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RTM/RPM Vendor-Contract Audit Checklist

Audit every remote monitoring arrangement against the CY 2027 proposed conditions of payment (CMS-1848-P) before the final rule lands in November. Items marked in red are the ones that can end a billing model outright. Progress saves in your browser.

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1 · Staffing and employment

Proposed: clinical-staff time counts only when the staff member is a direct employee of the billing practitioner or practice. Contracted third-party staff would not qualify.
Identify who furnishes monitoring minutes today.Vendor nurses, practice staff, or a mix? Pull the actual staffing roster, not the contract's description.
Confirm employment status of every person whose time is billed.W-2 employee of the practice, leased employee, 1099 contractor, or vendor employee. Only direct employment clearly survives as proposed.
Price the compliant alternatives.Practice hires monitoring staff; vendor converts to software-only licensing; or staffing restructured before January 1, 2027. Get the delta per enrolled patient.
Check the contract's regulatory-change clause.Who bears the cost if the billing basis disappears? Look for termination rights, fee adjustments, and indemnification tied to CMS rule changes.

2 · Patient eligibility and initiation

Proposed: RTM limited to established patients; RPM or RTM must be initiated by the billing practitioner at a separately reportable face-to-face visit (in person or telehealth).
Audit current enrollment paths for new-patient starts.Any workflow that enrolls patients the practice has not seen face-to-face fails the established-patient test.
Map the initiating visit into your scheduling templates.The visit is separately reportable; decide where it lives (surgical consult, pre-op, telehealth slot) and document the monitoring order at that visit.
Verify consent documentation location and content.Consent, device education, and setup should trace to the practice's record, not only the vendor's platform.

3 · Device economics

Proposed: device-supply and setup codes revalued using lower-cost crosswalks; PE inputs removed from treatment-management codes.
Re-run unit economics at reduced device-supply rates.If the program's margin lives in 98977/98985-type supply billing, model the proposed valuations before renewing anything.
Collect actual device invoices.Both for your own margin math and for the comment letter: CMS explicitly weighs invoice data.
Check hardware pass-through pricing in the vendor contract.Per-device fees pegged to current Medicare rates need a renegotiation trigger.

4 · The bundled G-code scenario

CMS is considering collapsing 17 codes into 4 monthly G-codes, each requiring device supply + 2 days of transmission + 20 minutes of management including a real-time interactive communication, every billed month.
Test your program against the all-elements-monthly standard.What share of current patient-months would qualify if every element were required every month? Get the number.
Add a live-touch workflow if you are asynchronous-only.A monthly real-time interactive communication (patient or caregiver) is in the draft descriptors. Design for it now.
Model revenue under both coding worlds.Current 17-code stack vs. bundled G-codes, at your actual engagement rates. The delta is your comment-letter exhibit.

5 · Compliance and documentation

The OIG findings CMS cites (43% of enrollees missing a service component) are the enforcement backdrop. Assume audits follow the final rule.
Reconcile billed months against transmission logs.Days-of-data requirements per code, verified from device data, not vendor summaries.
Verify time documentation for management codes.Who logged the minutes, their employment status, and the interactive-communication record.
Confirm ownership and portability of monitoring data.If you terminate the vendor, the clinical record and audit trail must come with you.

6 · Strategy

Monitoring that exists to bill codes is fragile. Monitoring that feeds outcomes infrastructure survives payment redesign.
Connect monitoring data to your PRO and functional-outcome stack.MIPS MVP core measures, ASM, and episode models all reward the same longitudinal data RTM produces.
Decide your posture before November.Restructure to comply, renegotiate, or sunset. Renewing a non-compliant contract into 2027 is choosing exposure.
Comment by September 14.The G-code bundle and the employment definition are open questions. Docket CMS-2026-2377.
© 2026 Techy Surgeon · Subscriber tool. Summarizes proposals in CMS-1848-P (federalregister.gov/d/2026-14327), which may change in the final rule. Not legal or reimbursement advice; review contracts with counsel.