Remote patient monitoring for providers: How to ensure compliance


Developing or improving a strategy for remote patient monitoring (sometimes called RPM) in your medical practice can help boost revenue, improve patient outcomes, reduce uncompensated time, and enhance the doctor-patient relationship. However, as you explore the benefits of remote patient monitoring, you also should be aware of a recent Office of Inspector General (OIG) report citing various concerns about whether the services physicians provide meet federal program requirements. 

What is remote patient monitoring for providers?
Providers use remote patient monitoring for established patients in their medical practice who have a chronic or acute condition that requires oversight. Remote patient monitoring occurs when those patients collect health data in their home and transmit it to their provider who, in turn, uses it to manage the patient’s condition. Patients must collect and transmit health data at least 16 days every 30 days.

For example, a patient might collect and transmit data related to their weight, blood pressure, or glucose levels. With remote patient monitoring, the patient’s provider supplies RPM devices approved by CMS (i.e., Internet-connected data collection devices that meet federal requirements) and educates the patient on how to use those devices. As data flows from the device into the electronic health record, the provider reviews that data and uses it to inform treatment decisions.

What’s included in Medicare remote patient monitoring?
The Medicare remote patient monitoring service includes three components: Device supply, education/setup, and treatment management. Although CMS doesn’t require providers to provide and bill for all three components, it only makes sense that they would. However, the OIG report found that 43% of Medicare beneficiaries did not receive all three components of the service, according to claims data. Most commonly, enrollees did not receive education/setup (28%) nor did they receive the device itself (23%). About 12% of enrollees did not receive treatment management.

What does the OIG say about remote patient monitoring for providers?
The OIG also voiced concerns that Medicare lacks key information about remote patient monitoring such as the type of health data being collected, the specific devices that are used, what disease or condition the provider is monitoring, the provider who orders the remote patient monitoring, and the provider who delivers the remote patient monitoring (specifically whether any remote patient monitoring services are delivered ‘incident to’). 

In terms of the specific diseases or conditions monitored, more than 7,000 Medicare enrollees received remote patient monitoring for a vague ‘other specified counseling’ while more than 500 enrollees had a diagnosis of ‘other specified health status’ and about 400 enrollees had a diagnosis of ‘encounter for examination and observation for other specified reasons.

Most Medicare enrollees with specific diagnoses received remote patient monitoring for chronic conditions, most often hypertension. The next most common chronic condition was diabetes followed by sleep-wake disorders. Remote patient monitoring for providers can be very helpful in terms of promoting positive outcomes.

Looking ahead: What to expect
Medicare remote patient monitoring will likely remain on the OIG’s radar in the years ahead as more providers embrace the service. The OIG’s claims analysis revealed that the number of Medicare enrollees who received remote patient monitoring was more than 10 times higher in 2022 than in 2019. In addition, payments for remote patient monitoring in Medicare were more than 20 times higher in 2022 than in 2019. Note that a little more than half of state Medicaid programs also reimburse for remote patient monitoring.

In addition, changes effective January 1, 2026, may usher in greater remote patient monitoring adoption. More specifically, CPT code 98980 (remote patient monitoring treatment management) requires only 11-20 minutes of a provider’s time rather than 20 minutes or more. For shorter-duration remote patient monitoring, there are 6 new codes that cover the first 2 to 15 days (99XX4-99XX5 and 98XX4-98XX7). 

CMS will also likely heed the OIG’s recommendations to implement additional safeguards to ensure that providers follow all remote patient monitoring guidelines, require a physician order for Medicare remote patient monitoring and include that information on claims and encounter data, and develop a method to identify what health data are being monitored. 

Here are three steps you can take now to ensure compliance in your medical practice:

  1. Supply patients in your medical practice with RPM devices approved by CMS that meet federal requirements.

  2. Provide patient education on how to use the remote patient monitoring device. Note that you can leverage clinical and nonclinical staff in your medical practice to deliver the education and device, but only clinical staff can deliver treatment management. Some patient education tips are included in this Medicare remote patient monitoring tip sheet. You can also view this more in-depth resource to better understand the remote patient monitoring device. 

  3. Read up on Medicare remote patient monitoring guidelines for billing compliance. This resource provides information about Medicare billing requirements for remote patient monitoring. Also stay tuned for additional CMS resources designed to educate healthcare providers about billing of remote patient monitoring in accordance with existing payment policies.

Billing for remote patient monitoring can help your medical practice boost revenue in 2025 and beyond. However, compliance is always critical. Learn how edgeMED can help promote compliant medical billing and coding.

edgeMED Healthcare

The authority in revenue cycle management for over 40 years

https://www.edgeMED.com
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