OIG Flags RPM as a Compliance Risk Area
In the Fall 2025 Semiannual Report to Congress, the HHS Office of Inspector General (OIG) identified the substantial growth in use of Remote Patient Monitoring (RPM) and classified the services as an area requiring enhanced oversight. The report highlighted RPM as a service category vulnerable to improper billing and recommended that payers strengthen monitoring to detect potential fraud, waste, or abuse.1
Understanding RPM and the CPT Codes Involved
Remote Patient Monitoring involves the use of non–face‑to‑face technology to collect and analyze physiological patient data such as oxygen saturation, blood pressure, weight changes, and blood glucose levels. The Current Procedural Terminology (CPT) codes utilized in reporting RPM include:
- 99453 – Initial setup and patient education on use of RPM equipment.
- 99454 – Device supply plus daily recordings or programmed alerts, requiring 16- 30 days of data within a 30‑day period (code updated for 2026).
- 99445 – Device supply plus daily recordings or programmed alerts, requiring 2-15 days of data within a 30-day period (code added 1/1/2026).
- 99470 – First 10 minutes of treatment management during the calendar month, requiring real-time interactive communication (code added 1/1/2026).
- 99457 – First 20 minutes of treatment management during the calendar month, requiring real-time interactive communication.
- 99458 – Each additional 20‑minute increment of RPM treatment management.
To summarize, CPT codes 99445, 99453–99458 and 99470 represent the full RPM service bundle which is comprised of three components: setup/patient education, device supply/automated data transmission, and ongoing treatment management with patient communication. The CPT code additions and updates for 2026 create short-duration pathways for data monitoring days and treatment management time.
Existing CMS Payment Edits and Requirements
Centers for Medicare and Medicaid Services (CMS) Telehealth & Remote Monitoring MLN guidance issued December 2025 outlines that clams for RPM are already subject to established review elements and payment edits.2 These include, but are not limited to:
- Established patient requirement: Patients must have a prior E/M service on record, although CMS does not define a look‑back timeframe.
- Eligible providers: Only physicians and Non-physician practitioners who can furnish E/M services may bill RPM.
- Medical necessity: Monitoring must address an acute or chronic condition.
- Data sufficiency: Data and duration of reporting must meet the minimum collection and interpretation requirements outlined in CPT descriptors.
- Bundling rules: time spent interpreting data obtained from RPM cannot be double counted with Remote Therapeutic Monitoring (RTM) or certain care management services such as chronic care management, transitional care management, behavioral health integration, principal care management, or chronic pain management.
OIG‑Recommended Additional Oversight Measures
To strengthen RPM program integrity, OIG has suggested CMS consider additional measures to further detect and prevent fraudulent reporting of RPM:3
Verify the Completeness of All RPM Components
Although providers are not required to bill for all three RPM components, OIG notes that providers’ billing patterns in which one or more components are not reported may indicate services are incomplete. The OIG has recommended that CMS analyze providers whose billing patterns often omit patient education/device setup or treatment management.
Scrutinize Diagnosis Code Specificity
RPM must be tied to monitoring acute or chronic conditions. Claims billed with vague or non-specific diagnoses, such as those describing “other specified counseling”, may draw additional payer scrutiny.
Develop New Procedure Codes or Modifiers to Allow for More Comprehensive RPM Coding
The OIG notes that current RPM Healthcare Common Coding System (HCPCS) codes are generic and lack detail to distinguish between the types of physiological data being collected or the device utilized. They recommend the creation of more specific codes or modifiers to improve transparency and enhance payer ability to monitor RPM services.
Evaluate Ordering Practices
To gain further transparency into whether reported RPM services meet payer requirements, OIG recommended that CMS require RPM to be ordered by a physician Qualified Health Plan (QHP) and that ordering provider information be displayed on claims.