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TapestryHealth Submits Comments on CMS’s Proposed 2027 Physician Fee Schedule

TapestryHealth has submitted formal comments to the Centers for Medicare & Medicaid Services regarding the Calendar Year 2027 Medicare Physician Fee Schedule Proposed Rule.
The comments support CMS’s efforts to strengthen program integrity and ensure meaningful practitioner involvement in remote physiologic monitoring and remote therapeutic monitoring. They also urge the agency to avoid policies that could unintentionally restrict access to clinically integrated remote care for residents of skilled nursing facilities and other elder care communities.
TapestryHealth’s recommendations ask CMS to:
  • Evaluate remote monitoring based on clinical integration, supervision, documentation, and practitioner accountability—not employment status alone.
  • Preserve payment for the technology, connectivity, cybersecurity, EHR integration, clinical review, and operational infrastructure required to deliver effective remote monitoring.
  • Retain the existing RPM and RTM code families rather than replacing them with a mandatory four-code structure and rigid 20-minute monthly threshold.
  • Develop a voluntary, outcome-aligned payment pathway for high-acuity institutional populations.
  • Maintain practical flexibility for initiating visits, telehealth-enabled care, and clinically distinct concurrent RPM and RTM services.
At the center of TapestryHealth’s comments is a straightforward principle: remote monitoring should be judged by whether it produces timely, documented clinical action—not simply by staffing structures, minutes accumulated, or data collected.
TapestryHealth welcomes continued engagement with CMS on policies that protect the Medicare program while preserving access to integrated, technology-enabled care for medically complex older adults.