Why does billing for multiple remote monitoring devices attract scrutiny?

OIG developed a measure to flag practices that bill for multiple remote patient monitoring devices for one enrollee in a month. Its data show that this pattern was uncommon across most practices, but about 20 practices billed for two or more devices more than 100 times in a year, making repeated claims a specific oversight concern.

OIG tracks a distinct billing pattern

The measure is part of a broader effort to monitor remote patient monitoring, or RPM, billing. A policy snapshot from AMDA, the Society for Post-Acute and Long-Term Care Medicine, reports that OIG developed measures for billing a high proportion of enrollees with no prior history at the practice and for billing multiple devices per enrollee in a month. The latter measure puts repeated device claims on OIG's radar as a pattern to examine.

The measure identifies billing activity for monitoring. A multiple-device count is a signal for review, not by itself proof that a claim was improper.

The pattern was rare, but repeated at some practices

OIG's 2024 data snapshot found that most medical practices never billed for more than one RPM device per enrollee per month. About 20 practices, however, frequently billed Medicare for two or more devices for an enrollee in a month. Each of those practices did so more than 100 times in a year.

That frequency helps explain why the measure attracts attention. A one-off claim and a recurring pattern are different billing profiles. OIG's measure is designed to help identify patterns for oversight; the snapshot does not say that every multiple-device claim is improper.

Scale adds to the oversight focus

RPM spending has grown large enough to draw broader attention. OIG reports that payments across Original Medicare and Medicare Advantage exceeded $500 million in 2024. In a separate report, the agency says there is an increasing need to understand who receives RPM, what conditions it is used for, and where vulnerabilities may limit oversight.

Those concerns apply to the program as a whole. For practices billing multiple devices, the device measure offers a more specific reason to examine how often that pattern appears in their own claims. A law firm reviewing OIG's report advised Medicare providers billing any RPM component to expect heightened government scrutiny, possibly including increased and targeted audits.

A practical review starts with the claims pattern

Practice owners can take a concrete first step by running a report that groups RPM device claims by enrollee and month. Reviewing how often the same enrollee has multiple device claims, and whether those instances recur, can help a practice see the pattern OIG is monitoring. This is a billing review, not a conclusion about whether an individual patient should receive monitoring.

Keep the review focused on what the measure tracks: the count of devices billed for an enrollee in a month and how frequently that occurs. Because OIG's measure is intended for oversight, practices with recurring patterns may want qualified billing or healthcare counsel to assess their claims and applicable requirements.

This page is general education only. It is not medical advice. Talk with your own doctor about your health.

Frequently asked questions

How many medical practices billed for RPM in 2024?

OIG identified 10,388 practices that billed at least one Medicare or Medicare Advantage RPM service in 2024. The count includes practices billing fee-for-service Medicare, Medicare Advantage plans, or both.

What other RPM oversight concern did OIG report?

OIG reported that about 43 percent of enrollees receiving RPM did not receive all three components of the service. It said this raised questions about whether monitoring was being used as intended.

Why might device claims be hard to interpret from the code structure alone?

Attorneys at McDermott Will & Schulte say RPM codes separately cover device provision, training and education, and treatment management tied to data transmission. They argue that some OIG concerns stem from this structure.

Sources

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