CMS Could Eliminate Pharmacy RPM Revenue in 2027.
Imagine waking up on January 1 and discovering that one of your pharmacy’s growing clinical revenue streams is no longer billable—not because your outcomes were poor, not because your patients weren’t benefiting, and not because you did anything wrong…
…but simply because you weren’t on someone else’s payroll.
That’s exactly what CMS is proposing for Medicare Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) services beginning in 2027.
If finalized, this rule could effectively shut independent pharmacies out of contracted RPM and RTM programs with physician practices, making it significantly harder for community pharmacies to participate in one of the fastest-growing clinical service opportunities in healthcare. The good news? This is still only a proposed rule—and we have until September 14 to fight it.
Before you assume someone else will handle this…
Don’t.
CMS is legally required to review substantive public comments before finalizing a rule. Every thoughtful comment submitted by pharmacists, physicians, patients, and practice managers increases the likelihood that this proposal is modified—or withdrawn altogether.
That’s why this blog isn’t just about explaining what’s happening.
It’s about helping you protect an important clinical service, preserve a growing non-PBM revenue opportunity, and ensure independent pharmacies continue to have a seat at the table.
Let’s break down exactly what’s being proposed—and, more importantly, what you can do about it.
Here’s The Key Details Of This Rule Change
There are more than 700 pages in CMS’s proposed 2027 Medicare Physician Fee Schedule.
Naturally, tucked inside all those pages is one sentence that could wipe out an entire clinical service and revenue opportunity for independent pharmacies.
Because apparently important information can never be placed somewhere convenient.
On July 14, CMS released its proposed rule for the 2027 Medicare Physician Fee Schedule, known as CMS-1848-P. Among many other changes, CMS is proposing that certain remote physiologic monitoring, or RPM, and remote therapeutic monitoring, or RTM, services only be payable when the clinical staff performing them are employed by the billing physician or practice.
That one employment requirement could create an enormous problem for community pharmacies.
Many independent pharmacies currently work as contracted clinical partners for local physician practices. The physician bills Medicare, while the pharmacist helps monitor readings, communicate with patients, identify potential problems, document interventions, and keep the program running.
Under the proposed policy, that contracted arrangement may no longer qualify for Medicare payment beginning January 1, 2027. Contracted pharmacists and pharmacy teams could be excluded even when they are operating under the practice’s supervision and following its clinical protocols.
CMS also proposes other RPM and RTM changes, including:
- Requiring an initiating visit before RPM or RTM begins
- Requiring a patient to be established with the billing practitioner for RTM
- Revaluing certain device-supply codes downward
- Considering whether RPM and RTM services should eventually be bundled into four new G-codes
There is some good news.
The employment proposal described in the source material does not extend to chronic care management, or CCM, and advanced primary care management, or APCM. Contracted staffing arrangements for those programs would remain available under the proposal.
But I would not take too much comfort from that.
Once CMS establishes employment status as a condition for one group of care-management services, it becomes much easier for that idea to wander into other programs later.
CMS Is Trying to Solve a Real Problem
I want to be fair here.
CMS did not wake up one morning and decide it had nothing better to do than make life harder for community pharmacies.
There are legitimate concerns about remote monitoring companies that enroll large numbers of patients, generate thousands of monitoring minutes, and operate with little meaningful connection to either the patient or the local care team.
Nobody wants Medicare paying for someone to glance at a dashboard, check a box, and call that healthcare.
The problem is that the proposed solution does not distinguish between those models and a local pharmacist working directly with a physician practice.
Those are not the same thing.
A pharmacist down the street who knows the patient, communicates with the prescriber, reviews medication adherence, and intervenes when something looks wrong is the opposite of the anonymous monitoring model CMS is trying to address.
Employment status is a very poor shortcut for measuring quality.
Supervision matters. Documentation matters. Clinical accountability matters. Patient outcomes matter.
Whether someone receives a W-2 or a 1099 tells us very little about the care the patient actually received.
Small Practices Cannot Simply Hire Their Way Out of This
Large health systems may be able to employ teams of nurses, medical assistants, care coordinators, pharmacists, and monitoring specialists.
The two-physician practice in a rural community probably cannot.
When a small medical practice partners with a local pharmacy for RPM, it is often not because the physician is trying to avoid responsibility. It is because the pharmacy has the clinical expertise, the patient relationships, and the staffing needed to make the program possible.
If the proposed rule is finalized, many of those practices will not suddenly hire an employee to replace the contracted pharmacist.
They will stop offering the service.
That means the physician loses a useful clinical program.
The pharmacy loses a potential revenue stream.
Most importantly, the patient loses monitoring that may have caught a rising blood pressure, poor adherence, rapid weight gain, or another warning sign before it became an emergency.
The policy could unintentionally make remote monitoring one more service available primarily through large health systems while patients in smaller and rural communities are left behind.
I do not believe that is CMS’s goal.
But it could absolutely be the result.
Your Comment Really Does Matter
I know what some of you are thinking.
“Lisa, is CMS really going to care what one pharmacy owner says?”
Yes.
Not because one angry paragraph automatically changes federal policy, but because agencies are required to review substantive comments and respond to the major concerns raised before issuing a final rule.
This is not an online petition where everyone clicks a button and feels productive for eleven seconds.
The public-comment process is part of federal rulemaking.
CMS specifically opened a 60-day public-comment period for the 2027 Physician Fee Schedule proposal, with comments due by September 14. The final rule is generally expected later in the year before any approved changes take effect in 2027.
A generic form letter may add to the volume, but a specific, thoughtful comment can give CMS something it must genuinely consider.
Tell them:
- How your pharmacy works with local medical practices
- How many patients your team supports
- What conditions you monitor
- What interventions your pharmacists have made
- Why the physician practice cannot realistically employ separate monitoring staff
- What patients in your community would lose if the program ended
One real story is more persuasive than ten paragraphs of generic outrage.
What Should Pharmacy Owners Say?
You do not need to write a legal brief.
You do not need to understand every page of the proposed rule.
And please do not ask AI to produce twelve paragraphs of federal-agency word salad that sounds like it was written by a committee of robots.
Focus on two or three strong points that reflect your actual experience.
Employment Does Not Determine Quality
Explain that a pharmacist’s training, license, accountability, and clinical ability do not change based on employment classification.
Ask CMS to focus on meaningful safeguards such as supervision, documentation, auditing, and measurable patient relationships rather than using employment as a blunt proxy for quality.
Small and Rural Practices Need Contracted Partners
Describe the operational reality.
A small practice may not have enough patients or revenue to employ a full-time monitoring nurse or pharmacist. Contracting with a community pharmacy may be the only financially realistic way to offer RPM or RTM.
If the contract option disappears, the service may disappear with it.
Local Pharmacists Are Not Anonymous Call Centers
Acknowledge the problem CMS is trying to solve, then clearly explain why your model is different.
The community pharmacist may see the patient face-to-face, communicate directly with the physician, maintain local records, understand the patient’s medications, and remain available when questions arise.
Ask CMS to distinguish between high-volume vendors with minimal patient relationships and licensed local clinicians participating in a coordinated care team.
Give CMS a Better Alternative
Do not only say, “We hate this.”
Offer a workable path.
You might ask CMS to:
- Withdraw the employed-only restriction.
- Continue allowing contracted auxiliary personnel under existing supervision requirements, with stronger documentation standards if necessary.
- Create an exception for licensed clinicians who have an established, in-person relationship with the patient.
- Permit contracted clinicians located in the same community or state as the billing practice.
- Develop audit standards that target improper billing rather than eliminating legitimate local partnerships.
CMS is trying to address abuse.
Help them solve that problem without removing community pharmacists from the care team.
Do Not Comment Alone
Your voice matters, but your physician partner’s voice may matter even more.
Remember, the medical practice is the entity billing these codes. A physician who says, “We cannot operate this program without our contracted pharmacist,” can speak directly to the operational impact of the proposal.
Ask comments from:
- Pharmacy owners and pharmacists
- Physician partners
- Practice managers
- Nurses and office staff
- Patients and caregivers
- State pharmacy associations
- Buying groups and other pharmacy organizations
Different people can explain different parts of the problem.
The pharmacist can describe the clinical work.
The physician can explain why the partnership is necessary.
The practice manager can explain why hiring another employee is financially impossible.
The patient can explain what the monitoring meant to their care.
That collection of voices is much harder to ignore than 500 identical copied comments.
How to Submit a Comment
The deadline is September 14, 2026.
Go to Regulations.gov and search for CMS-1848-P, or use docket number CMS-2026-2377 (you can click on this link here to shortcut this). Confirm that you are viewing the proposed 2027 Medicare Physician Fee Schedule before submitting your comment. CMS’s official rule page and the federal docket both list the September 14 deadline.
Your comment should clearly reference:
CMS-1848-P: Proposed requirement that RPM/RTM services be furnished only by clinical staff employed by the billing practice
You can submit your comment directly through the website or attach a letter on your pharmacy’s letterhead.
Keep it professional.
Include specific facts and real examples.
Ask for a clear policy change.
And remember that comments become public. Never include patient names, dates of birth, medical record numbers, or other protected health information. You can describe a situation generally without identifying the patient.
Once you submit it, save your confirmation number.
Then ask your physician partners to do the same.
One Last Thought
Independent pharmacy has spent years fighting to be recognized as more than a place that puts pills in bottles.
RPM and other clinical care programs give pharmacists a chance to use the education, accessibility, and patient relationships we already have to improve outcomes while building sustainable non-PBM revenue.
Now CMS is considering a policy that could cut contracted community pharmacists out of that opportunity.
It is not final.
That is the important part.
We have until September 14 to explain why a licensed pharmacist working with a local physician practice is not the problem CMS needs to eliminate.
Ten minutes may help protect an important revenue stream for your pharmacy.
More importantly, it may protect access to clinical care for patients who will not receive that monitoring anywhere else.
CMS is required to listen.
But first, we have to speak.
Take Action Before September 14
Submit a personalized comment opposing the employed-only restriction for RPM and RTM, then send the information to your physician partners, pharmacy colleagues, state association, and anyone else whose patients could be affected.
Inside Pharmacy Badass University, we are giving members the talking points, templates, and advocacy resources needed to respond quickly without starting from a blank page. Customize your story, submit your comment, and help us show CMS the difference between an anonymous monitoring vendor and the community pharmacist who already knows the patient standing on the other side of the counter. If you’re not a PBU Member, I have an entire playbook that shows you what to do as well. You can access it for FREE at this link HERE.
