OIG Calls for More Oversight of Remote Patient Monitoring in Medicare
By Alisa Pierce

The Office of Inspector General (OIG) at the U.S. Department of Health and Human Services (HHS) is calling for increased oversight of remote patient monitoring (RPM) in Medicare after a Sep. 24 report by OIG found compliance and billings errors among RPM usage.

Per OIG, RPM is the collection and transmission of health data – such as blood pressure, weight, or glucose levels – that physicians use to remotely monitor a patient’s health status and condition from their home. RPM can include both remote physiological monitoring and remote therapeutic monitoring.

The agency’s report found that while the number of Medicare patients who received RPM services grew by more than 10 times between 2019 and 2022 – and payments made by Medicare for RPM during that period increased by more than 20 times – approximately 43% of patients who received RPM did not receive all three components of it, raising questions about whether “monitoring is being used as intended,” per OIG. The three components are enrollee education and device setup; device supply; and treatment management.

According to the report:

• OIG found that around 28% of patients who used RPM in 2022 did not receive the required device education and setup, which includes 23% of patients who did not receive the device itself; and
• 12% of patients did not receive treatment management by the physician reviewing the RPM data and using it to manage the patient’s condition. At least 20 minutes of review and management time is required, including interactive, virtual communication with the patient or caregiver each month that RPM is billed.

“These findings demonstrate the need for additional oversight and safeguards to help to ensure that remote patient monitoring is being used and billed appropriately,” HHS-OIG wrote. “In addition, to further inform oversight, OIG has additional work underway examining remote patient monitoring, including a companion evaluation that will identify billing patterns that may indicate fraud, waste, and abuse.”

However, Texas Medical Association staff say that the report’s data does not necessarily mean physicians were not providing those services; rather, it is possible that physicians simply did not bill for them. Currently, the Centers for Medicare & Medicaid Services (CMS) does not require physicians to bill for all three components.

While OIG noted this in the report, it stated in its findings that Medicare lacks key information for oversight, including data on which physicians ordered monitoring for patients, and, in some cases, what diseases or conditions were being monitored.

TMA health information technology and coding staff say physicians using RPM should ensure they are properly utilizing and billing for the service: Physicians who bill Medicare for RPM services must use a set of procedure codes (999453 – 99091) that cover one of three components to RPM. Medicare pays separately for the three components and pays each component at the same rate, regardless of the type of device used or the health data collected.

Per HHS, physicians offering RPM services must have an established relationship with the patient and must be eligible to furnish evaluation and management services. To bill for RPM in Medicare, physicians must:

• Ensure the monitoring is medically reasonable and necessary, such as when a patient has a chronic or acute condition that requires monitoring;
• Confirm the RPM device is internet-connected, meets the Food and Drug Administration’s definition of a medical device that digitally uploads data, and collects and automatically transmit health data at least 16 days every 30 days; and
• Collect patient consent is at the time RPM is furnished.

For questions about billing and coding, visit TMA’s Physician Payment Resource Center. For more information about health care technology, see TMA’s Health Information Technology webpage.