Remote Patient Monitoring services are a great way to improve care outcomes for patients with chronic or acute conditions. Especially during the COVID-19 pandemic, RPM helped keep practices connected to patients and help identify problems early. And with more Medicare scrutiny, it’s imperative to ensure Remote Patient Monitoring compliance.

Despite the promising health outcomes, practices have been slow to start RPM programs. Some reasons might include the initial device cost and confusion around reimbursement requirements. And in 2021, the Office of Inspector General announced a focused audit of Telehealth services including Remote Patient Monitoring to determine whether practices were meeting Medicare requirements.

This additional layer of scrutiny means that practices who begin services must ensure that they or their RPM partner are following the guidelines closely. The following compliance best practices for RPM can ensure that your program passes the scrutiny of CMS.

Patient Requirements

Providers must ensure and document that patients meet the following requirements before commencing RPM services:

1. Patient has a chronic or acute condition that makes consistent monitoring of symptoms a medical necessity
2. Patient must be an established, current patient of the provider (during the COVID-19 public health emergency, CMS is allowing new patients to begin services)
3. Patient has given verbal or written consent to begin services. Patient has seen the provider in the past 12 months

Remote Patient Monitoring Compliance Best Practices:

1. Make sure that your EMR is up to date with patient data, including current diagnoses, appointments, hospitalizations, and the marking of inactive or deceased patients. Up-to-date patient information is essential for accurately determining which patients qualify for RPM services.
2. Use a dedicated team to identify and enroll eligible patients into your RPM program. The patient enrollment process requires time, attention to detail, and precise record-keeping. Providers may find that their internal staff doesn’t have the bandwidth to analyze large amounts of patient data or spend time on documentation and enrollment calls, so working with a third-party RPM service may help.

Device Requirements

To receive RPM services, patients must have the right devices. Medicare has the following requirements for devices and device procurement:

1. An FDA-approved medical device that transmits patient data to the physician automatically. Often, this means a second transmission device beyond the medical measurement device is needed. See additional device information in our post on CPT 99453.
2. Documentation of the patient condition (ICD-10) that requires monitoring, the order of the device, and the dates of delivery and patient education.

Remote Patient Monitoring Compliance Best Practices:

1. Make sure that the devices you order are simple to use and connect. In order for the devices to qualify for RPM, they cannot require the patient to manually enter data. One good way to ensure connectivity is to have the devices set up to connect via cellular data right out of the box.
2. Use a dedicated team to handle device research, procurement, and patient education. The many moving parts of the procurement process mean that small details are likely to fall through the cracks if left to an already busy general office staff.
3. Consider delegating the device procurement and education process to a third-party that specializes in RPM services. A vendor like HealthXL® can handle every part of the process, from researching and procuring the best devices, to making sure each patient knows how to use them with ease.

Service Requirements

Monthly RPM service is billed under two different codes: CPT 99454 and CPT 99457.

1. To receive reimbursement under CPT 99454, the patient must have at least 16 days of transmitted readings per month (e.g., blood pressure, oxygen and weight).
2. To receive reimbursement under CPT 99457, a clinical staff member must spend 20 minutes on patient treatment. This time can include evaluating and updating the patient’s plan of care, but must also include actually speaking to the patient.

Remote Patient Monitoring Compliance Best Practices:

1. Invest in automatic RPM tracking and billing software. It’s the best way to protect against the inaccuracies of manual record-keeping. Our team uses a proprietary, workflow-based system, iCare by HealthXL®, that tracks each reading and patient interaction–and marks a patient as billable only when all requirements have been met.
2. Have a dedicated RPM servicing team. A successful RPM program depends on keeping patients engaged—and that’s where a dedicated team makes all the difference. If patients do not take the required number of readings or pick up the phone, the provider cannot bill for either CPT 99454 or 99457. Our RPM servicing team calls patients multiple times a month and reminds them to stay on track with their readings.
3. Use a third-party RPM partner for servicing. Both the readings and time requirement make servicing and billing for RPM much more complicated than similar services like Chronic Care Management. To make the most of the RPM opportunity, consider working with an experienced partner that can service your patients at scale–and give you the confidence you are servicing compliantly.