December 17, 2024
Prevounce Health
RPM is the use of digital technologies to monitor and capture medical and other health data from patients and electronically transmit this information to healthcare providers for assessment and, when necessary, recommendations and instructions. RPM allows providers to continue tracking healthcare data for patients once they are discharged. It also encourages patients to take more control of their health.
Providers can use RPM to collect a range of patient health data, including blood pressure, vital signs, weight, heart rate, blood sugar levels, and physical activity.
RPM can employ wired or wireless measurement devices. The most common RPM devices are blood pressure monitors, weight scales, cardiac implants, blood glucose meters, and pulse oximeters.
Physicians and other qualified healthcare professionals (QHCPs) can provide and bill for RPM. Clinical staff can furnish and manage RPM under the general supervision of the billing provider.
Any patient. With that said, a provider should only order/prescribe RPM if captured data is directly relevant to managing a patient's condition(s) (i.e., medical necessity), with such justification documented in the medical record.
Yes, starting Jan. 1, 2024. More information on RPM rules for FQHCs and RHCs are below.
RPM provides a wide range of benefits, including the following:
Since each RPM program is different, the steps to set up programs will vary. The amount of work that providers must complete will differ by RPM program, but these are the general steps for providers who choose to deliver RPM services with minimal external support:
While this may seem like a lengthy list, a good RPM program vendor will perform many of these steps, thereby reducing the effort and management required from the provider and staff.
This will largely depend upon the RPM device and how data is transmitted from patient to provider. Some devices require patients to access one or more of the following: Wi-Fi; smartphone (in some instances, newer models); and personal computer. Other devices may only require the device itself. Such devices use cellular data to transmit information.
Depending upon the design and/or complexity of the device, patients may need in-person or virtual assistance to set up and use the technology.
Where RPM data is stored will depend upon the device. Typically, data is captured and transmitted via a Wi-Fi or cellular network to a central data repository. Types of repositories include an electronic health record (EHR) system or personal health record.
Older devices often stored the information on the device itself, which then required patients to convey the information to their providers. This type of workflow is no longer considered RPM by Medicare and the vast majority of other payers.
RPM is considered a specific subset of telehealth. One can use the phrase ‘telehealth’ to refer to RPM, but telehealth can also refer to many other types of remote healthcare services.
RPM is the use of a device for interaction between providers and patients outside of the provider’s organization. Telehealth is the use of electronic information and telecommunications technologies to support long-distance clinical care, patient and professional health-related education, public health, and health administration.
Yes, and providers must obtain — in writing or verbally — and document consents in patients' medical records. Medicare allows for informed verbal consent, but other payers may require written.
Specialties frequently embracing RPM include cardiology, pulmonology, endocrinology, gastroenterology, and bariatrics.
Common disease states managed by RPM include hypertension, obesity, congestive heart failure (CHF), chronic lower respiratory disease (COPD), and diabetes.
Like any healthcare program, providers should follow HIPAA security and privacy regulations. Providers should ensure that their RPM devices and technology are compliant with FDA standards. Technology that meets FDA standards can help ensure quality control and assurance, data accuracy, and compliance. Finally, providers will want to ensure that their RPM programs follows the most current coding and billing rules.
This essentially boils down to carefully vetting RPM vendors and their devices. Vendors should build their devices so that patient data is encrypted when it is in transit — from patient to provider and vice versa — and when the device that stores the data is not in use.
There are a variety of programs and vendors providers can choose from. Generally speaking, they can be broken down into two types: full-service programs and those requiring a self-managed approach. The following summarizes the essential differences between these programs:
For Medicare beneficiaries receiving services during a global period, a provider may furnish RPM or remote therapeutic monitoring (RTM) services — but not both — to the individual beneficiary and the practitioner will receive separate payment. Remote monitoring services provided must be intended to address an underlying condition, not linked to the global procedure or service.
The practitioner will receive payment for the RTM or RPM services, separate from the global service payment, as long as other requirements for the global service and any other service during the global period are met.
Additional Reading:
Learn more about RPM's value to patients and financial benefits to healthcare organizations.
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RPM is payable by Medicare, 37 state Medicaid programs (as of December 2023), and an increasing number of private payers. Some states, such as Louisiana, have mandated that all private insurers operating in the state must cover some form of RPM.
There is a small payment for initial patient enrollment, and a monthly base payment for management of the device and patient readings. There is an optional service for each 20 minutes of care management — which can be provided by clinical staff — up to 60 minutes total.
As of winter 2024, the Center for Connected Health Policy (CCHP) reports that 42 states have some form of reimbursement for remote patient monitoring in their Medicaid programs. This is up from 22 states from fall 2020.
However, there are some caveats to some states' RPM coverage. Many of the states with Medicaid programs that reimburse for RPM have restrictions associated with RPM use. CCHP states the most common of these restrictions include only offering RPM reimbursement to home health agencies, restricting the clinical conditions for which symptoms can be monitored, and limiting the type of monitoring device and information that can be collected.
Yes, via CPT code 99453. See the FAQ "What CPT codes cover RPM and how much are they reimbursed by Medicare?" below for more details.
Essentially, no. As long as patients are not in a shared space with the provider delivering the RPM services, they can receive these services. This means patients can be in their homes, on vacation, in a skilled nursing facility, at work, or any other location where the service can be provided.
Our billing guide offers vital information on new CPT codes, billing flow, service requirements and reimbursement.
As of CY 2025, they are as follows:
* Amounts identified are approximate. Reimbursement varies among Medicare administrative contractors (MACs).
Note: CPT code 99091 was the original way to bill for remote patient monitoring. Over the past several years, its limitations and requirements had made it rarely reported due to the availability of the newer codes listed above. However, the 2021 Medicare physician fee schedule final rule changed the frequency that CPT 99091 is reported as CMS now permits billing the code with newer codes. In other words, providers can bill for "complex" RPM management when the provider must spend significant time managing the patient and their RPM care plan. CMS also stated that 99091 can be billed each 30 days whenever such complex provider management occurs without affecting the practice's ability to bill clinical staff time via CPT 99457 each calendar month. In 2025, Medicare reimburses ~$52 for CPT 99091.
99457 reimburses for time spent by the billing physician, QHCP, or clinical staff, in accordance with laws.
No. Providers may recommend RPM services for any patient who may benefit from the service.
99454 can only be billed once per patient every 30 days. This is regardless of whether the patient is using a single device or multiple devices.
Yes, a provider can bill both the RPM CPT code 99457 and CCM CPT code 99490. CMS recognizes the analysis involved in furnishing RPM services is complementary to CCM and other care management services. With that said, the time spent by providers in furnishing these services cannot be counted towards the required time for RPM and CCM codes for a single month. In other words, no “double counting.” Billing 99457 and 99490 together requires a provider to deliver at least 40 minutes of services: 20 minutes of RPM, 20 minutes of CCM.
Prior to COVID-19, the answer to this measurement days question was fairly straightforward: 16. However, a federal waiver issued early in the pandemic permitted providers to deliver and bill for RPM services to those patients with suspected or confirmed cases of COVID-19. The waiver stated that CMS would permit the reporting of RPM services to Medicare for periods of time of fewer than 16 days but no less than two days during the public health emergency (PHE). This became known as Medicare's "2-day RPM requirement." However, what's important to understand is that billing for CPT code 99453 and CPT code 99454 requires usage of a medical device that digitally collects and transmits 16 or more days of data every 30 days for the billing of these codes. This referred to as the "16-day RPM requirement."
Some providers and RPM vendors applied the 2-day RPM requirement to all patients during the PHE. This interpretation was incorrect. In early 2021, CMS stated that the 2-day RPM requirement should only be applied to patients with a suspected or confirmed diagnosis of COVID-19.
In the 2024 Physician Fee Schedule final rule, CMS responded to comments to further clarify that the 16-day rule only applies to device and supply codes (99453/99454) and not to time-based treatment management codes.
For Medicare beneficiaries: Yes. RPM services, like other Medicare Part B services, are subject to a 20% beneficiary copay. This copay is generally not waivable, but it may be covered if a patient has supplemental coverage or Medicaid.
Private payers establish their own copay policies and may choose not to require a copay.
In January 2021, remote patient monitoring was included in an announcement by the Office of Inspector General that CMS would be conducting a series of audits of Medicare Part B telehealth services. These Recovery Audit Contractor (RAC) and Medicare Administrative Contractor (MAC) audits are to occur in two phases. RPM was identified as part of the second phase. To learn four of the RPM areas auditors are likely to focus on during audits, click here.
In September 2024, the Office of Inspector General (OIG) released their Medicare/OIG remote patient monitoring fee-for-service utilization review, which was announced in early 2023. The report identified instances of RPM companies with no other clinical services taking patients as referrals, and the large increase in RPM, among other concerns, as cause for additional oversight of RPM in Medicare. OIG Office of Evaluation and Inspection reports are often . For more in depth coverage on how this report may be used to guide future auditing and review strategies, read our co-founder, and practicing Medicare compliance attorney, Daniel Tashnek's Physicians Practice article on what practices need to know.
Providers should initially obtain informed beneficiary consent to receive RPM services.
To document CPT 99453, include the following:
For time-based codes (CPT 99457 and 99458), document the time spent on each.
No. CMS has defined interactive communication, as referred to in CPT code 99457 and CPT code 99458, as a conversation occurring in real time that includes synchronous, two-way interactions which can be enhanced with video or other kinds of data. This had been interpreted by some RPM providers and vendors to include texting as an acceptable method for delivering billable interactive communication time. But as of the 2021 Medicare physician fee schedule final rule, this is no longer the case. Time spent texting with patients can be counted towards RPM management time. However, it does not satisfy the requirement for interactive communication. Some billable time for each RPM code must be achieved via audio communication with the patient/caregiver.
No. This is a topic that has caused great confusion. If one or more providers attempt to bill for remote patient monitoring services for a patient already receiving RPM services from another provider, associated claims are likely to be denied. Repeated attempts to bill for RPM in this fashion could lead to compliance challenges.
Not for remote patient monitoring. While self-reporting measurements into a patient portal or app or otherwise manually conveying measurements to providers may qualify for other Medicare covered services, data captured in such a fashion cannot be counted towards Medicare RPM. RPM device measurements must automatically sync with a provider's remote patient monitoring platform without any patient transcription.
Resource Guide:
See what Medicare reimburses for CPT and HCPCS codes associated with RPM, RTM, and other care management services.
Generally speaking, remote therapeutic monitoring (RTM) is designed to help manage patients using medical devices that collect "non-physiological data." The concept of RTM was introduced by the American Medical Association in 2020. Providers could begin billing for RTM starting Jan. 1, 2022, following the release of the 2022 Physician Fee Schedule final rule.
It includes data around therapy/medication adherence, therapy/medication response, and pain level. RTM differs from remote patient monitoring in that RPM can only be used to track physiologic data, such as heart rate, blood pressure, and blood sugar levels.
The five remote therapeutic monitoring codes have the following descriptions and 2025 reimbursement rates:
These five RTM codes are classified as general medicine codes, whereas RPM codes are classified as evaluation and management (E/M) codes.
No.
Yes, starting Jan. 1, 2024. More information on RTM rules for FQHCs and RHCs are below.
Yes and yes. Remote therapeutic monitoring is also good for payers. Providers can use RTM to address some significant gaps in the current coverage and delivery of remote patient monitoring. RTM services helps patients experience more consistency and quality along the care continuum, especially for chronic disease monitoring.
WEBINAR:
Learn what is required to launch and scale a thriving RPM program from Rob Cushman, CEO of Dunwoody Village Clinic in Georgia.
In the 2024 Medicare Physician Fee Schedule (PFS) final rule, CMS finalized its policy to reimburse remote patient monitoring (RPM) and remote therapeutic monitoring (RTM) services when furnished by FQHCs and RHCs. Prior to 2024, RPM and RTM codes had not been separately billable by federally qualified health centers and rural health clinics, with the services considered "included" within an all-inclusive rate. The rule change was welcome news for FQHCs and RHCs and their patients, as coverage of RPM and RTM will enable these organizations to provide more comprehensive remote care management services to patients while generating meaningful revenue.
Through 2024 FQHCs and RHCs could only use general care management HCPCS G0511. Starting in 2025, Medicare will reimburse FQHCs and RHCs with the standard CPT codes, and reimbursement, outlined in the sections above.
Yes, provided that minimum requirements are met. When appropriate, FQHCs and RHCs can now bill G0511 for:
However, CMS has not made it clear how many G0511 codes can be billed on one patient each month. We know FQHCs and RHCs can bill for the provision of RPM and CCM together (which would generate ~$146 in Medicare reimbursement), but we are awaiting clarification on other billing rules, including whether billing for the initial enrollment/setup of RPM is an acceptable, standalone billing opportunity, as it is with the RPM CPT codes.
Additional Reading:
The Centers for Medicare & Medicaid Services (CMS) has issued its 2025 physician fee schedule (PFS) final rule. This overview covers five topics that stand out for remote care management.
Download the billing guide to learn more about:
Non-Medicare coverage for remote patient monitoring
Remote patient monitoring service codes
Remote patient monitoring management codes
The billing process for RPM
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