Prepared for San Diego Cardiac Center · 2026 Remote Care Strategy Review · Confidential — not for distribution
Cardiovascular Service Line Optimization · Kearny Mesa · Chula Vista · El Cajon

The Program Works.
It Just Never Got Built.

San Diego Cardiac Center has been billing remote physiologic monitoring since before most cardiology groups in the country — seven of nineteen physicians, roughly 241 Medicare patients, $199,018 allowed in CY2024. But the add-on rung is billed by exactly one physician, and transitional care, principal care management, 99091 and remote therapeutic monitoring return zero services across all twenty-three practitioners. This page shows what happens when the same clinical discipline is run as a service line — in the first year five hospitals the group staffs carry mandatory 30-day episode accountability.

$0
24-Month Net Reimbursement
0%
24-Month Practice Margin
0
Hospitalizations Avoided
0
Unique Patients in Active Remote Care at Month 24

Source: the companion CoachCare Value Analysis workbook, MAC locality CA • 01182-72.

The Position of Strength

You Already Proved the Clinical Model. Twice.

Nothing on this page argues that this practice should start doing remote monitoring. Its own Medicare claims show it already does — on the physiologic side and, separately, on the device side. The argument is about the other two thirds of the bench, and about the rungs of the ladder above and below the ones being billed.

★ Verified — CY2024 claims

$199,018 of remote physiologic monitoring, already billed

CPT 99453 · 99454 · 99457 · 99458 across seven of the group's nineteen CMS-listed physicians, on roughly 241 Medicare fee-for-service patients and 3,678 services. That is a working service with device logistics, data review and monthly management time behind it, not a pilot.

★ Verified — CY2024 claims

A second remote programme already runs on the device side

The 932xx family — remote pacemaker and defibrillator interrogation, rhythm monitoring and implantable hemodynamic monitoring — carried $99,770 across 2,721 services in the same year. The organizational muscle for remote data review is in the building already.

✓ Verified — the practice's own site

A heart failure programme since 1998 and a nurse-staffed anticoagulation clinic

The heart failure programme runs with a dedicated heart-failure nurse practitioner; the anticoagulation clinic runs a 15-minute recurring-visit protocol with nurse verification of dosing. Nurse-led, protocol-driven, between-visit chronic care is not a concept this group needs sold to it.

★ Verified — the whitespace

Zero CCM, zero PCM, zero TCM, zero 99091, zero RTM

Every practitioner reassigning to the group — all twenty-three — was queried individually against the full CY2024 Medicare care-management code set. Chronic care management, principal care management, transitional care management, remote physiologic data review and remote therapeutic monitoring returned zero services on every code. Verified absent, not suppressed.

Read as a share of the group's own book, the picture is sharper still: CY2024 traditional-Medicare allowed charges across twenty practitioners were $8,926,576, and the remote-monitoring line inside that is $199,018 — roughly 2.2% of the practice's own Medicare revenue. The programme is not failing. It is stranded — run as a clinical habit by a minority of the physicians rather than as an operationalised service line, and marketed nowhere: a crawl of all 95 pages on the practice's website returns zero mentions of remote monitoring, care management or any monitoring platform.

The right reading of that is a compliment, not a criticism. This group proved the clinical model before most cardiology practices in the country did, and then never built the machine around it. The clinical substrate underneath is unusually deep for a group this size — three of the nineteen CMS-listed physicians are board-certified in advanced heart failure and transplant cardiology, the practice was a site on a pivotal implantable pulmonary-artery-pressure trial, and it remains an active site on a remote-sensor insertable-cardiac-monitor study.

The 2026 Payment Shift

Five Hospitals You Staff Entered Mandatory Episode Accountability on 1 January 2026

The Transforming Episode Accountability Model makes a hospital financially accountable for a 30-day post-discharge episode, readmissions included. This practice holds no CCN and is not a participant. Its admitting hospitals carry the risk. It supplies the cardiology — and it bills no transitional care at all.

Live Since 1 Jan 2026
TEAM · CBSA 41740

Five Mandatory Participants, Not Three

CMS facility-affiliation data resolved across the group's eighteen cardiology NPIs places privileges at five hospitals that are all mandatory TEAM participants: Sharp Grossmont (CCN 050026), Sharp Chula Vista (050222), Sharp Memorial (050100), Sharp Coronado (050234) and Scripps Mercy San Diego (050077) — all in CBSA 41740, all with a performance period running 1 January 2026 to 31 December 2030.

Said plainly: the practice has no CMS Certification Number and is not itself a TEAM participant — participation attaches to a hospital CCN. All fifteen hospitals in the CBSA are mandatory participants, and following the July 2026 transfer of Tri-City Medical Center, Sharp now operates six acute-care hospitals in the county, five of them in TEAM. That makes this a system-level conversation, not a hospital-by-hospital one.

TCM · $0

Transitional Care Billing Is at Verified Zero

99495 and 99496 returned zero services across all twenty-three practitioners in CY2024. The transitional-care family is the direct billing instrument for the 30-day post-discharge window — the exact window five mandatory-TEAM hospitals are now reconciled on — and it is completely unbilled by the cardiology group that follows those patients out.

That is a rare alignment: a hospital-side financial mandate that began seven months ago, a specialist group that touches those discharges and holds the ambulatory relationship afterwards, and an empty post-discharge code set at that group. The practice is currently on the wrong side of it by default rather than by decision.

Billing Tailwind
CY2026

Short-Window RPM Is Now Billable

New codes 99445 (2–15 days of device data, where 16 or more were previously required) and 99470 (first 10 minutes of monthly management, where the floor had been 20) make short post-discharge and post-procedure windows cleanly billable for the first time. That is precisely the window TEAM reconciles on.

The market fact most people get wrong here
  • Delegated, not capitated San Diego is routinely described as a heavily capitated market. It is more accurate to call it a heavily delegated one — physician organizations holding professional risk under health-plan delegation — and the distinction matters commercially.
  • 53.6% Medicare Advantage penetration in San Diego County, against 51.5% for California and 51.2% nationally — only about two points above both, and tenth of the twenty-six California counties with more than 50,000 Medicare beneficiaries (CMS Medicare Monthly Enrollment, April 2026).
  • 289,032 traditional fee-for-service Medicare beneficiaries in the county. Transitional care, remote monitoring and principal care management are fee-for-service benefits, and that is the pool they are billed against. The opportunity should be sized off this number.
  • Flat, not climbing County MA share has sat at roughly 53% for four years while the national rate climbed toward it. Total Medicare beneficiaries grew about 7% from 2023 to 2026 — volume growth, not mix shift, is the expansion driver here, and the fee-for-service pool is not shrinking.
One honest caveat on the payer side. Medicare Advantage is a little over half the county's Medicare population, and for members managed under delegated arrangements the remote-care codes do not generate separate fee-for-service revenue — the value there is medical-expense avoidance and quality-rating support, and the network's own nurse case managers already serve members whose primary care physician sits inside it. That volume is real clinical upside and it is deliberately excluded from every financial figure on this page. The forecast below is built exclusively on the traditional fee-for-service panel, which is where the practice's existing $199,018 already comes from.
Heart Failure
Post-Discharge Transitions
Hypertension
Post-Procedure Recovery
The Operating Model

One Service Line, Three Sequenced Layers

A named service line with its own owner, P&L and scorecard, following the Medicare patient from the hospital bed back into the practice and then across the year. Built once, reused for every lever the group already cares about.

1 · At Discharge — TCM
  • What Structured 30-day post-discharge management: interactive contact within two business days, medication reconciliation, and a face-to-face visit inside the window.
  • Why here Zero transitional care management across all twenty-three practitioners in CY2024, against five hospitals that entered mandatory 30-day episode accountability on 1 January 2026. This is the largest untouched funnel in the practice.
  • Leverage This is the layer that moves the admitting hospitals' 30-day episode performance — the thing TEAM reconciles on.
3 · Across the Year — RPM + PCM
  • RPM Device-based physiologic monitoring — weight, blood pressure, pulse — as the continuous early-warning and titration layer, extended from seven physicians to the whole bench.
  • PCM Principal Care Management for a single high-risk cardiac condition. It is written for a specialist managing one complex condition, and it does not require the practice to be the patient's primary care physician — which this practice is not. It is the highest-fit unbilled family in the file.
  • Modelled The value analysis below models RPM and PCM only. Transitional care management revenue is deliberately excluded from the forecast and sits as upside on top.
The staffing answer, up front. CoachCare operates the engine — enrolment outreach, device logistics, 24/7 monitoring, escalation, and billing-ready documentation — while the practice's physicians govern the protocols and make every clinical decision. Launch requires no new practice headcount. The forecast also assumes one on-site enrolment specialist funded by CoachCare: that specialist is CoachCare's expense and embedded value, and is never a deduction from practice margin.

The CY2026 Billing Stack

ServiceCodes~CY2026 MagnitudeCardiovascular UseIn the model?
Transitional Care Management99495 · 99496~$200 / ~$280Every discharge from the five mandatory-TEAM hospitals the group staffs — at zero services todayNo — upside
RPM setup & device supply99453 · 99454 · 99445 (new)~$20 setup · ~$52/mo99445 opens the 2–15-day post-discharge window; 99453 captured on 41 patients against 241 on device supplyYes
RPM treatment management99457 · 99458 · 99470 (new)~$52 + ~$41 add'lMonthly review, titration, escalation. 99458 is billed by exactly one physician today — the clearest single capture gap in the fileYes
Principal Care Management99424 · 99425 · 99426 · 99427~$79 / ~$57 · ~$60 + ~$50 add'lSingle high-risk cardiac condition managed by a specialist; clinical-staff codes are the workhorse of a full-service care teamYes

Magnitudes in this table are national non-facility figures. The value analysis below uses CY2026 rates auto-resolved by MAC carrier and locality for zip 92123 — CA • 01182-72 — not these national figures.

One Build, Every Lever

The same infrastructure — enrolment, devices, alert triage, escalation, documentation, billing capture — powers each thing the group already cares about.

The stranded programme
Twelve of nineteen CMS-listed physicians billed no remote monitoring at all in CY2024, several of them carrying four-figure Medicare beneficiary counts. The clinical argument has already been won inside this practice; what is missing is a referral pathway that makes enrollment one order rather than a personal workflow. The same engine harvests the rungs already in front of the group — 99458 on 26 patients against 244 receiving the first-20-minute code, and setup on 41 against 241 on device supply. Neither gap is clinical. Both are documentation-and-capture problems.
Episode leverage with five hospitals
The practice becomes the instrument by which its admitting hospitals defend TEAM episode performance. That reframes the conversation from "a revenue add for a cardiology group" to "the group's leverage in its hospital relationships" — and this group can hold that conversation with more standing than most. It fields eighteen cardiology clinicians in the county against eleven at the system's own employed multispecialty group. It is the larger cardiology capability inside that orbit, and it is not a supplicant in the relationship.
Procedural throughput
Remote post-procedure surveillance supports faster, safer discharge after transcatheter valve work, left-atrial-appendage occlusion, ablation and device implant — all of which this group performs inside hospitals it does not own. Faster recovery pathways free hospital capacity and protect case throughput, which is a shared interest with the same systems carrying the episode risk.
Capacity the practice does not have to hire
The service line absorbs the between-visit work — monitoring, outreach, documentation — as delivered hours rather than clinic slots. The forecast below models 48,901 care-team hours over 24 months, about 23.5 full-time equivalents. Against a bench that has published no care-coordinator, chronic-care-manager or remote-monitoring-nurse posting, that is the difference between a decision to scale and a decision to recruit.
Protocol discipline already in the building
A practice running multiple active clinical trials already has consented-patient workflows, device-data handling, protocol adherence and a research-coordinator function. That is most of the operational muscle a scaled remote-care programme needs — and today it is pointed at sponsors rather than at the practice's own Part B revenue.
Technology & Workflow · Scoped Honestly

Building Inside a Hosted Epic — And Why That Changes the Pitch

Most remote care proposals open with an integration promise. This one does not, because the integration seam here is not the practice's to sell into. Here is exactly what is verified about the platform, what follows from it, and what the service line runs on in the meantime.

What is actually established
  • Verified The electronic record is Epic — and it is the health system's Epic instance, on the system's own tenant path, not a platform the practice owns or licenses.
  • Verified The only patient-portal link anywhere on the practice's website is the system's portal. There is no practice-branded portal and no independent tenant.
  • Verified The practice's organizational NPI registers no Direct address and no FHIR endpoints at all in NPPES. Even patient bill pay routes to a third-party service rather than to a practice-owned portal.
  • Inferred Confirm in contracting The most likely contractual vehicle is a community-connect style arrangement, by which a system extends its licensed instance to affiliated independent practices — but the specific vehicle is not publicly documented and must be confirmed.
PHASE 1 · NO SYSTEM DEPENDENCY Launch the service line Enrollment, consent, devices, 24/7 triage, documentation, automated claim generation. Decision: the practice's alone PHASE 1B · THE DISCHARGE SIGNAL Who was discharged yesterday? A daily identification process across the five hospitals. Practice-side, better with help. Decision: the practice, with hospital interest behind it PHASE 2 · SCOPED INTEGRATION Inside the system's Epic tenant Decision: joint — confirmed in contracting THE PRACTICE CONTROLS Its Medicare enrollment and TIN Its physicians' orders Its protocols and supervision The claims it submits SAME DESTINATION Billable service Documented escalation Claims-ready records No integration decision required
Why automated claim generation matters here specifically. This account provides its own evidence for it. Setup was billed on 41 patients against 241 on device supply, and the add-on rung on 26 against 244 receiving the first-20-minute code. Those are the predictable output of a workflow where the documentation and the claim are assembled by people who also have a clinic to run. At a modeled census of 4,939 active programme enrollments at month 24 across three offices, hospital-campus sites and 26 referring providers, the monthly billing task is thousands of per-patient, per-code, time-documented claims — 109,461 billed units over 24 months. A lean administrative layer cannot assemble that by hand, and the failure mode is not a rejected claim; it is a programme that quietly bills less than it delivers.

The value analysis on this page does not assume any particular integration depth. No interface cost, timeline or capability is priced into the forecast, and none is claimed here.

The Clinical Twin of the Value Analysis

Clinical Governance & Escalation

The economics prove the service line pays. This proves it is safe and disciplined. Every reading a patient takes routes through one shared escalation engine with defined thresholds, defined trends, defined routing and a defined documentation standard — so the practice receives signal, not noise, and never carries surveillance liability it did not agree to.

One shared escalation engine

Both programmes in this service line — remote physiologic monitoring and principal care management — route through the same logic. The engine is programme-agnostic; the thresholds are set with the practice.

1

Critical value → escalate immediately

A reading at a critical threshold escalates regardless of whether the patient reports symptoms. There is no "wait and see" branch on a critical value, and no client preference can suppress it.

2

Out of range → retake, then symptom check

A non-critical out-of-range reading is worked rather than forwarded: confirm technique, retake, then run a structured symptom check. Most out-of-range readings resolve here — which is exactly why the practice's inbox stays clean.

3

Trend is defined objectively

An out-of-range trend is not a judgement call. It is three consecutive readings at least one hour apart for blood pressure or glucose, or three readings within seven days for heart rate. A confirmed trend escalates on the same footing as a threshold breach.

4

Unreachable is not a dead end

If the patient cannot be reached, the attempt is documented, a voicemail and callback request are left — and if the reading was critical or a confirmed trend, the escalation proceeds anyway. Silence never downgrades a clinical finding.

5

Every escalation is documented the same way

Six fields, every time, so the record is auditable and the practice can reconstruct any event.

VitalFindingsMethodContactOutcomeFollow-up
The emergent pathway — non-negotiable
  • Triggers Chest pain · new shortness of breath · signs of stroke · syncope · worst-ever headache · sudden swelling. Any of these reported during an outreach call activates the emergent protocol immediately.
  • Action 911 is called with the patient still on the line — the call is not ended and handed off.
  • If refused If the patient declines emergency services, they are routed to the clinic and the refusal is documented; if the situation warrants it, CoachCare activates 911 regardless.
  • The guarantee CoachCare's urgent and emergent policy supersedes any client-specific escalation preference. A practice can shape routing for everything else. It cannot lower the floor on an emergency.

The post-discharge three-touch cadence

Triggered automatically by any emergency-room visit or hospitalisation reported in the last 60 days. This is the readmission-prevention spine — and the mechanism behind the 301 hospitalizations avoided in the forecast below. It matters here specifically: five hospitals the group staffs now carry 30-day post-discharge episode accountability, and the cadence lands entirely inside that window.

Touch 1 · Day 1–2

Stabilise

Confirm the patient is home and safe, reconcile discharge medications against what is actually in the house, verify follow-up appointments exist, and confirm the monitoring device is set up and transmitting. Clinical alerts documented and escalated per the engine above.

Touch 2 · Day 5–8

Detect

The window where post-discharge decompensation typically declares itself. Symptom review, weight and blood-pressure trend review against the readings already flowing in, adherence check, and escalation on any confirmed threshold or trend.

Touch 3 · Day 12–14

Secure

Confirm the follow-up visit happened, close open issues, verify the patient understands the escalation path, and hand the patient into the longitudinal monitoring panel so the 30-day window closes with continuity rather than a cliff.

Continuity and discharge governance

Patients do not silently fall out of the programme, and the practice is notified at every decision point.

A

Unreachable → escalate on a fixed cadence

A patient who stops responding is escalated to the practice first, then re-escalated every 30 days — not quietly dropped and not left accruing.

B

A hard backstop

If no instruction is received from the practice, discharge proceeds at 180 days. The practice is notified in every case, and discharges generally process in the first week of the following month.

C

The practice always decides

Clinical discharge criteria, escalation thresholds and routing are the practice's to set. CoachCare executes them consistently and documents the execution — it does not overrule clinical judgement, with the single exception of the emergent floor above.

D

Auditable by design

Because every escalation carries the same six documented fields, any episode can be reconstructed end-to-end — which is what a shared-accountability conversation with a hospital partner, or a CMS model reviewer, actually requires.

One coordination rule to settle before the first enrollment. Only one practitioner may bill remote physiologic monitoring for a given patient in any 30-day period, and the physician association this practice belongs to already supplies nurse case management to members whose primary care physician sits inside it. Settle in writing which patients are the practice's to manage and which are not — before a denial or a duplicated call settles it instead.
What this section deliberately does not do. It does not price anything, quote a code, or claim a clinical outcome. Escalation thresholds, the routing matrix and the discharge criteria are configured with the practice's physicians during protocol design — the logic above is the standard operating floor, not a substitute for that design session.
CoachCare Value Analysis · Modeled for San Diego Cardiac Center

The Value Analysis

A 24-month forecast for a two-programme service line — remote physiologic monitoring and principal care management — across the group's offices, 26 referring providers, one CoachCare-funded on-site enrolment specialist, and CY2026 rates auto-resolved for MAC locality CA • 01182-72. It models $6,608,698 of net reimbursement and $2,811,277 net to the practice over 24 months — a 42.54% practice margin (net to the practice ÷ net reimbursement), 42.18% in Year 1 and 42.66% in Year 2. Transitional care management revenue, TEAM episode performance, avoided-admission savings, procedural throughput and all Medicare Advantage and commercial volume are not in these numbers. They are upside on top.

Enrolled Services Under Active Management

Monthly active enrolment by programme · physician referrals (8 per provider per month across 26 providers at 80% acceptance) plus one on-site enrolment specialist at 80 per month and a small telephonic stream, net of a 1.5% monthly discharge rate. Both arms are pace-limited: RPM reaches 3,646 against an enrolment ceiling of 3,895 and PCM 1,293 against 3,783 — neither is constrained by the size of the eligible pool, so month 24 is not the programme's terminal size.

Monthly Economics — Net Reimbursement, Fees, Practice Margin

Net reimbursement after a 6% realization discount for payer mix and collection, against CoachCare fees. Month 1 runs a $2,419 deficit because one-time implementation lands there; the programme turns margin-positive in month 2 and never looks back, reaching $530,844 of monthly net reimbursement and $226,477 of monthly practice margin by month 24.

24-Month Net Reimbursement Mix

$6.61M total across the two-programme stack. RPM is the engine; PCM is the longitudinal chronic layer that stacks with it in the same month on discrete documentation. Both are still climbing at month 24.

The Financial Summary

LineYear 1Year 224-Month
RPM net reimbursement$1,237,379$3,778,465$5,015,843
PCM net reimbursement$385,565$1,207,290$1,592,855
Total net reimbursement$1,622,944$4,985,754$6,608,698
CoachCare fees$938,377$2,859,045$3,797,421
Practice net (after fees)$684,567$2,126,710$2,811,277
Practice margin42.18%42.66%42.54%
Practice margin is net to the practice ÷ net reimbursement. Includes one on-site enrolment specialist staffed at CoachCare's expense — embedded value already reflected in the fees above, never a deduction from practice margin.

Month-1 practice profit is −$2,419; the first profitable month is month 2. Unit economics are modeled at approximately $111.25 of net reimbursement per RPM patient-month and $99.69 per PCM patient-month, across 45,086 RPM and 15,978 PCM patient-months. The full model is available as a companion workbook.

109,461

Billed Claims / Units

Recurring, subscription-like professional-fee volume over 24 months — on top of the existing procedural, imaging and device book, not instead of it.

473,399

Physiologic Readings

A continuous clinical picture of the heart failure, hypertension and post-procedure panels between visits — the physiologic twin of the device data the group already reviews.

~301

Hospitalizations Avoided

Roughly $4.5M of avoided acute cost at $15,000 per admission — and direct 30-day episode relief for the five mandatory-TEAM hospitals the group staffs.

23.5

FTE-Equivalent Absorbed

48,901 care-team hours of monitoring, outreach, escalation and documentation carried by the service line rather than by practice staff.

Test the Assumptions Yourself

Scenario Explorer

Every input below is an assumption, and every assumption is arguable. Move them and the 24-month forecast recomputes live. At the modeled settings this engine reproduces the companion Value Analysis workbook exactly — so any disagreement you have with the output is really a disagreement with an input, which is a much more productive conversation.

Build Your Own Forecast

Defaults are the modeled scenario. Enrolment ceilings are recomputed as panel × eligibility × conversion; RPM eligibility is 75% of the in-scope panel and PCM 85%.
24-mo net reimbursement
$6.61M
24-mo practice margin
$2.81M
Margin %
42.5%
Enrolled services at M24
4,939
Hospitalizations avoided
~301

"Enrolled services" counts active programme enrolments; a patient enrolled in both programmes counts twice. At month 24 the model's 4,939 enrolled services correspond to 4,034 unique patients once dual enrolment is deduplicated.

Implementation

Chartered in 30 Days.
Piloting by Day 90.

CoachCare operates the engine — enrolment outreach, device logistics, 24/7 monitoring, escalation and billing-ready documentation — while the group's physicians govern the protocols and make every clinical decision. Full-service delivery means launch requires no new practice headcount, and the on-site enrolment specialist in the model is funded by CoachCare.

0–30 Days

Charter the Service Line and Give It the Owner It Never Had

Name a physician lead and pair them with the administrative lead. Put the existing enrolled remote-monitoring patients under one protocol before adding a single new one. Confirm the billing configuration for MAC locality CA • 01182-72, agree the escalation matrix and discharge criteria, and settle the attribution rule in writing.

31–90 Days

Pilot Two Anchor Cohorts

First, the heart failure panel — the highest-yield population and the one this group's bench is built for. Second, post-discharge patients from the five mandatory-TEAM hospitals, on the three-touch cadence with short-window RPM placed at discharge. Stand up the daily discharge signal alongside them; it is the item most worth the hospitals' cooperation.

91–180 Days

Extend From Seven Physicians to the Bench

Referral pathway made a single order rather than a personal workflow, across Kearny Mesa, Chula Vista, El Cajon and the hospital-campus sites. Longitudinal RPM and PCM panels running under protocol; the add-on rung and setup code captured by the billing engine rather than by hand. Monthly scorecard — census, capture rate, revenue per patient-month, escalation volume, readmission signal — reporting to practice governance.

181–365 Days

Enter 2027 With Results, Not Plans

A documented 30-day post-discharge track record to take into the hospital conversation — which is where the episode-risk discussion becomes a negotiation rather than a request — and a full year of capture data on a service line whose first-year census is still climbing.

About CoachCare

The Experience to Get It Right

The service line described on this page runs on infrastructure already proven at national scale.

500,000+

Patients Managed

Over 400 managed conditions for more than 500,000 patients.

10,000+

Clinicians on the Platform

Providers running remote care programmes day to day.

1,000+

Implementations

Successful programme implementations.

5M+

Claims Generated

Care plan coding and billing generating over five million claims.

100M+

Vitals Recorded

Over 100 million vitals recorded and more than four million care actions enabled.

Policy Watch · CMS-1848-P

2027 Proposed Rule Insights

CMS's CY2027 Physician Fee Schedule proposed rule, published July 16, 2026, proposes to reprice remote physiologic monitoring. Here is what it reaches, what it leaves alone, and how the operating model behind this service line absorbs it.

1

The Proposal Is Confined to RPM

CMS's remote-monitoring proposals sit in one code family: RPM. CCM, PCM, and TCM are not part of them. That distinction lands directly on this forecast — PCM carries $1,592,855 of the modeled $6,608,698 in 24-month net reimbursement, and the TCM touch at discharge is outside the proposal entirely. Neither is in scope.

2

CoachCare Is Building the Contingencies Now

The delivery model has more than one shape, and CoachCare is preparing each so the service line's economics hold wherever the rule settles. One unbundles the program into its parts — SaaS platform, device logistics, and program enablement — priced as components. Another engages CoachCare to run the staffing itself, an MSO-style arrangement in which the practice owns the clinical program and the billing while CoachCare carries the labor model. Neither requires re-architecting the service line described on this page.

3

ACCESS Moves Remote Care to Risk-Based PMPM

Alongside the fee schedule, CMS's ACCESS Model pays remote care as a risk-based per-member-per-month arrangement rather than per code: recurring per-beneficiary payments, half of each one withheld and reconciled against outcome attainment. Cardiometabolic care is among its four clinical tracks. What earns under that structure — controlled pressures, titrated therapy, decompensations caught early — is what this service line is built to produce.

What the Proposal Actually Takes Off This Forecast

This forecast repriced code by code at CMS's CY2027 proposed values, at this practice's own MAC locality rather than national averages. Same enrollment, same phasing plan — only the rates move.

−20.7%
The headline per-code cut — device supply (99454 / 99445), the code the proposal reprices hardest.
−9.5%
The RPM patient-year, because device supply is only 33% of it — the management codes barely move.
−7.2%
The whole service line, because PCM carries 24.1% of the forecast and is not in scope.
RPM alone — the only code family in scope$5,015,843 over 24 months
−$474,876
−9.5% of RPM
The whole service line — RPM + PCM$6,608,698 over 24 months
−$475,636
−7.2% of the whole

Both bars run on the same dollar scale, so the red slice is nearly the same width in each — the same dollars, measured against a larger base. The empty track on the top bar is the care-management revenue RPM alone does not include.

RPM, retained at CY2027 proposed rates The proposed reduction PCM — not in scope

Repriced at this locality's own geographic adjusters. The RPM reductions fall almost entirely on practice expense, so the untouched work component carries more weight in some localities than others; the same repricing at national rates would be −8.8% on RPM. Of the $475,636, RPM accounts for $474,876 and the care-management arm for $760.

Where the Proposal Lands, Code Family by Code Family

CY2026 versus CMS's published CY2027 proposed values, shown at national non-facility amounts so they can be read against CMS's own tables. This practice's locality-adjusted amounts differ; the repricing above uses the local figures.

Code familyWhat CMS proposedCY2026CY2027 proposedChange
In scope — remote physiologic monitoring
99454 / 99445 · device supplyPractice expense recrosswalked$52.11$41.38−21%
99457 · management, first 20 minDirect practice expense removed$51.77$49.59−4%
99458 · management, each addl 20 minDirect practice expense removed$41.42$40.39−2%
99453 · setup and patient educationCrosswalked; one-time per patient$21.71$20.03−8%
Not in scope — the codes the proposal does not reach
99424–99427 · PCMNo structural change proposed$67.80$67.00−1%
99495 / 99496 · TCMNot addressed by the proposalOutside the remote-monitoring provisions entirely

National non-facility amounts; CY2027 values are CMS's own published proposals in Addendum B of CMS-1848-P. The care-management rows show the lead code in each family; every code in those families moves within about 4% in either direction, which is ordinary annual movement rather than a repricing. The RPM reductions are also phased — section 1848(c)(7) of the Act caps any one code's total-RVU reduction at 19% in a single year, and CMS publishes the affected codes, so CY2027 is a single-digit year for a typical program and the remainder arrives no earlier than CY2028.

None of this is final. CMS-1848-P is a proposed rule. Comments are due September 14, 2026, the final rule is expected in early November, and it takes effect January 1, 2027. CoachCare is leading the advocacy — filing comments, putting the device cost and pricing evidence in front of CMS that the rule itself states the agency does not have, and helping practices file their own. This practice gets the final rates, and the model rerun against them, the week they publish.