Remote Patient Monitoring Again in the Spotlight

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) has posted a report titled Additional Oversight of Remote Patient Monitoring in Medicare is Needed.

You know what that means?

Primary care physicians and cardiologists beware!

Since use of telehealth and remote patient monitoring has skyrocketed since COVID, the OIG has determined that telehealth, like behavioral health or home health, is a less tangible service – rather than, for example, orthopedist services, where X-rays display broken bones. Therefore, since patient monitoring, behavioral healthcare, and home health are more subjective, they tend to get ranked as high-risk in the eyes of the Centers for Medicare & Medicaid Services (CMS). The most common conditions for which Medicare enrollees receive remote monitoring services were hypertension (55 percent) and diabetes (16 percent). Hence, primary care (59 percent) and cardiology (11 percent) providers are targets in the firing zone.

According to the OIG report, approximately 43 percent of the Medicare enrollees analyzed in the report who received remote patient monitoring services were not provided at least one of the three following components of these services:

1. Enrollee education and set-up (CPT® code 99453);
2. Supply of a connected device (CPT code 99454); and
3. Treatment management (CPT codes 99091, 99457, or 99458).

What OIG is alleging is that providers billed for the aforementioned codes, but did not render the services. In my opinion, OIG’s report is a bit more focused than usual. Oh, and I guess I should include durable medical equipment (DME) companies because of 99454, supply of a connected device.

Going back to the codes at issue: there is no requirement to render all three components to all consumers. I think that is important to remember, as a possible denial reason could be that an auditor thinks all three are required. It would be illustrative of the types of denials we have seen in the past. CMS and OIG’s report are clear. The agencies smell blood.

This report is just the latest indicator signifying that remote patient monitoring is an area of increased government interest. In addition, Medicare use of remote patient monitoring remains an open OIG Work Plan item, and CMS recently provided additional clarification regarding Medicare restrictions related to remote physiologic monitoring and remote therapeutic monitoring services in the 2024 Physician Fee Schedule Final Rule.

Among other things, the Final Rule reaffirmed that such remote monitoring services should only be furnished to an established patient, confirmed a return to pre-pandemic data collection and transmission requirements of at least 16 days in a 30-day period, and provided additional detail about when remote monitoring may and may not be billed in conjunction with other services.

Thus, Medicare providers that bill for any component of the remote patient monitoring services should expect and prepare for heightened government scrutiny regarding their Medicare billing practices, which may include increased and targeted audit activity.