On September 24, 2024, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) released a pivotal report titled “Additional Oversight of Remote Patient Monitoring in Medicare Is Needed”.1 The report scrutinizes the rapid expansion of service coverage for Remote Patient Monitoring (RPM) by the Centers for Medicare & Medicaid Services (CMS) while calling attention to vulnerabilities in billing practices, service delivery, and the potential for fraudulent activities. In its report, the OIG offers specific guidelines aimed at strengthening the oversight mechanisms employed by CMS.1 This Viewpoint aims to discuss the development of the OIG report as well as the implications thereof to patients, providers, and the RPM service industry at large.
In recent years, RPM has experienced considerable growth in the USA, influenced by several factors including the rising burden of chronic diseases, the proliferation of consumer-grade wearable health devices, and the expansion of telehealth reimbursement policies. Early RPM initiatives focused on monitoring vital signs to facilitate chronic disease management and reduce hospital readmissions. However, RPM has since manifested in a wide range of clinical contexts and patient populations, from postpartum care to mental health and post-operative recovery.
In particular, RPM has swiftly become a cornerstone of the “Hospital-at-Home” chronic care paradigm, one which enables the management of chronic and acute conditions outside traditional hospital settings.2 The utility of RPM for this purpose was alluded to over 70 years ago by psychologist Egon Brunswik whose scholarship recognized that patient outcomes are shaped by a diverse array of contextual factors that are often unaccounted for in the context of the traditional laboratory, clinic, or hospital environments.3 This vision underscores the potential of RPM to clarify and redress environmental influences on patient health outside traditional care settings.4 To this end, a common hallmark of current RPM programs is the integration of home-based medical devices (e.g., blood pressure cuffs, glucometers, pulse oximeters) with cloud-based analytics platforms and secure data-sharing interfaces. These systems enable continuous or intermittent monitoring and real-time feedback loops. Concurrently, patient engagement strategies—such as in-app coaching, educational modules, and automated reminders—are increasingly woven into RPM platforms, reinforcing medication adherence and self-management behaviors.
Despite these advantages, patients may encounter barriers to using digital health tools, including limited technological literacy and unreliable internet.5 For providers, smaller practices may lack resources needed to train staff and adapt existing systems, compounding administrative burdens and liability risks.5 Nonetheless, with continued policy support—reflected in Medicare coverage expansions—and ongoing technological refinements, RPM holds promise for improving health outcomes and patient satisfaction on a broader scale.
There are a number of potential strategies to overcome the aforementioned obstacles associated with RPM implementation. First, healthcare organizations can invest in user-friendly platforms that integrate seamlessly with electronic health records (EHRs), minimizing data overload for providers and improving continuity of care. By refining alert systems and automating data prioritization, these platforms can help providers focus on the most clinically relevant patient information rather than being overwhelmed with excessive notifications. Second, training programs and digital literacy initiatives—particularly for older adults and underserved populations—can help close the technology gap. Providing personalized onboarding support, step-by-step guidance, and access to technical assistance can ensure that patients feel comfortable using RPM tools as part of their care routine. Third, expanding reimbursement structures will be key to driving adoption. Developing sustainable payment models that cover not only device costs but also training, ongoing monitoring, and patient support can help make RPM more accessible. Finally, strengthening data security to address privacy concerns is needed. Implementing stronger encryption methods, multi-factor authentication, and secure data storage solutions can enhance patient confidence in remote monitoring. Ensuring that patients have clear information about how their data is used, stored, and protected will also help build trust and encourage broader participation.”
Since CMS expanded the coverage of RPM services in 2018, substantial investment in RPM technologies has taken place by dint of their potential to improve patient outcomes via proactive management, enhanced health equity, and reduced healthcare costs—particularly for those with chronic conditions or high caregiving needs.1 More recently, the COVID-19 pandemic accelerated the adoption of RPM at a time when healthcare systems sought to minimize hospital-acquired infections as well as accommodate the increased demand for at-home care.1 Legislative and executive actions, including the extension of the RPM-related CMS policies through December 31, 2024, and the introduction of new Current Procedural Terminology (CPT) reimbursement codes, further supported the growth of RPM and its integration.1
Despite its promise, the rapid expansion of RPM has also raised concerns about the potential for fraudulent billing practices and the integrity of service delivery. It is in this context that CMS mandated three service components for RPM so as to ensure consistency in delivery and billing: (1) patient education and setup, (2) device supply, and (3) treatment management.1 The OIG report, for its part, highlighted that approximately 43% of CMS enrollees who are utilizing RPM did not receive all three of the aforementioned mandated components, as determined by claims data review. This method may not fully reflect real-world service delivery but nonetheless presents a potentially concerning trend.1 Furthermore, the OIG report highlights significant risks related to fraudulent billing, such as enrolling beneficiaries without medical necessity and/or charging for inadequate monitoring services.1 Such issues appear to be compounded by the lack of comprehensive data on the types of health parameters that are being monitored by RPM, the devices used in this context, and the provider(s) ordering the RPM services in question.
The OIG report goes on to offer recommendations intent on fortifying the oversight of CMS-covered RPM services, such as mandating the inclusion of the ordering provider information on RPM claims thereby increasing transparency.1 Additionally, the OIG advocates for the development of new Healthcare Common Procedure Coding System (HCPCS), that is, procedural codes or modifiers to better track the specific types of health data being monitored with an eye towards aiding compliance verification.1 To further mitigate fraud risks, the OIG report recommends the use of advanced data analytics to identify and flag suspicious billing patterns.1 Finally, the OIG underscores the importance of national provider education initiatives so as to bridge gaps in the understanding of proper RPM use and billing.
The release of the OIG report elicited mixed reactions from stakeholders within the healthcare community. Arguments were made to the effect that the concerns raised by the OIG may stem from misunderstandings of RPM billing protocols.6 Moreover, concerns have been raised with respect to the possibility that the OIG interpretation of billing requirements and data collection thresholds may not account for the diverse nature of RPM applications across the medical spectrum—particularly in clinical scenarios wherein extensive and regular monitoring may prove unnecessary.6 This ongoing debate underscores the need for collaborative efforts between regulatory bodies, healthcare providers, the health services research community, and advocacy groups with an eye towards refining RPM oversight without stifling its potential benefits.
IMPLICATIONS FOR BUSINESSES, PROVIDERS, AND PATIENTS
Enhanced oversight and stricter billing requirements are likely to increase the regulatory burden on RPM providers and adopters by necessitating investments in compliance infrastructure and billing accuracy systems. Startups entering the RPM space may face higher entry barriers if they are to navigate complex billing protocols and implement robust data tracking mechanisms to meet CMS and OIG standards. Market consolidation may well result. It follows that health systems and established RPM companies might experience heightened scrutiny through more frequent audits and claims reviews. In time, however, this ideally may prompt a shift towards more transparent and accountable billing practices.
For providers, the OIG report calls for rigorous adherence to RPM billing protocols so as to avoid potential audits and penalties and thus increasing the administrative burden associated with compliance. Providers may also be compelled to invest in enhanced documentation systems and staff training to meet the requisite needs. Such heightened scrutiny could lead to operational challenges, particularly for smaller practices. On the patient side, more comprehensive RPM service delivery may support improved health outcomes and reduced hospital readmissions. That said, the RPM industry must be mindful of how increased regulatory oversight may result in some providers limiting or discontinuing RPM services which in turn may curtail benefits for patients who may otherwise face barriers to accessing care. In fact, the only US-based randomized controlled trial of Hospital-at-Home care utilized robust RPM—highlighting its inextricability from these novel models of care.7
FUTURE DIRECTIONS: ADVANCING RESEARCH, POLICY, AND PRACTICE IN REMOTE PATIENT MONITORING
Looking forward, research efforts should focus on evaluating the integration of RPM with traditional care models and on assessing the impact of specific RPM technologies on various chronic and acute conditions. For example, greater evidence is necessary to determine which RPM modalities are most beneficial—and which may be superfluous—for various patient sub-populations in Hospital-at-Home settings. Establishing best practices through evidence-based investigations will not only clarify clinical applications but also ensure that regulation and billing policies closely follow the science, promoting more precise and impactful RPM adoption. Additionally, it is crucial to investigate the barriers to comprehensive service delivery as identified by the OIG such as incomplete billing practices and variability in service components which may require the development of targeted interventions that enhance the fidelity and effectiveness of RPM programs. With respect to policy reform, CMS should not only implement the OIG recommendations but also consider policies that lower billing thresholds and offer flexible billing options for different medical conditions, thereby reducing administrative barriers to RPM adoption. Collaborative efforts between CMS, the American Medical Association (AMA), and other stakeholders may prove essential to the refining of billing guidelines, ensuring that these are both comprehensive and adaptable to the evolving RPM landscape. Furthermore, healthcare providers must prioritize the integration of RPM into their routine workflow by adopting standardized protocols for service delivery and billing, investing in interoperable RPM platforms that facilitate seamless data exchange, and foster a patient-centric approach through clear communication, informed consent, and robust data privacy and security measures. The aforementioned steps are vital for maintaining trust and maximizing the benefits of RPM for patient care and for proactive health management.
Ultimately, the future of RPM hinges on a balanced approach that combines rigorous oversight with supportive measures to promote innovation and accessibility. At the same time, there must be vigorous enforcement of fraudulent activities to discourage misuse, safeguard patients, and maintain public confidence in RPM. By advancing research, refining policies, and enhancing clinical practices, stakeholders can ensure that RPM continues to evolve as a valuable tool in improving patient outcomes, reducing healthcare costs, and expanding access to high-quality care for CMS beneficiaries.
Declarations
Conflict of Interest
The authors declare that they do not have a conflict of interest.
Footnotes
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References
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