Health Law Daily Wrap Up, BILLING AND CODING—OIG REPORTS: growth in remote patient monitoring which can lead to improvements in patient care, billing efficiencies, (Sep 9, 2025)

By Donielle Tigay Stutland, J.D.

OIG continues to highlight RPM's significant growth and the need for enhanced oversight to prevent fraud, waste, and abuse.

The HHS Office of Inspector General (OIG) released a Data Snapshot titled, “Billing for Remote Patient Monitoring in Medicare” offering insight into how the use of remote patient monitoring (RPM) can offer benefits to Medicare enrollees while saving program costs. The data snapshot follows up a prior OIG report from September 2024 that highlighted RPM's potential for significant growth and the need for enhanced oversight to prevent fraud, waste, and abuse. The report shows continued growth, and noted that in 2024, payments— including both Original Medicare and Medicare Advantage—for remote patient monitoring exceeded $500 million (OIG Report, OEI-02-23-00261 (Aug. 28, 2025)).

RPM Growth. The data snapshot highlighted that nearly one million Medicare enrollees received RPM in 2024. Further, the use of RPM continued to grow in 2024, with Medicare payments exceeding $536 million. This includes Original Medicare (also known as Medicare fee-for-service) and Medicare Advantage. This also represents a 31-percent increase from 2023 and continues an upward trend that has occurred in every year since Medicare began covering the services more widely in 2019. Additionally, the number of Medicare enrollees who received RPM also grew. The nearly 1 million enrollees received RPM in 2024 accounted for a 27-percent increase from 2023.

OIG reported that around 4,600 medical practices routinely billed for RPM in 2024. Typically, these medical practices each billed remote patient monitoring for about 70 enrollees during the year and added about 5 new enrollees each month. OIG highlighted that some medical practices experienced significant growth. For example, 32 medical practices had a large increase in the number of new enrollees for whom they billed RPM. One medical practice billed remote patient monitoring for nearly 3,400 new enrollees in a single month. OIG cautioned that this could be a signal for further fraud scrutiny. Noted the report, “While significant increases in billing may represent legitimate growth in a practice’s uptake of remote patient monitoring, these types of spikes in billing have been a marker of fraud in other Medicare services.”

Measures to Monitor. OIG has developed several measures to monitor billing for RPM, including billing for a high proportion of enrollees who have no prior history with the medical practice; and billing for multiple monitoring devices a month for an enrollee. CMS requires that medical practices have a prior relationship with an enrollee to bill for RPM. While it was reported that most medical practices had prior relationships with nearly all of their patients, 45 medical practices— including practices that bill Original Medicare and Medicare Advantage Organizations—did not have a prior medical relationship with more than 80 percent of the patients for whom they billed RPM in 2024. This was noted as a flag to identify medical practices with billing for RPM that warrant further scrutiny.

The report also highlighted that treatment management is an essential component of RPM and for 52 medical practices, more than 75 percent of their enrollees never had treatment management billed to Medicare during the year. OIG pointed out that a medical practice that has a high percentage of enrollees who never received treatment management in any month warrants further scrutiny to ensure that remote patient monitoring is being effectively used to treat the enrollee’s condition.

Another concern to be monitored is when medical practices billed for RPM for the same enrollee as other practices. Most practices, nearly 90 percent, never billed for the same enrollees as two or more other practices. However, the research showed 34 practices frequently billed for the same enrollees as two or more other practices. These practices billed this way for more than 25 percent of their enrollees. OIG noted that this raises concern that they may be billing for monitoring that is not necessary or not provided; such billing warrants further scrutiny.

Finally, OIG addressed the concern related to about 20 practices which frequently billed Medicare for 2 or more devices per month per enrollee. Each of these practices billed for multiple devices for enrollees more than 100 times in a year. One medical practice billed this way about 1,700 times during the year. While most medical practices never billed for more than one device per month per enrollee, if there is frequent billing for multiple devices per enrollee, it may indicate that practices are double billing for the same device, or billing for devices that are not provided or not medically necessary. OIG suggested such patterns signal a need for further scrutiny.

Recommendations. This report stressed that OIG reiterates the importance of CMS implementing the recommendations made in the September 2024 report about RPM to strengthen its oversight of these services.

OIG previously recommended that CMS implement additional safeguards to ensure that remote patient monitoring is used and billed appropriately in Medicare. Using measures to monitor billing for RPM can help safeguard program integrity and prevent fraud, waste, and abuse.

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