The Comment Window Is Open: What CMS’s CY 2027 Fee Schedule Proposal Means for Telehealth Billing

By Elena Pak, Credentialing Department, WCH

State legislatures and Medicaid programs aren’t the only ones rewriting telehealth rules this summer — the same is happening at the federal level, on its own separate clock, as covered from the state side in our companion briefing, “State Telehealth Policy Shifts, Summer 2026.” CMS released its proposed CY 2027 Physician Fee Schedule on July 14, 2026. Most years, this document is a formality for telehealth watchers — a handful of code additions, a routine restatement of statutory dates. This year is different in one important respect: CMS has used the rule to propose a structural change to who gets paid for remote patient monitoring, and it has said so in language pointed enough that it reads less like routine rulemaking and more like a response to a specific problem the agency has decided to solve.

That proposal — and the September 14, 2026 deadline to comment on it — is the reason this rule deserves more than a skim. Everything else in it is largely CMS finishing paperwork that Congress already assigned it through the Consolidated Appropriations Act of 2026 (CAA 2026). The RPM/RTM section is not that. It is CMS exercising discretion, and discretion is the one part of a proposed rule that can still be moved by a well-argued comment before it hardens into January 1, 2027 policy.

Below is what to prioritize between now and the comment deadline, organized by how much say providers actually have in the outcome.


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