New data shows increase in RPM billing, concerning trends

The Office of Inspector General (OIG) released a report on medical practices’ billing patterns for remote patient monitoring (RPM) services, highlighting the expanding use of these services and a need for additional oversight.

RPM coding and billing across CMS programs has been on the OIG’s radar for several years. The agency conducted this review to provide additional data that supports its findings and recommendations from 2024.

The OIG examined 2024 Medicare fee-for-service and Medicare Advantage claims and encounters with at least one RPM procedure code. Although over 10,000 practices billed for RPM services in 2024, the report focuses on the behavior of 4,639 facilities that “routinely billed” for RPM, meaning that they billed for 10 or more enrollees and over 100 RPM services.

Overall, Medicare payments for RPM services increased by 31% between 2023 and 2024, jumping from $408 million to $536 million, according to the report. Approximately one million enrollees received RPM services in 2024, representing a 27% increase from 2023.

The OIG created several measures to analyze each practice that routinely billed for RPM services, including the number of new enrollees, prior medical relationships, the number of devices, and more. The agency determined that some facilities showed significant, sudden growth in RPM billing rates. For example, one practice billed RPM services for nearly 3,400 new enrollees in a single month. While the growing use of RPM could be attributed to industry shifts and patient/provider preferences, similar billing spikes for other Medicare services have been markers of fraud.

Facilities must have a prior relationship with an enrollee to bill Medicare for RPM services, meaning that the patient must have an in-person or telehealth visit with one of its providers before any billing or monitoring occurs. The OIG determined that 45 practices in their audit sample did not have a prior medical relationship with more than 80% of their RPM patients in 2024.

Practices are generally not allowed to bill Medicare for more than one RPM device per month per enrollee, and the majority of facilities sampled by the OIG complied with this requirement. However, 20 of the sampled practices billed Medicare for at least two devices per month per enrollee over 100 times in 2024. This data could indicate that practices are double billing for the same device or billing items that are not medically necessary.

The OIG encouraged CMS to implement the following recommendations from its previous report:

• Implement additional safeguards to ensure that RPM is used and billed appropriately in Medicare
• Require that RPM be ordered and that information about the ordering provider be included on claims and encounter data
• Develop methods to identify what health data are being monitored
• Conduct provider education about RPM billing
• Identify and monitor companies that bill for RPM services

Revenue integrity professionals at facilities that bill Medicare for RPM services should review the OIG’s latest findings. Examine the five measures in the report, and identify and address any noncompliant RPM billing practices at your organization. RPM billing and coding will continue to be a focus area for the OIG, so facilities should monitor for additional audit work and CMS guidance.