← ProtectRPM.orgThe Solution: full story & framework
ProtectRPM.org · The Solution · Re: CMS-1848-P · Comment record closes September 14, 2026

Eliminate the fraud, waste, and abuse in all remote care.
Do it right the first time. Save twice as much. Disconnect no one.

We agree with CMS's goals, all of them. But the rule regulates two programs and disconnects a million seniors. This plan regulates the whole remote care family (RPM, RTM, CCM, PCM, BHI) with more accountability and roughly double the savings, and not a single senior loses care.

The rule as proposed
Half the savings.
Covers only RPM and RTM (CCM, the family's biggest spend, keeps compounding untouched), and 1,000,000+ monitored seniors are disconnected on January 1.
vs
This plan
≈$15B saved (est.)
All five programs regulated at once, on all five of the OIG's own recommendations, one standard, one gate, one declining cost curve. Nobody loses care.
01 · The problem, and it is real

Fraud, waste, and abuse crept into remote care. CMS is right to act.

The HHS Office of Inspector General documented it in September 2024: cold-calling operators enrolling patients they never treated, 43% of enrollees not receiving all three required service components, and Medicare unable to see who ordered the monitoring or which companies furnished it. Meanwhile spend compounded: $15M (2019) → $536M (2024) for RPM alone, with CCM, PCM, and BHI riding the same curve. Nobody serious disputes any of this. We don't either.

Enrollment fraudDocumented · OIG 2024–25

Cold-call operators signing up patients with no clinical relationship, the OIG found practices with no prior relationship to more than 80% of the patients they billed.

Invisible deliveryDocumented · OIG 2024

Medicare cannot see who ordered monitoring, what data is monitored, or which companies furnish it. Waste hides in the dark.

No barrier to entryThe actual gap

A physician spends a decade earning the right to bill Medicare. Anyone can start a remote care company tomorrow, no registration, no standards, no bond.

Inflationary trajectoryThe budget problem

RPM +31%/yr; CCM bigger still at just ~4% penetration. Left alone, the family compounds toward $7B+ a year by 2031.

02 · What the rule proposes

CMS-1848-P answers with three cuts at once

The staffing ban

From January 1, 2027, Medicare pays only when monitoring is performed by the practice's own employed staff, supervised clinical partnerships are cut off, with no exemption for patients already enrolled.

No grandfathering

A new face-to-face initiating visit is required, and the rule is silent on the million-plus patients already in care, no exemption, no transition.

The payment cuts

Code re-valuations engineered in two steps: the statute caps year-one cuts, so a monitored month falls only ≈$104 → $91 in 2027 — then CMS's own phase-in tables take it to ≈$40–58 in 2028, and a floated consolidation into flat G-codes would land at ≈$35.

03 · Why it can't work

The rule doesn't end the fraud. It ends the care.

Reality 175–80% of monitored patients are served through partners

RPM software and device providers estimate that 75–80% of the market is delivered through third-party monitoring partners, because most practices are incapable of running these programs themselves. On January 1, that is who loses access. Vendors can attest to the share; we'll help CMS assemble that record.

Reality 2CMS itself built the partnership model, on purpose

CMS moved remote monitoring from direct to general supervision precisely because practices could not staff 24/7 monitoring in-house. The partnership model isn't a loophole; it's the delivery architecture CMS's own rulemaking created. One nurse covers ~300 patients (≈$94K median salary, BLS), more patients than most practices have, and round-the-clock coverage no single hire can provide.

Reality 3Even the well-funded and the giant can't build it alone

Pure-play RPM companies that raised tens of millions of dollars have gone out of business, the devices, logistics, software, and 24/7 clinical staffing are that hard to operationalize. And the largest health systems (Providence, LifePoint, Community Health Systems, Sentara, UnityPoint, Mount Sinai) publicly contract specialized partners; the systems that self-build run subscale programs their patients outgrow. Their care teams are centralized anyway, not employed by each billing practitioner, so the W-2 test fails even them.

Reality 4The math ends it even where the ban doesn't — one year later

The deep cut is deferred, not avoided: section 1848(c)(7) of the Act caps year-one reductions at 19%, so 2027 shows a survivable −12% for a typical month — then CMS's own "Fully Implemented" tables complete the phase-in, taking device supply from $41.38 to $9.85 and the month to ≈$40–58 in 2028. At those rates — let alone the ≈$35 flat G-code floated in the rule — no delivery model, employed, partnered, or health-system, can furnish 24/7 clinical monitoring. The payment provisions end the benefit by arithmetic; the staffing ban just gets there first. The rule's own tables cannot say within 45% what a monitored month pays in 2028 — the valuation record is as incomplete as the access record. And a W-2 test never distinguishes a fraudulent operator from a legitimate one, it disqualifies both alike.

04 · What the OIG actually recommended

The Inspector General asked for oversight, not elimination. This framework is the OIG's own playbook, operationalized.

In its September 2024 report, Additional Oversight of Remote Patient Monitoring in Medicare Is Needed, the OIG gave CMS five recommendations. Not one of them says “ban the delivery model.” Every one of them maps to this framework:

OIG 1 of 5Add safeguards so monitoring is used and billed appropriately

1 · “Implement additional safeguards to ensure that remote patient monitoring is used and billed appropriately”

→ The Remote Care Organization standard: registration, required leadership, filed protocols, surety bonds, revocation

OIG 2 of 5Require a physician order, on the claim, in the record

2 · “Require that RPM be ordered and that information about the ordering provider be included on claims”

→ The initiating-visit gate, every patient starts with a physician order, on the claim, in the record

OIG 3 of 5See what health data is actually being monitored

3 · “Develop methods to identify what health data are being monitored”

→ Certified software with audit-grade visibility: every reading, alert, and intervention timestamped and auditable

OIG 4 of 5Educate providers on proper billing

4 · “Conduct provider education about billing of remote patient monitoring”

→ Filed clinical protocols and marketing-conduct standards, with education built into registration

OIG 5 of 5Identify and monitor the companies that bill for RPM

5 · “Identify and monitor companies that bill for remote patient monitoring”

The heart of it: register and credential the companies. The OIG asked CMS to identify and monitor them, the rule skips oversight and goes straight to elimination.

Source: HHS OIG, OEI-02-23-00260 (September 2024)

05 · The solution

Three moves. All from the OIG's playbook. All on machinery CMS already runs.

Medicare has regulated its way out of exactly this problem three times: DMEPOS suppliers, IDTFs, and clinical labs (CLIA). Each time, the fraudulent exited and the legitimate industry kept serving every beneficiary. The same playbook, applied to all of remote care: RPM, RTM, CCM, PCM, BHI. The result: more accountability than the rule, roughly double the savings, and nobody disconnected.

1

Gate the enrollment

A physician-ordered start for every new patient, cold-call fraud becomes structurally impossible, while grandfathering the million-plus already enrolled.

2

Register the companies

CMS credentialing for remote care organizations, like DMEPOS, IDTFs, and CLIA labs. Bad actors exit; visibility becomes total. No registration, no payment.

3

Pay for outcomes

Outcomes reported with every claim, reviewed annually, waste can't hide, and CMS tightens patient eligibility with evidence, like it did for CCM.

The full Remote Care Organization standardEight requirements, registration, leadership, filed protocols, certified software, outcomes with claims, surety bonds, marketing conduct, growth gate
The Remote Care Organization standard: RPM · RTM · CCM · PCM · BHI
CMS registration & screening, billing-linked identifier; no registration, no payment (the CLIA principle)
Required leadership, physician medical director + designated quality manager, attested (the IDTF principle)
Filed clinical protocols, documented division of responsibility between practitioner and partner. Nsight offers its own as the template
Approved software, audit-grade visibility, every reading, alert, and intervention timestamped and auditable
Annual outcomes reporting with claims, each claim attests active care delivery (the ACCESS architecture)
Surety bond + revocation: DMEPOS-style bond; clean removal authority for violators
Marketing conduct standards, enrollment only through a clinical relationship; cold-calling is a revocable offense
Growth gate, initiating visit for new patients (grandfathering existing), with a remote-consent pathway for urgent starts
The unit economics the industry will put on the tableReimbursement → contracted fees → delivery costs → margin & payback, ours and our competitors'
1

Reimbursement

What Medicare actually pays, by code and locality

2

Contracted fees

What providers contract to partners, the real split between the provider's share and the partner's share

3

Delivery costs

Software · security · development · FDA-cleared devices · cellular transmission · clinical labor, per patient, per month

4

Margin & payback

What's left for each party, and payback periods per enrolled patient

The principle: valuations should be set on these numbers, and they must leave a workable margin for both the ordering provider and the specialist organization. A program that isn't economically viable for either party delivers care to no one. There is room for a measured re-valuation; there is no room for $35/month.

The rule vs. this plan, on CMS's own scorecard
Same goals: way more savings, and nobody loses care.
The rule
This plan
Fraud, waste & abuse
Bans a delivery model, fraudulent and legitimate alike
Registers, credentials & audits every company, the OIG's own recommendation
Medicare savings
Limited to RPM/RTM, and CCM keeps compounding
≈$15B over five years across the whole family (est.), about double
Cost curve
Cuts once, then the survivors' spend grows again
Deflationary: declining spend via AI-earned efficiency → ACCESS by year 3–5
The million+ seniors
Disconnected January 1, no exemption
Nobody loses care. Existing patients grandfathered.
06 · What to pass, exactly

The whole ask, in six lines.

Specific enough to draft from. Adopt these six lines and CMS gets the accountability, roughly double the savings, and a program nobody has to lose:

1

Finalize the initiating-visit requirement prospectively. Exempt patients enrolled before the effective date; authorize telehealth or a consent-portal-of-record for initiation when clinically indicated.

2

Withdraw the employment restriction. In its place, require enrollment of Remote Care Organizations under a new standard: CMS registration and screening, a physician medical director and designated quality manager, filed clinical protocols, certified software with audit-grade visibility, a surety bond, and revocation authority.

3

Condition payment on annual outcomes reporting with claims, adopting the ACCESS model's claims-as-attestation architecture for all registered organizations. Use the annual outcomes record to refine patient-selection criteria over time, covering the patients the data proves benefit, exactly as CMS tightened CCM eligibility.

4

Hold current valuations and open a formal cost-data collection. The industry will populate it, reimbursement, contracted fees, provider/partner splits, delivery costs, payback periods, and CMS re-values on the record in CY2028.

5

Decline the flat G-code consolidation. Retain acuity-based increments pending the transition plan, so the sickest patients stay funded.

6

Extend the standard to CCM, PCM, and BHI, and announce the transition workplan: per-minute thresholds retire as AI proves outcome parity under supervision; legacy codes sunset into ACCESS on a 3–5 year schedule.

07 · The innovation path

Deflationary care: AI proves itself against human outcomes, then earns autonomy

CMS wants care programs that get cheaper as they scale, not more expensive. This framework builds that in: inside registered organizations, voice-AI clinical support runs beside human teams, and outcomes-with-claims reporting compares the two cohorts in real time. Supervision winds down only when the evidence says it can, and cost per patient falls as autonomy is earned.

Human supervision winds down as AI proves equivalent outcomes

Share of AI-supported monitoring under direct human supervision, each step down is an outcome gate, not a date

100% 50% 0% Stage 1 · side by side, fully supervised Stage 2 · steps down by evidence Stage 3 · autonomous, audited gate: AI matches human outcomes ✓ gate: sustained parity across cohorts ✓ Years 0–1 Years 3–5

AI-supported cohorts must meet or beat human-cohort benchmarks in the same outcomes-with-claims reporting that governs every registered organization. Where AI doesn't prove it, supervision stays. Autonomy is granted by CMS's own evidence, and revocable.

Why this matters to CMS, and why per-minute codes block itDeflationary economics, audited supervision, and the code architecture that has to retire

Why this matters to CMS

Cost per monitored patient falls as autonomy is earned, that is what turns the glide path downward and makes ACCESS economics work at national scale, with the evidence trail built in.

Why per-minute codes block it

Time-threshold billing pays for human minutes rather than results, structurally preventing the least-cost path to the same outcome. Retire the thresholds; keep the accountability.

Why supervision is safe

The credentialing standard makes the comparison auditable: same platforms, timestamped interventions, parallel cohort reporting. Nothing is taken on faith.

08 · The bigger win

Accountability up. Cost down. About double the savings the rule's own scope could produce.

The rule targets RPM and RTM. But CCM is the family's biggest spend at just ~4% penetration, the next RPM-sized curve, already compounding, and untouched by the rule. Regulate the whole remote care family at once and the trajectory doesn't just flatten, it declines: the first genuinely deflationary care framework in Medicare.

The whole remote care family: current trajectory vs. this framework

$ billions per year, RPM + RTM + CCM + PCM + BHI combined · RPM actual (OIG); other programs industry-estimated, blended growth ≈ +22%/yr · framework = measured re-valuation + initiating-visit growth gate in 2027, then decline via AI-earned efficiency into ACCESS

$0 $2B $4B $6B $8B ACCESS migration $7.3B current trajectory (family, ≈+22%/yr est.) ≈ $15B lower five-year spend about double what regulating RPM and RTM alone could save declining with innovation → ACCESS 2027: measured re-valuation + growth gate 2024 2025E 2026E 2027 2028 2029 2030 2031 current trajectory framework: regulated, declining ACCESS outcomes-based payment

Illustrative projection. 2024 family base ≈ $1.8B: RPM $536M (OIG actual, +31%/yr documented); CCM ≈ $1.0B, RTM ≈ $150M, PCM + BHI ≈ $150M (industry estimates from enrollment × published rates, we will substantiate with claims data in the working session). Blended growth ≈ +22%/yr. Framework: 2027 holds near $2.5B (measured re-valuation + growth gate across the family), declining toward ≈$1.65B by 2031 via AI-earned efficiency and ACCESS migration. All assumptions open to CMS actuaries, we will run this jointly.

Program by program: why the whole family must be coveredCCM is the biggest spend at ~4% penetration, and the rule doesn't touch it

Every program in the family is compounding. CCM is the biggest and the earliest

Estimated 2026 Medicare spend by program, $ billions · the rule regulates only the two smaller curves

CCM only ~4% of eligible beneficiaries enrolled, the steepest runway in the family · NOT covered by the rule ≈$1.4B est. RPM ≈$0.92B · +31%/yr (OIG) RTM ≈$0.25B est. · fastest-growing PCM + BHI ≈$0.21B est. · early innings · NOT covered by the rule

Leaving CCM, PCM, and BHI outside the framework doesn't just shrink the win, it hands the same integrity problems a bigger, faster-growing place to live. One standard, one gate, one glide path, the whole family.

09 · The evidence

Everything, in one place

The Optum actuarial study: $2,467–$3,012 saved per patient per yearIndependent, propensity-matched, monitoring reimbursement excluded from the savings math

The Optum actuarial study

Independent analysis by Optum (UnitedHealth Group), May 2026, propensity-score-matched, difference-in-difference, 12 months of claims, monitoring reimbursement excluded from the savings math. 2,800+ monitored Medicare patients vs. 13,000+ matched controls.

CohortMedical cost savings, per member per yearSample
Hypertension with complications$2,467n = 1,001 vs. 4,864 matched controls
Diabetes$3,012n = 703 vs. 3,438
Chronic kidney disease$2,483n = 1,112 vs. 5,418

Results are directional actuarial findings pending larger samples. Full methodology open to CMS actuaries, that review is part of our ask.

Clinical outcomes from monitored populations−11.5 mmHg systolic · −71.6 mg/dL glucose · −72% critical heart-failure alerts

−11.5 mmHg

average systolic blood-pressure reduction across monitored hypertension patients, up to −29.6 mmHg in Stage 2 hypertension

National monitoring program data, 2026

−71.6 mg/dL

glucose reduction in high-risk diabetes patients (>175 mg/dL cohort) by 12–18 months of monitoring

National monitoring program data, 2026

−72%

reduction in critical weight alerts among monitored heart-failure patients over six months, decompensation caught before the ER

National monitoring program data, 2026

10.9M readings

reviewed by licensed nurses in six months in a single national program, 246,785 critical alerts resolved, 41,000+ per month

Jan–Jun 2026
Peer-reviewed & health-system evidenceFewer hospitalizations, $12M health-system ROI, population-scale BP control

Fewer hospitalizations

Published literature shows reduced heart-failure hospitalizations and lower total cost of care for remotely monitored populations.

$12M health-system ROI

University of Michigan Health reported $12M in avoided hospitalizations across 1,700+ remotely monitored patients.

BP control at population scale

Sustained blood-pressure reductions of this magnitude translate directly into fewer strokes and heart attacks across a monitored population.

The operational reality1 nurse ≈ 300 patients · the largest systems outsource · ~80% third-party delivered

1 nurse ≈ 300 patients

At the ~$94K median RN salary (BLS 2025), more monitored patients than most practices have, and 24/7 alert coverage no single hire can provide.

Even the largest systems outsource

Providence, LifePoint, Community Health Systems, Sentara, UnityPoint, and Mount Sinai all publicly contract specialized monitoring partners, and their care teams are centralized, not employed by each billing practitioner.

~80% third-party delivered

RPM software and device providers estimate roughly 80% of the market runs through third-party partners, because most practices cannot operate these programs themselves. Vendors can attest, we'll help assemble that record.

10 · The offer

Take the meeting, or simply adopt the six lines above

A working session with CMS, before the rule is finalized.

Nsight Health, on behalf of the industry, will bring the Optum actuarial study with its methodology open to CMS actuaries · industry-wide outcomes and utilization data · complete unit economics from our programs and our competitors' · our clinical protocols as a drafting template · and the joint spend model above.

We are asking to help write standards we will then be held to.

Nsight Health · nsightcare.com · Campaign & public evidence: protectrpm.org

Sources: Federal Register 2026-14327; HHS OIG OEI-02-23-00260 (Sept 2024) & 2025 data snapshot; Optum Actuarial Study (May 2026); 42 CFR 410.33 (IDTF); DMEPOS supplier standards (BBA 1997/MIPPA); CLIA (1988); CMS ACCESS Model (2026); BLS OEWS (2025); Mathematica (CCM penetration); public health-system RPM partnership announcements.

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