On August 28, 2025, the U.S. Department of Health and Human Services’ Office of the Inspector General (OIG) issued the report “Data Snapshot: Billing for Remote Patient Monitoring in Medicare.” The report highlights the explosive growth of RPM services in 2024, citing key data points gathered in a review of Medicare billing for these services over the past year. The report reiterates and renews OIG’s calls for increased oversight of RPM as a potential hotbed for healthcare fraud. In this article, we break down key takeaways from the report and proactive steps for providers to prepare for increased regulatory scrutiny of RPM billing.

About the Report

The report details statistics for over 4,600 medical practices that routinely billed for remote patient monitoring throughout 2024. To identify the extent of the potential for fraudulent billing in RPM, the report evaluated RPM billing trends for these practices using 5 metrics:

1. New Enrollees: OIG looked at the number of new enrollees for whom practices billed each month, making note of any providers with sudden month-over-month increases.
   • Findings: Data demonstrated that on average, the medical practices studied billed for RPM services for about 70 patients per month, with an average of 5 new enrollees added each month. Of the 4,600 practices studied, 32 had a month-over-month increase in new enrollees of 150% or more, with one practice billing for 3,400 new enrollees in a single month.
2. Prior Relationships: OIG reviewed historical patient data to determine the proportion of enrollees who did not have a prior relationship with the practice before RPM billing began. Practices who had an in-person or telehealth visit with a Medicare patient between 2021 and the first date of RPM billing were considered to have a prior relationship with the patient.
   • Findings: Most practices had a prior relationship with enrollees prior to billing for RPM services. However, many medical practices did not have prior relationships with more than 80% of their patients.
3. Treatment Management: This metric was used to determine the percentage of patients who were billed for RPM services but never received treatment management in 2024. Treatment management refers to a provider’s review of enrollee data to make and communicate decisions regarding patient care.
   • Findings: A number of medical practices did not bill any treatment management services for more than 75% of patients, suggesting that RPM was not appropriately used for condition management.
4. Billing for Enrollees Common to Other Practices: This metric evaluated whether multiple practices billed for RPM services for the same patient.
   • Findings: OIG found that the “vast majority” of practices did not bill for RPM for the same enrollees as two or more other practices. However, some practices were identified as having more than 25% of their RPM enrollees in common with other practices.
5. Billing for Multiple Devices per Enrollee: OIG tracked the number of times practices billed for multiple RPM devices within the same month.
   • Findings: Few practices were found to have billed for two or more devices per month per enrollee.

Key Findings

The OIG’s report reveals several key insights about key fraud risks for RPM, as well as insights into how OIG and other regulators may seek to evaluate practices for RPM billing fraud. For one, the report reiterates that the use of RPM services only continues to grow. Medicare paid more than $500 million for RPM services for beneficiaries last year, with nearly 1 million beneficiaries receiving some form of RPM. Further, the report discusses new metrics developed by OIG to identify RPM fraud, a helpful insight for providers seeking to conduct billing audits and develop plans to ensure compliance with Medicare billing requirements.

Importantly, the report makes clear that OIG and other regulators continue to view RPM services as a focus of federal fraud prevention efforts. With that in mind, providers who offer RPM services must remain vigilant in working to identify and prevent billing fraud before it happens.

Takeaways for Providers Who Bill Medicare for RPM Services

The OIG's report is a clear signal that increased oversight and audits are on the horizon. To mitigate risk and ensure compliance, providers should take proactive steps to strengthen their billing practices and documentation.

• Expect Increased Scrutiny: The OIG's focus on data-driven targeting means that providers with unusual billing patterns are more likely to be flagged for review. Be prepared for heightened oversight from Medicare Administrative Contractors (MACs) and special investigation units.
• Validate Patient Eligibility and Relationships: Ensure that you have a bona fide prior relationship - whether established through an in-person or telehealth visit - with every patient before initiating RPM services.
• Strengthen Documentation: To prepare for future audits, providers should ensure that their practices have thorough documentation policies in place to ensure a thorough record for every patient encounter. Having clear, detailed documentation that includes the patient’s consent, condition, and rationale indicating that RPM services are medically appropriate is your best defense in an RPM audit.
• Monitor Enrollment Velocity: A sudden, significant increase in new patient enrollments could be a red flag. Implement internal reviews and controls to ensure that any enrollment spikes are clinically appropriate and well-documented.

Health Law Alliance: Your Trusted Audit Defense Team

Navigating audits from federal regulators can be complicated, stressful, and challenging. Staffed by a team of ex-federal prosecutors, UPIC supervisors and MAC medical directors, our team at Health Law Alliance have years of proven experience handling government audits. We utilize our firsthand knowledge to help your practice prepare for scrutiny from any payor. Whether you need advice on preventing billing risks or have auditors knocking on your door, we’re on your side and ready to help.