CY 2027 RPM/RTM Vendor-Model Revenue & Compliance Readiness Diagnostic
CMS-1848-P proposes limiting RPM/RTM payment when the relevant clinical work is performed by contractors rather than clinical staff employed by the billing practice. This is a proposed rule, not final, and it does not imply that current arrangements are noncompliant or subject to retrospective recoupment. The diagnostic separates today's compliance questions from prospective CY 2027 eligibility.
Request RPM/RTM Readiness DiagnosticWho it's for
Provider organizations and practices billing Medicare RPM/RTM that use third-party vendors.
Based on
CMS-1848-P proposed policy language, current Medicare RPM/RTM requirements, and the staffing, vendor, and billing configuration supplied by the organization.
Why it matters
The consequential question is not whether a vendor is used, but who performs the clinical work supporting the billed services.
What we analyze
Current RPM/RTM staffing and billing model; current-state compliance assessed separately from prospective CY 2027 eligibility; revenue associated with potentially affected workflows; technology-only versus contractor-staffed responsibilities; operational remediation options.
What you receive
A structured readout: current state → proposed CY 2027 state → gap → revenue exposure → response options, with an executive action roadmap. Operational and reimbursement-readiness analysis, not legal advice.
Format
Bounded readiness diagnostic.
Investment
contact us for pricing on Standard, multi-site , or Final-rule refresh
Discuss this engagement
Tell us about the organization and the decision you are facing. We will confirm the scope before work begins.