Comment on CMS-2026-2377-0002

The Mississippi Rural Health Association appreciates the opportunity to comment on the proposed CY 2027 Medicare Physician Fee Schedule and the proposed clinical staffing requirements for Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM). We respectfully request clarification regarding whether contracted clinical personnel may continue to furnish these services when they function as an integrated extension of the treating practice, with appropriate physician supervision, two-way communication, documentation, escalation of clinical concerns, and continued practitioner responsibility for the patient's care. Third-party clinical staffing is essential for many rural practices because existing workforce shortages and limited reimbursement make employing dedicated remote monitoring personnel operationally and financially impractical. If CMS prohibits these integrated contractual arrangements, we are concerned that many rural providers will not transition to employed monitoring staff but will instead discontinue RPM and RTM services, significantly reducing access for rural Medicare beneficiaries. We urge CMS to preserve legitimate, physician-directed contractual staffing arrangements while using targeted program-integrity safeguards to address inappropriate billing and disconnected vendor models.