Remote Patient Monitoring under OIG Scrutiny

by  Wyn Staheli, Director of Content - innoviHealth
Sep 8th, 2025

The Office of Inspector General (OIG) recently released a report entitled “Billing for Remote Patient Monitoring in Medicare Analyzing Medical Practices’ Billing Patterns”. Remote physiologic monitoring services (codes 99091, 99453, 99454, 99457, and 99458) were carefully reviewed because of the significant increase from 2023 to 2024 in the number of patients receiving these services (27% increase) as well as a 31% payment increase during the same time period. There could be natural reasons for this increase, but the OIGs concern, of course, is fraud. Is all of this growth legitimate? To make that assessment they looked at the following:

1. Is this an established patient?
2. Was treatment management provided?
3. Do several providers bill for the same patient?
4. Is more than one device being reported?

The first thing they reviewed was the need for a prior relationship with the patient. According to their report, for Medicare beneficiaries, this can be established by either having an in-person service OR or a telehealth service. It should be noted that Medicare Advantage plans or other payers may have different requirements. According to their report, there were many organizations which did NOT meet this requirement.

The second item reviewed was the “treatment management” requirement for codes 99457 and 99458. To report these codes, the provider must meet the time requirements (i.e., at least 20 minutes for 99457) per month using the collected data to make decisions about the patient’s treatment AND interactively communicate with the patient about their care. This means that the OIG reviewed documentation to determine if these components were met. A patient may be enrolled in the program, but unless the treatment management requirement is met and documented in the medical record, then the service may not be billed.

Thirdly, they looked at the number of practices billing these monitoring services at the same time for the same enrollee. The report stated that “when practices bill for the same enrollees as two or more other practices, it raises concern that they are billing for services that are unnecessary.”

The last thing they reviewed was the number of devices being billed. The report used the example of a patient having both a connected blood pressure cuff AND a connected weight scale. Both of these devices send information to the provider. The report stated that “Medicare generally allows practices to bill for only one remote patient monitoring device per month per enrollee.” Ensuring compliance on this point can be difficult for an organization since the patient may not realize that they have signed up for these services at more than one provider’s office. Complicating things even further, a cardiologist may be monitoring the patient’s blood pressure, but the primary care provider may be monitoring the weight.

Keep in mind that this report is only regarding claims submitted to Medicare. However, when the OIG reports on findings like this, other payers often follow suit. Because of this, organizations need to take time to carefully review the findings and ensure that their policies and procedures are appropriate when billing these services.