Comment on CMS-2026-2377-0002

Re: CMS-1848-P — Proposed requirement that RPM/RTM services be furnished only by clinical staff employed by the billing practice: I respectfully urge CMS to reconsider any proposal that would prevent or significantly limit contracted pharmacies from participating in Remote Patient Monitoring (RPM) services. Community pharmacies are among the most accessible healthcare providers for Medicare beneficiaries, particularly in rural and underserved areas. Contracted pharmacies play an important role in helping patients understand and use RPM devices, encouraging adherence, identifying potential issues early, and facilitating communication with the patient's healthcare team. Removing pharmacies from this process would reduce patient access to valuable support and could negatively affect health outcomes. Many patients have established relationships with their local pharmacy and are more likely to engage with RPM programs when pharmacists and pharmacy staff are involved. Pharmacies often provide education, troubleshoot equipment issues, reinforce care plans, and help ensure patients remain actively engaged with their monitoring programs. These services improve continuity of care and help providers receive more complete and reliable patient data. Rather than restricting pharmacy participation, CMS should continue to allow qualified contracted pharmacies to collaborate with physicians and other practitioners in delivering RPM services while maintaining appropriate program integrity safeguards. Preserving this collaborative model supports better patient engagement, improves care coordination, and helps achieve the goals of value-based care. I encourage CMS to recognize the important contributions of contracted pharmacies and to maintain their ability to work with patients as part of Remote Patient Monitoring programs.