We recently hosted a webinar diving into remote patient monitoring compliance. Our webinar was designed to provide attendees with knowledge on how to better maintain compliance with CMS regulations. The program was prompted in part by the increased federal scrutiny into non-compliant RPM programs. If you missed the webinar, don’t worry. You can still watch "Crash Course on Remote Patient Monitoring Program Compliance” on demand and learn how to better ensure your RPM program meets regulatory standards.*
The webinar was very well attended, and many attendees asked excellent questions that we did not have time to address during the live program. To further help you ensure remote patient monitoring compliance, we provide answers to many of those questions below, organized by topic.
RPM Enrollment and Device Setup (CPT 99453)
Q: Can I bill 99453 more than once if a device is replaced?
A: CPT 99453 is a one-time code billed for patient education and device onboarding. If a brand-new device (different model or function) is issued and requires re-education, 99453 can be billed again. However, replacing a broken unit with the same device does not warrant a second 99453.
Q: Does 99453 require 16 days of readings?
A: While CPT 99453 strictly covers patient set-up and device education, it can only be billed following a 30 day period with 16 days of data collected. We typically recommend billing 99453 at the same time you bill your first 99454 for a patient.
Note: For more information on 99453, read our Guide to RPM CPT Code 99453: Initial Setup and Patient Education.
RPM Supply Code (CPT 99454)
Q: Is 99454 billed once or monthly?
A: CPT 99454 is a recurring code that covers device supply and daily transmission. It’s billed once every 30 days, assuming the device records and transmits at least 16 days of data within that time frame.
Q: What happens if the 16-day threshold isn’t met?
A: CPT 99454 cannot be billed if 16 days of data aren't transmitted during the 30-day period. However, 99457 can still be billed if at least 20 minutes of care management is delivered, including at least one interactive communication.
Q: When billing 99454 in February, is there an exception for only having 28 days in the month?
A: The number of days in a month has no impact on billing CPT 99454. Providers should be tracking when a 30-day period has been completed and billing accordingly, not necessarily when a month has completed. Simply put, the 16-day threshold in a 30-day period still applies for February despite the month only having 28 days. Good RPM software will help providers ensure they are billing at the appropriate times.
Note: For more information on 99454, read CPT Code 99454: Guide to Monthly Device Supply & Data Transmission.
Interactive Communication and RPM Time Codes (99457, 99458)
Q: What qualifies as "interactive communication" for remote patient monitoring?
A: Interactive communication means a live phone or video call between a clinician and the patient or the patient’s caregiver. Voicemails, emails, or text messages do not count toward this requirement, although time spent managing the care still counts toward the 20-minute threshold required for billing CPT 99457.
Q: Do we need to spend the full 20 minutes in interactive communication?
A: No. The 20-minute requirement includes non-face-to-face care management time. However, at least one interactive communication must be part of those 20 minutes to bill CPT 99457. Additional time beyond the initial 20 minutes can be billed under CPT 99458 in 20-minute increments.
Q: Can we continue to bill 99457 and 99458 if we speak directly to a patient but they only have one day of data?
A: You can still bill for CPT 99457 and 99458 if the patient fails to reach 16 days worth of readings. If the patient has two or more chronic conditions, they might be a better candidate for support provided via a chronic care management (CCM) program if device compliance is a challenge. Reimbursement rates are slightly higher for CCM.
Note: For more information on 99457 and 99458, read Guide to CPT 99457: Understanding the Code for Initial 20 Minutes of RPM and Guide to CPT Code 99458: Additional 20 Minutes of Care Management.
RPM Coding and Billing Cadence
Q: Do RPM codes follow calendar months or rolling periods?
A: RPM billing varies by code:
- CPT 99453 can be billed one-time per patient per episode of care
- CPT 99457 and 99458 follow the calendar month.
- CPT 99454 follows a rolling 30-day cycle.
For ease of workflow, many providers choose to sync all RPM billing to a calendar month.
Q: Can you bill 99453 and 99454 right after capturing 16 days of data?
A: You can bill CPT 99453 and CPT 99454 once the 16-day threshold is met, even before the full 30 days, during the first eligible month. After that, 99454 should be billed every 30 days.
RPM Documentation Requirements
Q: Is Prevounce’s built-in care plan and consent documentation sufficient to meet CMS requirements?
A: Yes. The embedded documentation tools within the Prevounce platform fulfill CMS requirements for care plans and consent. Providers may choose to add more detail for internal documentation purposes, and we can help set up templates or micros.
Q: How often does medical necessity need to be documented?
A: There’s no defined CMS frequency for medical necessity, but annual documentation is a good best practice. A note in the patient chart during a routine office visit confirming continued clinical relevance is often sufficient.
Q: What documentation is required for time logs?
A: Time spent must be accompanied by detailed notes indicating how the time was used. Notes should include communication efforts, care plan updates, and patient progress. Software can help with compliance. For example, using Prevounce’s built-in time tracking and activity logs simplifies this process.
Direct Supervision Requirements
Q: Can a vendor staff member deliver RPM services under 99457 and 99458?
A: Yes, clinical staff operating under the direct supervision of a billing provider can deliver RPM services. The billing must be submitted under the supervising provider’s national provider identifier (NPI). Vendors must either work within this model or operate as an independent clinic with their own supervising provider.
Device Transmission and Patient-Entered Data
Q: What if the patient takes their blood pressure using a digital cuff and manually enters the reading into an RPM app?
A: Manual entry by the patient is considered self-reported data and is not billable under RPM CPT codes. For remote patient monitoring to qualify for reimbursement, the device must automatically and directly transmit readings to the care team without any patient transcription or data entry.
Smart Devices and Consumer Wearables
Q: Can smartwatches be used for RPM?
A: Consumer wearables can be used for RPM if the device transmits data directly and automatically through a third-party integration that is consented to by the patient. The key is that the data must be clinically relevant and automatically transmitted, not manually entered.
Q: Are CGMs and wearables billable under RPM codes?
A: Continuous glucose monitors (CGMs) have their own separate billing codes and are not included under the traditional RPM code set (99453, 99454, 99457, and 99458). While RPM doesn’t cover CGMs, other personal devices — such as smartwatches — can be used if data transmission and clinical relevance criteria are met.
Encouraging Patient Compliance
Q: How can we increase patient compliance with the requirements for RPM coding and billing?
A: Start by understanding what’s getting in the patient’s way of being an active, engaged participant in the RPM process. Then tailor your outreach and support to address those roadblocks. Personalized motivation based on patient-specific challenges often drives better engagement.
Chronic Care Management (CCM)
Though our webinar was focused on building and maintaining compliant RPM programs, many of our clients run CCM programs in tandem with their RPM program. This integration leads to better patient outcomes, improved care coordination, and enhanced revenue.
Q: Can you send messages via EMR or text and count that time for CCM billing?
A: Yes. Time spent sending and responding to secure EMR or HIPAA-compliant messages can count toward the total time required for CCM (CPT 99490), but it does not count as interactive communication.
Q: Can RPM and CCM be billed for the same patient in the same month?
A: Yes, but you cannot count the same time for both services. For example, time spent managing a device-monitored condition might be billed under RPM, while broader care management activities like diet, medication, or community resources might be billed under CCM.
Did You Miss Our Crash Course? Watch it Here!
Ensuring your RPM program meets regulatory standards is crucial for long-term sustainability and success, and our “Crash Course on Remote Patient Monitoring Program Compliance” on-demand webinar is designed to give you the knowledge and tools you need. This program provides attendees with knowledge on how to build and manage an RPM program that's always compliant with Medicare rules. Watch it now here.
If you would like to schedule a free audit of your existing RPM program, book a consultation with one of our remote patient monitoring experts.
* Disclaimer: The above information 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.