Remote patient monitoring is a relatively new vertical for most providers, but that doesn’t mean it has to be overwhelming. Here are ten common questions that patients and providers have when it comes to RPM and how to offer this service:

1. What is Remote Patient Monitoring (RPM)?

Remote patient monitoring is the practice of collecting, transmitting, and analyzing patient physiologic data between home-based equipment and equipment located at medical care facilities. This data must be wirelessly transmitted through a secure platform to be considered remote patient monitoring by CMS. The data collected via RPM can be used to guide your patient care protocols, monitor the progression of chronic and/or acute conditions, and reduce the costs of providing medical services.

When paired with other modern care practices, remote patient monitoring can enhance your organization’s ability to serve your clients and improve your patients’ access to care.

How is RPM different from telehealth?

It’s easy to get these terms mixed up, but the difference is straightforward. Think of telehealth as the broad category for all remote healthcare services, like video appointments or secure messaging with your doctor. Remote patient monitoring is a specific type of telehealth. According to Prevounce, RPM is unique because it uses digital devices to automatically collect and transmit patient health data from outside the clinic. So, while a video call is telehealth, monitoring a patient’s blood pressure from their home with a connected cuff is RPM. It’s a proactive way to keep an eye on patient health between visits, making it a powerful tool within the larger telehealth ecosystem.

What are the benefits for patients and practices?

For patients, the advantages are significant. RPM can lead to better health outcomes, fewer hospital stays, and lower overall healthcare costs. It’s especially beneficial for older adults or those with disabilities, as it allows them to manage their health while remaining in the comfort of their own homes. For your practice, implementing an RPM program opens up a new revenue stream while improving the quality of care you provide. It allows for more continuous patient management, which can prevent complications and lead to more efficient use of your staff’s time. Ensuring your medical billing processes are set up to handle RPM codes is key to realizing these financial benefits.

What conditions and devices are common in RPM?

One of the best things about RPM is its versatility. It can be adapted to monitor a wide range of chronic and acute conditions using simple, non-invasive devices that patients can easily use at home. This flexibility allows you to tailor your RPM program to the specific needs of your patient population, whether you’re a primary care physician or run a specialty practice.

Common conditions monitored

RPM is particularly effective for managing long-term health issues that require regular monitoring. According to HealthArc, this includes a variety of chronic conditions that affect millions of people. Some of the most common ones are high blood pressure (hypertension), diabetes, congestive heart failure (CHF), and chronic obstructive pulmonary disease (COPD). It’s also used in specialties like cardiology, endocrinology, and pulmonology to track patient progress and adjust treatment plans without requiring constant in-person visits. This is especially valuable in fields like behavioral health, where monitoring co-occurring physical conditions is crucial.

Examples of RPM devices

The technology used in RPM is designed to be user-friendly for patients. You don’t need to be a tech expert to use these devices. HealthArc notes that some of the most frequently used tools include digital blood pressure monitors, blood glucose meters for tracking blood sugar, and pulse oximeters to measure blood oxygen levels. Other common devices are digital weight scales, electrocardiogram (ECG) monitors for heart activity, and thermometers. These tools automatically send data to your clinical team, providing a steady stream of information to guide patient care.

2. How do I set up an RPM program?

Launching an RPM program involves more than just buying devices; it requires thoughtful planning and a clear strategy. The first step is to define the scope of your program. Decide which patient populations you want to serve and which chronic conditions you’ll focus on managing. From there, you’ll need to select the right devices that align with those conditions. It’s also critical to talk with insurance companies to understand their coverage and billing requirements for RPM services. This is where having solid provider credentialing in place is essential to ensure you can get reimbursed properly.

Once you have the foundational pieces in place, you can focus on the operational side. This includes creating clear protocols for everything from patient onboarding and device training to data review and clinical intervention. Your staff will need to be trained on these new workflows to ensure the program runs smoothly. Finally, you’ll need to let your patients know about the new service. A well-planned program not only improves patient care but also integrates seamlessly into your practice’s daily operations, supported by robust revenue cycle administration to manage the new billing complexities.

Choosing an RPM program model

You don’t have to build your RPM program from scratch. According to Prevounce, providers can typically choose from three main models: full-service, self-managed, or a hybrid approach. In a full-service model, you partner with a third-party vendor that handles almost everything, from providing the devices and onboarding patients to monitoring the data. This is a great option if you have limited staff or resources. A self-managed model means your practice handles all aspects of the program in-house. This gives you complete control but requires more internal resources. The hybrid model is a middle ground, where you manage some parts of the program and outsource others.

What technology do patients need?

A common concern is whether patients need to be tech-savvy to participate in an RPM program. The good news is that the technology is designed to be accessible. The specific requirements depend on the device. Some devices may need a Wi-Fi connection or a smartphone to transmit data, but many modern RPM tools are much simpler. As Prevounce explains, many devices now come with built-in cellular technology. This means they work right out of the box without any complex setup, Wi-Fi, or a separate smartphone, making them ideal for patients who may not be comfortable with technology.

How is patient data kept secure with HIPAA?

Patient data security is paramount in any healthcare service, and RPM is no exception. To maintain HIPAA compliance, it’s crucial to work with RPM vendors who prioritize security. According to Prevounce, a key requirement is that all patient data must be encrypted, both when it’s being transmitted from the device and when it’s stored. This scrambling of data ensures that protected health information (PHI) remains confidential and secure from unauthorized access. When vetting potential partners, always ask about their security protocols to ensure they meet HIPAA standards and protect both your patients and your practice.

2. Which CPT Codes Are Used for RPM Billing?

As part of their efforts to expand RPM protocols, CMS has laid out a detailed order of operations for the remote patient monitoring billing process.

They have stated that the first step in the RPM process is the initial set-up of medical devices that are used to collect a patient’s physiologic data. This also includes patient education on how to use these devices.

After the physiologic data have been collected and transmitted, the next step is for physicians and qualified health care professionals (QHCPs) to analyze and interpret the physiologic data.

The final step is to create a custom treatment plan and implement said plan until patient improvement goals are attained. Following the plan until patient improvement goals are attained will bring about the conclusion of an episode of care.

Breaking Down CPT Code 99091

Code 99091 is used to bill for collection and interpretation of patient physiologic data. It requires a minimum of 30 minutes of time in a 30-day period. This collection and interpretation of physiologic data must be performed by a physician or other QHCP, and patient consent for this service must be obtained and documented in the patient’s medical record. 99091 can be used once every 30 days.

Breaking Down CPT Code 99457

Code 99457 is used to bill for the development of a treatment plan that is informed by the ongoing analysis and interpretation of patient data. This code includes the first 20 minutes of treatment care in a 30-day period, and requires interactive communication with the patient or the patient’s caregiver during this time. Care management services, as described by CPT 99457, can be furnished by clinical staff under the general supervision of the physician or non-physician provider (NPP).

3. Which Codes Cover RPM Practice Expenses?

The two primary remote patient monitoring practice expense codes are 99453 and 99454.

A Closer Look at CPT Code 99453

This code is designated for the initial implementation of remote patient monitoring services, and can only be used once per episode of care. Code 99453 accounts for your staff’s time spent educating the patient on the use of the equipment and setting up monitoring devices. 99453 cannot be resubmitted unless the provider is starting a new episode of care for the patient.

A Closer Look at CPT Code 99454

CPT code 99454 is utilized for billing the costs of assessing the patient with the monitoring equipment.

Even if multiple medical devices have been issued, care team billing agents should only use 99454 once per 30-day billing cycle. The costs of operating and programming these devices for repeat monitoring should be calculated cumulatively for billing purposes.

### What are the typical reimbursement rates?

Reimbursement rates for RPM can vary based on the payer and your geographic location, but Medicare’s fee schedule offers a solid benchmark. Medicare uses five main CPT codes for RPM services: 99091, 99453, 99454, 99457, and 99458. Each code corresponds to a specific action with its own reimbursement rate. For instance, CPT code 99453, which covers the initial setup and patient education for using the RPM device, is reimbursed by Medicare at around $20. This is a one-time charge per episode of care. Meanwhile, CPT code 99454 covers the monthly service of providing the device and monitoring the data transmission. Understanding these rates is the first step in building a financially sustainable RPM program for your practice.

### Are there new RPM codes coming?

The world of medical billing is always evolving, and RPM is no exception. CMS and other payers are continually refining how they support telehealth and remote care. One area to watch is Remote Therapeutic Monitoring (RTM). While similar to RPM, RTM focuses more on non-physiologic data, like therapy adherence and pain levels. New codes for RTM are being introduced, which will expand the types of remote care that can be reimbursed. Staying informed about these changes is key to maximizing your practice’s opportunities and ensuring your medical billing processes remain current and compliant.

5. What about insurance coverage and patient costs?

Does insurance cover RPM?

Yes, insurance coverage for RPM is becoming increasingly common. Medicare was an early adopter and provides coverage for RPM services nationwide, setting a standard that many other payers have followed. This has paved the way for broader acceptance across the healthcare industry. Patients can receive these services almost anywhere, including their own homes, as long as they are not in the same physical location as their provider. This flexibility makes RPM an accessible care option for many, especially those with chronic conditions or limited mobility. As telehealth continues to grow, more insurance plans are recognizing the value of remote monitoring for improving patient outcomes and reducing overall healthcare costs.

Medicare, Medicaid, and private payers

Medicare provides robust coverage for RPM, which has been a major driver of its adoption. Following Medicare’s lead, a majority of state Medicaid programs—over 37 as of late 2023—now also cover RPM services, though the specific requirements can vary by state. Coverage from private insurance companies is also on the rise, with some states even mandating that private payers cover telehealth services, including RPM. However, coverage details can differ significantly between plans, so it’s crucial to verify benefits for each patient. Effectively managing the requirements of these different payers is a key part of provider credentialing and revenue cycle management.

Do patients have a copay for RPM?

In most cases, yes, patients are responsible for a copay for RPM services, just as they would be for an in-office visit. For patients with Medicare, this typically means a 20% coinsurance for RPM, as it falls under Part B services. This cost-sharing is a standard part of most insurance plans, and it’s important to communicate this clearly to patients before they begin the program. Being transparent about potential out-of-pocket costs helps manage patient expectations and ensures they are fully informed about their financial responsibility. This simple step can prevent billing confusion down the line and maintain a positive relationship with your patients.

4. What’s the Minimum Monitoring Time for RPM Billing?

Both CPT codes 99453 and 99454 have a minimum monitoring threshold that must be met. Patients and care team members must have utilized the issued remote monitoring devices to collect patient physiologic data during at least 16 days in a 30-day billing period.

During the current COVID-19 pandemic, CMS is allowing RPM codes to be billed for a minimum of 2 days of data collection over a 30-day period rather than the 16 days of data collection that is normally required. When the PHE for COVID-19 expires, CMS will once again require 16 days of data out of 30 days to be collected to bill for codes 99453 and 99454.

5. Which RPM Devices Does Medicare Approve?

For devices to be eligible for remote patient monitoring, they must meet the FDA’s definition of a medical device. Furthermore, eligible devices must be capable of digitally (i.e., automatically) uploading patient data.

The devices prescribed to patients must also be deemed “necessary and reasonable” for the treatment, monitoring, or diagnosis of an illness or injury. Eligible devices must be utilized to reliably collect and transmit valid physiologic data.

This data must also assist your team in managing the care plan and understanding the patient’s health status during treatment.

6. What Counts as ‘Interactive Communication’ for RPM?

CPT code 99457 requires your team to engage in a minimum of 20 minutes of “interactive communication” with the patient during the billing cycle. According to CMS, “interactive communication” must include real-time two-way audio communication that is capable of being enhanced with video or other kinds of data sharing technology.

The initial 20 minutes of interactive communication should be billed using code 99457. Each additional 20-minute block of interactive communication should be reported with CPT code 99458.

Billing agents for care teams cannot utilize supplemental code 99458 unless the criteria for 99457 have already been met during that 30-day cycle. 99458 does not serve as a standalone billing code.

9. Can I bill for RPM and Chronic Care Management (CCM) together?

This is a fantastic question, and one that comes up often for practices managing patients with multiple chronic conditions. The short answer is yes, you absolutely can bill for both RPM and CCM services in the same month for the same patient. These services are designed to be complementary, offering a more complete approach to patient care. However, there’s a critical rule you must follow: the time spent on each service must be separate and distinct. You cannot count the same minutes toward both services.

Think of it like this: to bill for both, you need to meet the minimum time requirement for each service independently. For the most common codes, this means you must provide at least 20 minutes of RPM services (CPT code 99457) and at least 20 minutes of non-face-to-face CCM services (CPT code 99490). This adds up to a total of 40 minutes of dedicated care management time. The key is meticulous documentation. Your records must clearly show that 20 minutes were spent on RPM-specific tasks and a separate 20 minutes were spent on CCM activities.

Properly managing these concurrent services is vital for compliance and ensuring proper reimbursement. Keeping detailed, separate time logs for each activity protects your practice during an audit and justifies the claims. For many practices, navigating these specific billing rules can be a challenge on top of providing excellent patient care. This is where having a solid revenue cycle management partner can be invaluable, as they can help ensure your billing is accurate, compliant, and optimized, allowing you to focus on your patients’ health.

7. Who on My Team Can Handle RPM Consent and Services?

Qualified healthcare professionals and clinicians can provide remote patient monitoring services provided they meet the definition described by CMS.

Your clinical staff providing care under the supervision of a licensed physician or non-physician practitioner can furnish CPT codes 99457 and 99458.

In the 2021 expansion of remote patient monitoring regulations, CMS also stated that auxiliary personnel could utilize CPT codes 99453 and 99454 if they are acting under a billing physician or other  practitioner’s “general supervision”.

CMS further clarified that health care teams should obtain consent for remote patient monitoring services at the time that services are provided. Auxiliary personnel or can obtain patient consent, provided that the correct forms are used, and the patient takes a positive action to affirm consent.

8. Who Is Qualified to Order and Bill for RPM?

Since remote patient monitoring solutions are classified as evaluation and management services by CMS, they can only be ordered and billed by physicians and qualified non-physician practitioners.

These individuals must be eligible to bill for Medicare E/M services. Compliance with this provision is essential if you want to avoid any billing discrepancies or reimbursement concerns.

12. What are the documentation and compliance rules?

Like any billable service, remote patient monitoring comes with its own set of rules for documentation and compliance. Getting these details right from the start is the key to building a successful and sustainable RPM program. It ensures you can defend your billing practices if questioned and helps create a smooth reimbursement process. Think of it as building a strong foundation—it protects your practice and makes everything that comes after much easier to manage.

What documentation is required for RPM billing?

Meticulous documentation is non-negotiable for RPM billing. To create a clear and compliant record for each patient, you need to keep track of several key items. According to CMS guidelines, your documentation should always include the patient’s consent for RPM services, the physician’s order for the monitoring device, and specific details about the conditions you are monitoring. You also need to record what device is being used, the date it was provided to the patient, and when they received training on how to use it. This level of detail is essential for proper medical billing and reimbursement.

Are there limits on who can bill for an RPM patient?

Yes, there are important restrictions on who can bill for RPM services. First, only one healthcare provider can bill for RPM for a specific patient during a given period. This prevents duplicate billing for the same service. Furthermore, CMS classifies RPM as an evaluation and management (E/M) service. This means only physicians and qualified non-physician practitioners who are eligible to bill Medicare for E/M services can order and bill for RPM. Ensuring your team meets these requirements is a critical step in maintaining compliance, which often starts with proper provider credentialing.

What should I know about government audits?

As RPM programs become more common, so do government audits. Agencies like the Office of Inspector General (OIG) are actively reviewing RPM programs to check for compliance with billing regulations. They are specifically looking for cases where services are billed without adequate clinical oversight or proper documentation. This increased scrutiny means it’s more important than ever to have your records in order. Maintaining thorough, accurate documentation for every patient isn’t just good practice—it’s your best defense in an audit and a core component of effective revenue cycle administration.

9. Is RPM for New Patients, Established Patients, or Both?

Currently, remote patient monitoring is allowed for new and established patients. CMS is temporarily allowing RPM services to be offered to new patients in response to the national COVID-19 Public Health Emergency.

Once the PHE for COVID-19 ends, CMS will again require that RPM services be offered to only established patients. The purpose behind limiting RPM to established patients is to ensure that physicians have had an opportunity to conduct a physical exam and collect relevant medical history for the patient.

A notable exception to the established patient rule is the use of real-time interactive communication in the telehealth industry. CMS has not provided any specific guidance on the practice of conducting E/M services on new patients via this type of communication.

Medicare-approved telehealth providers are allowed to use new patient E/M codes. It appears that CMS is deferring to state clinical care standards on this issue.

We recommend consulting with your legal department to discuss the possibility of conducting remote E/M new patient assessments. Depending on the laws in your state, your organization may be able to satisfy CMS assessment requirements for remote patient monitoring via interactive electronic communication.

10. Do Patients Need a Chronic Condition to Qualify for RPM?

In 2019, CMS specifically limited coverage of remote patient monitoring services to patients suffering from chronic medical conditions. However, they modified this stance in response to the 2020 COVID-19 pandemic. Currently, CMS allows you to furnish remote patient monitoring for individuals suffering from acute conditions and/or chronic conditions.

15. Are there related services or special billing cases?

As remote monitoring becomes more integrated into patient care, it’s natural for new applications and billing scenarios to emerge. Beyond the standard RPM framework, there are related services like Remote Therapeutic Monitoring (RTM) and specific rules for different types of healthcare facilities. Understanding these nuances is key to maintaining compliance and ensuring proper reimbursement for the care you provide. It’s also important to know how these services can be applied in specialized fields, such as palliative care, to support patients with complex needs. Let’s look at a few of these special cases.

What is Remote Therapeutic Monitoring (RTM)?

While RPM focuses on physiological data like blood pressure and glucose levels, Remote Therapeutic Monitoring (RTM) is a newer set of services designed to monitor non-physiological data. Introduced in 2020 and billable since 2022, RTM tracks things like a patient’s adherence to a medication or therapy plan, their response to treatment, and self-reported pain levels. This is particularly useful for managing musculoskeletal and respiratory conditions. It’s a critical distinction for billing purposes, as you cannot bill for both RPM and RTM services for the same patient in the same month. Choosing the right one depends entirely on the type of data you need to manage your patient’s care plan effectively, making accurate medical billing essential.

Can FQHCs and RHCs bill for RPM?

Yes, and this is a significant update for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs). As of January 1, 2024, these facilities can provide and bill for both RPM and RTM services. Previously, these services were considered part of the general care included in the all-inclusive payment rate and were not separately billable. This change opens up a new revenue stream and allows FQHCs and RHCs to offer more comprehensive remote care to their communities. It’s also important to note that by October 2025, these clinics will need to transition from using the general care management code G0511 to using specific CPT codes for these services, which requires careful attention to your healthcare revenue cycle management processes.

How is RPM used in palliative care?

RPM is an excellent tool for palliative care, where the focus is on managing symptoms and improving a patient’s quality of life. For instance, a patient with advanced heart failure can use a remote scale to monitor for fluid retention, allowing the care team to adjust diuretics proactively and prevent a hospital visit. Nurse practitioners, who are often at the forefront of palliative care, can conduct telehealth visits to discuss this data and can bill for their time using either standard office visit codes or the specific RPM codes. This flexibility allows providers to integrate remote monitoring seamlessly into their workflow, ensuring that every team member, from nurses to physicians, has the proper provider credentialing to bill for these valuable services.