The US Health and Human Services Office of Inspector General (OIG) recently released a report by its Office of Evaluation and Inspections highlighting significant trends and recommendations regarding billing for remote patient monitoring (RPM) in Medicare. The report acknowledges the growing adoption of RPM as a technology-based healthcare service while underscoring the importance of providers and the Medicare program adopting compliance-oriented safeguards when billing and paying for RPM services.
Growth in Remote Patient Monitoring
As the location of healthcare delivery increasingly shifts from the facilities to the home, RPM creates opportunities for greater access to preventive care at a more affordable cost, in turn leading to reductions in hospitalizations and emergency visits. RPM refers to the collection and transmission of patients’ physiological data (e.g., blood pressure, glucose levels, heart rate) from their home or another nonclinical setting to healthcare providers for assessment and intervention.
RPM often involves the use of digital devices, mobile apps, and secure data platforms that enable continuous communication between patients and care teams, supporting early detection of changes in health status and more timely clinical decision-making.
Over the last several years, healthcare providers have increasingly integrated the use of RPM technologies into the delivery of their healthcare services. OIG reported that in 2024 alone Medicare payments for RPM surpassed $500 million, with Medicare coverage for RPM having only been first established in 2019.
This growth reflects the industry’s increasing reliance on technology to enhance patient care and management, with nearly one million Medicare enrollees utilizing RPM services in 2024, representing a substantial uptick in the use of technology-based healthcare solutions.
As is often the case, OIG monitors Medicare coverage and payment trends for new technologies and services. In 2024, OIG released its first report on RPM services, finding that nearly half of enrollees who received RPM services did not receive all three of its components: education and setup, device supply, and treatment management.
This discrepancy led OIG to question whether the Centers for Medicare & Medicaid Services (CMS) Medicare payments for RPM services were actually being used as intended. As a result, OIG recommended in 2024 that CMS strengthen its oversight of RPM through the implementation of additional billing safeguards, inclusion of information about the ordering provider within claims and encounter data, and provider education. In its August 2025 report, OIG is sounding the cautionary yellow flag yet again.
Monitoring and Safeguarding Medicare
In light of the continued expansion of RPM use and associated program integrity concerns, OIG’s updated report on the use of Medicare payments for RPM reiterated the recommendations of its first report and again called for additional CMS oversight on the use and reimbursement of RPM services. Specifically, OIG emphasized the need for vigilant monitoring of RPM billing to protect the Medicare program from potential fraud, waste, and abuse.
In furtherance of this recommendation, the report outlines specific measures that CMS may use to identify billing practices that require further scrutiny. These measures include monitoring for healthcare providers that are billing for
- a high proportion of enrollees with no prior history with the medical practice;
- a high proportion of new enrollees with the medical practice that are receiving RPM services for the first time;
- a high proportion of enrollees that have never received any associated treatment management;
- an enrollee that is already receiving RPM services at another practice; or
- multiple monitoring devices per month for a single enrollee
The recommendations in the report suggest that, if CMS adopts the OIG’s recommendations, claims for RPM services will be reviewed with a more careful eye toward identifying patterns that signal potential program integrity concerns. As a result of these recommendations, we can reasonably expect greater Medicare claims scrutiny for RPM services.
Providers utilizing RPM with their Medicare beneficiary population should reinforce appropriate training and processes to protect against RPM billing noncompliance and ensure that the provision of RPM services is medically necessary for the patient’s condition.
How We Can Help
Morgan Lewis provides counseling to healthcare providers and digital health companies on Medicare requirements related to various RPM services. Our team will continue to monitor the developing regulatory environment influencing the provision of RPM services and remains ready to assist digital health companies and providers in navigating these complex issues.