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Medicare RPM Growth, Risks, and the Path to Compliance

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Remote Patient Monitoring (RPM) is no longer a niche pilot project—it has become a mainstream part of patient care. The Office of Inspector General’s (OIG) August 2025 data snapshot confirms what many providers already see every day: adoption is accelerating, and so is regulatory scrutiny. Medicare spending on RPM topped $500 million in 2024, a 30% jump from the prior year, with nearly one million beneficiaries now actively enrolled. What was once described as the “future of care” is now today’s standard practice and success will hinge on billing accuracy and compliance.

 

What Billing Red Flags is OIG Watching?

The OIG flagged several billing behaviors that could trigger audits or penalties:

  • Enrollment surges that outpace capacity: When patient sign-ups grow faster than a practice’s ability to provide monthly reviews, it raises regular concerns about “phantom” care.
  • Missing provider-patient relationships: CMS requires documentation showing that an established relationship exists before RPM is billed.
  • Incomplete treatment management time: Providers must log at least 20 minutes of monthly patient review and interaction to justify billing.
  • Multiple providers billing the same patient: CMS allows only one provider to bill per patient per month, regardless of conditions monitored.
  • Duplicate device charges: CPT 99454 covers the supply of device(s), so it can be billed once per month, whether a patient uses one or multiple devices.

 

The Challenge of Overlaps

Duplicate RPM billing is often unintentional. For example, a patient may not mention they’re already in a monitoring program, or two specialists might independently prescribe different types of monitoring (e.g., glucose and blood pressure).

Since CMS rules limit RPM billing to “per patient, per month”, providers face a visibility gap. There is currently no universal system to see if another practice has already billed for that patient.

Potential solutions could include:

  • Payer alerts for duplicate billing attempts
  • Better data sharing via health information exchanges
  • EHR flags showing existing RPM enrollments

Until then, careful intake processes and thorough patient disclosure remain the first line of defense.

 

Clarifying Device Billing

 

OIG also noted confusion around device claims. The rules are straightforward:

  • CPT 99454 covers all devices supplied to a patient each month.
  • A patient using both a blood pressure cuff and a scale still falls under a single 99454 claim.
  • Billing multiple 99454 codes for the same patient in the same month is a compliance red flag.

 

Staying Compliant in 2025 and Beyond

To stay ahead, RPM stakeholders should focus on:

  • Internal audits: Regularly review claims for enrollment spikes, duplicate billing, or missing documentation.
  • Documentation discipline: Ensure patient relationships and treatment time are clearly recorded.
  • Patient intake updates: Ask patients directly about other RPM enrollments.
  • Billing consistency: Apply CPT 99454 once per patient, per month.

 

The Bottom Line

The OIG’s 2025 report sends a dual message:

  1. RPM is now a validated, mainstream tool for patient care.
  2. Oversight is tightening, and compliance cannot be an afterthought.

 

Providers, payers, and digital health companies that want to thrive in this space must balance opportunity with accountability. Accurate billing, clear documentation, and proactive audits are not just about avoiding penalties. They build trust in RPM as a reliable, scalable model of care.

Now is the time to revisit your RPM workflows, validate your billing practices, and make sure your program is ready for growth and for audits.

 

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