Remote Patient Monitoring (RPM) Frequently Asked Questions

Coverage for RPM

CPT Copyright 2023 American Medical Association. All rights reserved.
CPT® is a registered trademark of the American Medical Association.

What payers cover RPM and how is it reimbursed?

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.

What state Medicaid programs cover RPM?

As of spring fall 2023, the Center for Connected Health Policy (CCHP) reports that 37 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.

Is setting up the RPM device and related patient education considered covered services?

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.

Are there rules governing where patients need to be to receive RPM services?

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.

RPM Billing, Coding, and Compliance

What CPT codes cover RPM and how much are they reimbursed by Medicare*?

As of CY 2024, they are as follows:

• 99453 (Remote monitoring of physiologic parameter(s) (e.g, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment) — Medicare pays ~$20 for initial setup of an RPM device and patient education.
• 99454 (Device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days) — Medicare pays ~$47 per month for monitoring patient data as it streams in from a device.
• 99457 (Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; initial 20 minutes) — Medicare pays ~$48 per month for spending 20 minutes a month tracking and monitoring data and managing resulting care.
• 99458 (Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; additional 20 minutes) — Medicare pays $39 per month for each additional minute spent past 99457's initial 20 minutes up to 60 minutes total.

* 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 2024, Medicare reimburses ~$53 for CPT 99091.

Who can perform RPM under CPT code 99457?

99457 reimburses for time spent by the billing physician, QHCP, or clinical staff, in accordance with laws.

Are RPM services only reimbursable for patients with multiple chronic conditions?

No. Providers may recommend RPM services for any patient who may benefit from the service.

Is CPT code 99454 reimbursed per device or per patient?

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.

Can RPM be billed in conjunction with chronic care management (CCM)?

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.

What is the 16-day rule?

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.

Is there a copayment associated with RPM services?

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.

What should I know about auditing of remote patient monitoring programs? 

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 April 2023, the Office of Inspector General (OIG) noted that a Medicare/OIG remote patient monitoring fee-for-service utilization review was underway, with a report expected to be released in 2024. The report will include research into general RPM utilization, enrollee characteristics, and the extent of fraud/waste identified. OIG Office of Evaluation and Inspection reports are often used to guide future auditing and review strategies.

What are the documentation requirements for RPM?

Providers should initially obtain informed beneficiary consent to receive RPM services. 

To document CPT 99453, include the following:

• practitioner order for device deployment;
• condition(s) for which the patient is being monitored;
• device identification;
• date of delivery of the device to the patient; and
• date(s) on which training is provided to the patient.

For time-based codes (CPT 99457 and 99458), document the time spent on each.

Is text messaging an acceptable form of "interactive communication" under Medicare rules?

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.

Can multiple practitioners deliver remote patient monitoring services to the same patient at the same time?

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.

Are patients permitted to report their own measurements? 

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. 

Federally Qualified Health Centers (FQHCs) & Rural Health Clinics (RHCs)

Can federally qualified health centers (FQHCs) and rural health clinics (RHCs) deliver RPM and RTM services?

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.

What HCPCS code should FQHCs and RHCs use to bill for RPM and RTM?

Use general care management HCPCS G0511. For 2024, Medicare will reimburse FQHCs and RHCs ~$73 for HCPCS G0511.

Can FQHCs and RHCs bill HCPCS G0511 multiple times in a calendar month for the same patient?

Yes, provided that minimum requirements are met. When appropriate, FQHCs and RHCs can now bill G0511 for:

• Remote physiological/patient monitoring (RPM)
• Remote therapeutic monitoring (RTM)
• Chronic care management (CCM)
• Principal care management (PCM)
• Behavioral health integration (BHI)
• Chronic pain management (CPM)
• Community health integration (CHI)
• Principal illness navigation (PIN)

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.