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The CMS Brief (July 2026): Tracking Rulemaking Seasons, Margin Pressures, and Strategic Shifts
Every month, CMS releases dozens of announcements, policy updates, proposed rules, and operational guidance documents. Some generate headlines. Others quietly signal where healthcare policy, payment reform, and value-based care may be heading next.
The CMS Brief is designed to help accountable care organizations, value-based care participants, healthcare technology companies, provider groups, and industry stakeholders quickly understand the CMS developments most likely to impact the healthcare landscape.
Here's what happened in July.
CMS Proposes Changes to Remote Patient Monitoring
CMS has proposed a change for the 2027 Medicare Physician Fee Schedule that would stop Medicare payments for Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) services when provided by outsourced third-party clinical staff. If finalized, only the billing practitioner or their qualified clinical staff could offer these reimbursable services, representing a meaningful shift for organizations that rely on outsourced monitoring vendors.
Why It Matters: If approved, this could change how RPM and RTM programs are staffed and delivered across the healthcare industry. Healthcare organizations, physician practices, and service providers may need to rethink vendor partnerships, staffing models, and care management workflows to maintain compliance and reimbursement. The proposal further strengthens CMS's priority of integrating remote monitoring into the patient's broader care team, ensuring that treatment management remains closely connected to the clinician responsible for the patient's care.
Navigating the Proposed 2027 RPM Changes: What You Need to Know
We want our partners to know the ThoroughCare team is fully aware, actively analyzing the language, and on top of these possible changes. It’s important to remember this is currently a proposal, not a Final Rule, and we are already building a comprehensive action plan to ensure you remain compliant and positioned for sustainable, outcome-based care.
Stay tuned for strategic guidance and resources to help you submit public comments during the open feedback window.
Read more about the 2027 Proposed Rule
CMS Seeks Industry Input on Reimbursing for AI Use
As part of the CY 2027 Medicare Physician Fee Schedule (MPFS) Proposed Rule, CMS is requesting input on how AI is transforming primary care and how Medicare should approach payment for AI-enabled services. The agency is specifically seeking feedback on the use of AI in care management programs and Annual Wellness Visits (AWVs), including whether existing requirements create barriers to supporting new AI care delivery models. CMS is also exploring whether future reimbursement should be more closely tied to demonstrated clinical outcomes rather than the time and intensity of services alone.
Why It Matters: CMS isn’t creating new AI billing codes yet, but this move shows they’re serious about shaping the future of AI in primary care. For healthcare groups and tech companies, it’s a chance to help decide how AI can best support clinicians and patients and how it’ll fit into Medicare’s payment system. This is an early sign that CMS wants to move the conversation from whether AI should be used in care to how it should be valued and paid for.
CMS Launches Medicare GLP-1 Bridge Program
Following high-profile discussions earlier this spring regarding expanding access to weight-loss and chronic disease therapies, CMS officially launched the "Medicare GLP-1 Bridge" initiative on July 1. The program aims to seamlessly expand access to GLP-1 medications for eligible beneficiaries while balancing federal spending.
Why It Matters: This operational rollout solidifies GLP-1 therapies as a foundational component of modern federal chronic disease management. For risk-bearing entities and value-based care clinicians, this program offers a clearer blueprint for incorporating these high-demand medications into long-term population health and preventative care strategies.
CMS Proposes Sweeping Program Integrity and Enrollment Tightening
In its newly issued Calendar Year (CY) 2027 Home Health Prospective Payment System proposed rule, CMS went beyond routine rate adjustments. The agency introduced sweeping changes to Medicare provider enrollment rules that apply across the board to all Medicare-enrolled providers and suppliers. Key changes include expanding the grounds for enrollment denials or revocations, targeting issues such as shared office spaces with previously revoked providers, identity misuse, and a new requirement to disclose ownership by Private Equity (PE) and Real Estate Investment Trust (REIT) entities.
Why It Matters: CMS continues its initiatives to address program integrity and prevent fraud. Organizations navigating mergers, acquisitions, or co-located clinical setups must adapt to much tighter compliance scrutiny, as administrative oversight is fast becoming a zero-tolerance arena.
CMS Accelerates 340B Recoupment and Proposes Site-Neutral Imaging Rates
The CY 2027 Hospital Outpatient Prospective Payment System (OPPS) proposed rule delivered a major shift for hospital finances. CMS proposed increasing the annual budget-neutrality offset percentage from 0.5% to 3%. This wil aggressively accelerate the recoupment of billions paid out during the 2018–2022 340B drug pricing dispute. Additionally, the rule aims to implement site-neutral payments for "imaging without contrast" services performed at off-campus provider-based departments (PBDs), aligning their reimbursement with standard physician office rates.
Why It Matters: The tripling of the 340B offset, combined with the expansion of site-neutral payment models, puts immediate pressure on hospital outpatient margins. Systems that rely heavily on off-campus imaging and 340B pharmacy revenue will need to recalibrate their financial models and focus even harder on lower-cost care delivery.
CMS Seeks Input on Overhauling Essential Health Benefit (EHB) Requirements
CMS issued a comprehensive Request for Information (RFI) seeking public feedback on potential structural changes to the federal government's definition and implementation of the Affordable Care Act’s Essential Health Benefits (EHBs). The agency is evaluating whether to alter the way states select and define their EHB benchmark plans across 10 core categories.
Why It Matters: While this primarily targets individual and small group commercial plans, changes to the EHB baseline often redefine what is considered "standard" healthcare coverage nationwide. Value-based care organizations should monitor this closely, as shifts in benchmark benefits directly alter downstream technology design, behavioral health integration, and preventative service coverage.
Looking Ahead
As we head into August, the healthcare industry is eagerly anticipating the release of the CY 2027 Medicare Physician Fee Schedule proposed rule. This will set next year's baseline conversion factors and outline operational layers for the upcoming Advanced Specialty Model (ASM).
We will also be tracking the public comment period for this month's major rules, ongoing interoperability deadlines, and evolving federal AI governance frameworks. We'll be back next month with another edition of The CMS Brief.
