OIG report identifies remote patient monitoring billing compliance concerns

On August 28, 2025, the Office of Inspector General (OIG) of the Department of Health and Human Services posted Billing for Remote Patient Monitoring in Medicare, which confirm the continued expansion of remote physiological monitoring (RPM) and highlight potentially suspect RPM billing practices that the OIG views as warranting scrutiny.

See "Report sheds light on remote patient monitoring" for background on RPM and remote therapeutic monitoring (RTM).

With regard to RPM usage, the OIG found that Original Medicare and Medicare Advantage payments for RPM increased to $536 million in 2024 (a 31% increase from 2023) and that nearly one million Medicare enrollees received RPM in 2024 (a 27% increase from 2023). This continued the growth trend for RPM since 2019.  

The analysis found that 10,388 medical practices billed at least one RPM service in 2024 for Original Medicare or Medicare Advantage enrollees, and 4,639 medical practices routinely billed for RPM, meaning that each of those practices billed for 10 or more Medicare enrollees and more than 100 RPM services in 2024.

This report identified the following billing patterns as warranting scrutiny:

• large sudden spikes in RPM billing by a medical practice
• billing for a high proportion of patients who had no prior history with the medical practice
• billing for multiple monitoring devices a month for a patient
• billing under supply and transmission RPM codes for a high percentage of patients who did not receive RPM treatment management services
• billing by multiple medical practices for RPM furnished to the same patient.

This report appears to be a follow up to the September 2024 OIG report, which recommended that the Centers for Medicare & Medicaid Services (CMS) expand its oversight of remote patient monitoring and revealed that the OIG was examining remote patient monitoring and intended to issue a companion evaluation identifying remote patient monitoring billing patterns that may be indicators of fraud, waste, and abuse.  In this 2025 report the OIG reiterated the importance of implementing the recommendations in the OIG’s 2024 report to strengthen oversight of RPM services.

This 2025 report and the 2024 OIG report focus on RPM, and not RTM, although similar concerns are likely for RTM.

The OIG noted that it did not conduct a medical record review and that the analysis did not confirm whether any particular medical practice is engaging in fraudulent or abusive practices or fails to meet RPM billing requirements.  Nevertheless, this report, coming on the heels of the OIG call less than a year ago for additional oversight of RPM billing and the late 2023 remote cardiac monitoring false claims settlement and OIG remote patient monitoring Consumer Alert, and a June 2025 RPM false claims settlement, should serve as another reminder to be prepared for increased scrutiny of RPM and RTM billing. 

For RPM and RTM compliance tips, see our "Practical Compliance Playbook: Steps to Reduce Audit Risk."

For more information on remote patient monitoring and related issues, please contact McDonald Hopkins Healthcare Practice Group's Rick Hindmand or Rachel Carey.