directly employs, a provision that presumes practices will own their programs, including the devices. The pricing proposal makes device ownership uneconomic in the same breath. A practice cannot comply with a rule that requires it to internalize RPM while being paid less than the cost of supplying the device. The two provisions cannot both achieve their stated goals as written.

The evidence CMS says it's missing

CMS has said plainly that it doesn't have enough invoice and cost data to value these devices with confidence. That's an unusual admission for a proposed rule to make, and it cuts both ways. A comment built on data will carry more weight with CMS than a comment built on objection alone.

Practices already have what CMS says it's missing, as follows:

• Vendor invoices and quotes for devices, connectivity and software
• The specific rate below which a program stops being viable, and
• Outcomes data showing what's at stake if it isn't

Submitting that kind of detail before the comment period closes on Sept. 14 does more to change this number than arguing that it's wrong. The data and the remedy work together. Cost evidence in the record doesn't need to be comprehensive to defeat the crosswalk, because even a handful of real invoices proves the proposed rate sits below cost. And if CMS still finds the record too thin to set a precise new value, a thin record is a reason to retain the CY 2026 rate it derived from actual cost data one year ago, not to cut it 80%, while the code family review already scheduled for January 2028 fills the gap for good.

Daniel Tashnek, J.D., is the co-founder of Prevounce Health, a health care software and services company that simplifies the provision of preventive medical services, chronic care management and remote patient monitoring. Daniel is also a practicing health care attorney specializing in regulatory compliance, reimbursement, scope of practice and patient care issues.