*Watch our "Crash Course on Remote Patient Monitoring Program Compliance” on-demand webinar to learn how to better ensure your RPM program meets regulatory standards.*
In August 2025, the Office of Inspector General (OIG) released a new data snapshot on Medicare billing for remote patient monitoring (RPM), showing continued growth in use and billing patterns that warrant additional oversight.
This latest report builds on OIG's September 2024 review, which raised concerns about companies offering RPM without other clinical care and the rapid rise in billing. Following that review, the OIG announced in December 2024 that it would audit Part B RPM services through 2025 to determine whether providers were furnishing and billing in accordance with Medicare requirements.
Billing Measures Identified From the 2025 OIG Report
In its new report, the OIG noted that while RPM can expand access to care and improve outcomes, the rapid growth and potential for abuse prompted the office to examine billing patterns and propose a few "billing measures" that Medicare can use to help find improper claims and fraud.
As the report states, RPM use rose in 2024, with Medicare payments exceeding $500 million, a 31 percent increase from the prior year. Nearly 1 million beneficiaries received RPM services, a 27% increase from 2023. Further, RPM service numbers are expected to continue to rise with growing proof of clinical value and a significant expansion of RPM Medicare coverage set for 2026. The OIG noted that roughly 4,600 medical practices "routinely" billed for RPM in 2024, with routinely defined as a practice with at least 10 patients enrolled in RPM at some point throughout the year. In total, the OIG identified nearly 10,400 medical practices billing for at least one RPM service in 2024.
While most medical practices billed appropriately, OIG's analysis of those routinely billing for RPM identified the following patterns the agency is suggesting be used as the ongoing billing measures to help detect improper billing.
Measure 1: RPM billed without an existing patient relationship
Medicare requires an existing patient relationship be formed between the patient and provider prior to enrolling the patient in an RPM program. The OIG identified 45 five practices that billed for RPM for patients with whom they had no documented in-person or telehealth history. Except for rare circumstances, this means there was no existing patient relationship. The most egregious example cited by the OIG was a single practice with more than 30,000 enrollees without a prior relationship.
It is very likely that these practices which the OIG believes are running afoul of the existing patient relationship requirement are actually RPM outsource vendors that are standing in as medical practices for billing purposes. The OIG referenced these in their previous report as an area of concern, and many in the industry have warned against the practice.
Measure 2: RPM patients not receiving concurrent treatment management
RPM services are billed as a device supply code (CPT 99454) and a set of treatment management codes that are billed for each 20 minutes of clinical staff time spent on a patient (CPT 99457 and 99458). The OIG is arguing that there should not be device supply codes being billed without concurrent treatment management, but this runs counter to the most recent CMS guidance. Not all enrollees may need 20 minutes of treatment management per month and a provider should not arbitrarily spend more time just to hit the code when it is not beneficial to the patient.
The OIG analysis found that although the vast majority of practices were providing treatment management services for enrolled RPM patients, 52 practices had more than 75% of their patients not receiving it.
Measure 3: Sudden spikes in patient enrollment
The OIG found that 32 practices showed rapid growth in RPM enrollment of at least 150% in a single month. They cite one particular practice which enrolled 3,400 patients in a single month.
There are many reasons an RPM program may grow quickly, particularly when a new program is launched or an existing program is expanded to a new patient cohort or disease state. Substantial increases are more likely to draw scrutiny from CMS, as they may suggest problematic actions, but such swings alone do not indicate rulebreaking.
Measure 4: Billing for two or more devices on the same patient
Medicare only covers a single RPM device per patient per month. The OIG cites concerning instances where practices billed repeatedly for two or more devices, which would be squarely against the current rules. It is a little unclear how this happened, as there is logic implemented on the Medicare side to proactively deny claims for multiple device codes (99454) submitted within the same 30-day period.
Measure 5: Billing for two or more devices on the same patient
Similarly to the double device measure, OIG also noted that 34 practices billed for RPM on the same enrollees as two or more other practices. It is unclear how this happened, as there is logic implemented to deny claims when a second provider attempts to bill RPM for the same patient in the same month.
Conclusion
While the OIG raises some valid concerns, it is notable how few instances of fraud their review uncovered relative to the preliminary report released last year. This new report does highlight some billing patterns that merit closer review, but it also makes clear that the vast majority of medical practices are in compliance with Medicare requirements, or at least are close enough that the fraud is not apparent from population-level claims data.
Unlike the more high-profile September 2024 report, this data snapshot was released with less attention, but it reinforces that RPM's growth trajectory will keep the service under ongoing scrutiny. For providers, this underscores the importance of working with compliance-focused partners when outsourcing RPM programs and ensuring coordination of care management between the vendor and the practice.
Organizations should remain attentive to regulatory updates while continuing to leverage the benefits of RPM for patient care. OIG's findings should not discourage providers from starting or expanding good-faith RPM programs but rather highlight the need to build them on a strong foundation of compliance and oversight.
* Disclaimer: This presentation is for informational purposes only and does not constitute legal or other professional advice. Billing and coding requirements – especially in the telehealth space – can change and be reinterpreted often. You should always consult an attorney and/or medical billing professional prior to submitting claims for services to ensure that all requirements are met.