OIG’s 2025 Report on Remote Patient Monitoring: Growth, Compliance Red Flags, and Medicare Billing Clarifications

The Office of Inspector General (OIG) has released August 2025 Data Snapshot on Remote Patient Monitoring (RPM) in Medicare. The findings highlight both the explosive growth of RPM adoption and the compliance red flags that providers, digital health vendors, and investors need to proactively address.

RPM Growth Confirms Market Validation

Medicare payments for RPM reached $536 million in 2024, a 31% increase from 2023. Nearly 1 million Medicare beneficiaries were enrolled in RPM programs last year.

This rapid growth is strong evidence that RPM is now a mainstream care delivery model for managing chronic and acute conditions. Patients are increasingly using connected devices—blood pressure cuffs, glucose monitors, weight scales—to transmit physiologic data to their providers for active management.

For innovators and investors, the OIG report is yet another market validation signal that RPM is here to stay.

OIG Flags Compliance Risks in RPM Billing

While affirming the value of RPM, the OIG also identified billing patterns that raise concerns about potential fraud, waste, and abuse:

  • Sudden spikes in new patient enrollment that may outpace a practice’s ability to provide real care.

  • No prior provider–patient relationship before RPM is initiated.

  • Lack of treatment management time (i.e., the required 20 minutes/month of provider review and patient interaction).

  • Multiple practices billing for the same patient in the same month.

  • Multiple devices billed for the same patient in the same month.

Each of these is a compliance red flag that may trigger OIG or CMS scrutiny.

Multiple Practices Billing for the Same Patient

One of the trickiest issues is two or more practices billing RPM for the same patient in the same month.

This is not always intentional. In practice:

  • A patient may forget to mention they are already enrolled in RPM when another provider asks.

  • Different specialists may order different monitoring—for example, an endocrinologist ordering glucose monitoring and a cardiologist ordering blood pressure monitoring.

Unfortunately, CMS policy is clear: RPM is billed “per patient, per month,” not per condition. Only one practice may bill RPM for a given patient/month.

This creates a knowledge gap—individual practices have no reliable way of knowing if another provider is billing RPM simultaneously.

Potential solutions could include payer-driven alerts when duplicate billing occurs, better data-sharing through health information exchanges, or EHR flags when patients are already enrolled in RPM. Until such systems exist, practices must rely on patient disclosure and careful intake processes.

The Device Supply Question: One Code, Not One Device

OIG also flagged cases of practices billing multiple devices for the same patient in the same month. Here’s the key clarification:

  • CPT 99454 is defined as “supply of device(s)” — note the plural.

  • This means a patient can have more than one device (e.g., a blood pressure cuff and a weight scale).

  • However, 99454 is billed only once per patient per month, regardless of the number of devices supplied.

Compliance risk arises only when practices bill 99454 multiple times in a month for the same patient.

Compliance Strategies for RPM Providers and Vendors

To stay ahead of OIG and CMS oversight, RPM stakeholders should:

  • Conduct proactive internal audits to identify billing patterns that could be flagged.

  • Document prior patient relationships before billing RPM.

  • Track and record treatment management time to ensure the 20-minute/month requirement is consistently met.

  • Audit 99454 billing to confirm it’s billed once per month per patient, even when multiple devices are used.

  • Update intake processes to ask patients explicitly about other monitoring programs—while recognizing disclosure gaps may remain.

FAQs: Common Questions About RPM Billing

Q: Can more than one practice bill RPM for the same patient in the same month?

No. RPM is billed on a per-patient-per-month basis. Only one practice may bill, even if multiple conditions are being monitored by different practices.

Q: Can CPT 99091 and 99457 be billed in the same month?

Yes, but only by the same provider, and only if the time spent is distinct and not double-counted. Two different providers cannot split these codes for the same patient in the same month.

Q: Can multiple devices be billed under CPT 99454?

Yes, a patient can have multiple devices, but 99454 may only be billed once per patient per month.

The Bottom Line

The OIG’s 2025 RPM report sends a dual message:

• RPM is validated as a rapidly growing, clinically significant service.

• Oversight continues to tighten, and practices must ensure billing integrity to avoid compliance risk.

Nixon Law Group advises digital health companies, providers, and investors on RPM compliance and strategy. If your organization relies on RPM as part of its care model, now is the time to review your workflows and audit your billing practices. Contact us to ensure your RPM program is both scalable and compliant.

Remote MonitoringCarrie NixonRemote Patient Monitoring, OIG