Report sheds light on remote patient monitoring

In April, the Peterson Center on Healthcare published a report, Evolving Remote Monitoring: An Evidence-Based Approach to Coverage and Payment, which analyzed the use of remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) from 2019 through 2023 and related benefits and billing patterns, and proposed policy changes.   

Remote patient monitoring background and payment standards

Remote patient monitoring typically involves the collection of an individual’s health data through a medical device and transmission of the information to a health care provider or staff member who analyzes the data to monitor and manage the patient’s conditions. Common remote patient monitoring modalities include RPM (monitoring and analyzing physiological metrics, such as blood pressure, blood sugar, oxygen saturation or weight) and RTM (monitoring non-physiological data relating to therapeutic treatment, such as respiratory or musculoskeletal system status, therapy adherence, therapy response or pain levels). 

Medicare pays for RPM and RTM under three main components of CPT billing codes:

• patient education and device setup
• medical device supply with collection and transmission of health data, at least 16 days in a 30 day period
• treatment management involving review of the collected health data and use of the data in managing the patient’s condition for at least 20 minutes in a month.

RPM and RTM services are often furnished by clinical staff under the supervision of a physician, advanced practice registered nurse, physician assistant, or in some cases other qualified health care providers, such as a physical or occupational therapist. The principal RPM and RTM codes and national Medicare non-facility rates are summarized in the two tables below. 

CPT code	RPM Description	Time	Medicare Rate
99453	patient education and device setup	Initial setup	$19.73
99454	monthly medical device supply and transmission with daily recording(s) or programmed alert(s)	At least 16 days in 30 days	$43.02
99457	RPM treatment management services, including interactive communication with the patient/caregiver	20 minute monthly minimum	$47.87
99458	RPM treatment management	Additional 20 minutes	$38.49
99091	collection and interpretation of physiologic data	30 minute minimum	$51.75

CPT code	RTM Description	Time	Medicare Rate
98975	patient education and device setup	Initial setup	$19.73
98976	monthly medical device supply and transmission to monitor respiratory system	16 days in 30 day period	$43.02
98977	Monthly medical device supply and transmission to monitor musculoskeletal system	16 days in 30 day period	$43.02
98978	monthly medical device supply and transmission to monitor cognitive behavioral therapy	16 days in 30 day period	Contractor-priced
98980	RTM treatment management services, including interactive communication with the patient/caregiver	20 minute monthly minimum	$50.14
98981	RTM treatment management	Additional 20 minutes	$39.14

Coverage for RPM and RTM by Medicaid and private payors varies.

The American Medical Association (AMA) CPT Editorial Panel in September 2024 approved revisions to existing RPM and RTM codes as well as the creation of new RPM and RTM  codes. The new codes are expected to allow payment for supplying a medical device if data is collected 2 to 15 days in a 30-day period (reduced from the current 16-day minimum) and for treatment management for 10 to 19 minutes in a 30-day period  (reduced from the current 20-minute monthly minimum).  These new codes and revisions are scheduled to take effect January 1, 2026, and would expand  RPM and RTM billing opportunities if adopted by the Centers for Medicare and Medicaid Services (CMS) and other payors. 

Evolving Remote Monitoring report

The Evolving Remote Monitoring report analyzed the use and billing of RPM for Medicare and Medicaid patients from 2019 (when Medicare began paying for RPM) through 2023 and the use of RTM in 2022 (when Medicare began paying for RTM) and 2023, with particular focus on the use of RTM to treat musculoskeletal disorders and RPM for diabetes and hypertension, which the authors identified as the three most common principal diagnosis codes for RTM and RPM.

The authors found that in 2023 only a small portion (approximately 1%) of traditional Medicare beneficiaries received RPM services and fewer than 0.2% of Medicare beneficiaries received RTM services, but that the use of both RPM and RTM have expanded rapidly since Medicare began paying for RPM and for RTM. Medicare RPM expenditures grew from $6.8 million in 2019 to $194.5 million in 2023, due to increases in both the number of beneficiaries receiving RPM (a tenfold increase, from 44,500 to 451,000) and the duration of RPM services (the average duration of RPM increased from 1.7 months to 5.2 months).  RPM use for Medicare Advantage and Medicaid also increased, although the data was less current.

These findings are generally in line with the September 2024 report of the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services, which noted a tenfold increase from 2019 to 2022 in the number traditional Medicare and Medicare Advantage patients receiving RPM services, and a twentyfold increase in traditional Medicare and Medicare Advantage payments for RPM.

RTM use and expenditures also increased, although the numbers were available only for two years (Medicare began paying for RTM in 2022), and only one year (2023) for RTM cognitive behavioral therapy. RTM spending in traditional Medicare increased from $2.2 to $10.4 million from 2022 to 2023.

The analysis of billing patterns found that RPM and RTM have been used to monitor a variety of conditions. Hypertension (57%) was the most common principal diagnosis for traditional Medicare patients who received RPM in 2023, followed by diabetes (13%) and sleep-wake disorders (6%), with seven other conditions between 2% and 4% of traditional Medicare beneficiaries who received RPM. Musculoskeletal disorders (59%) were the most common principal diagnoses for Medicare beneficiaries who received RTM in 2023, followed by respiratory disorders and hypertension (5% each), sleep-wake disorders (4%), nervous system signs and symptoms (4%), and six other conditions between 1% and 3%.  Mental and behavioral health disorders were the principal diagnoses for only 1% of traditional Medicare patients who received RTM in 2023, although Medicare began paying under the RTM supply code (98978) for cognitive behavioral therapy in 2023.  

The report points to evaluations of diabetes, hypertension and musculoskeletal conditions revealing that remote patient monitoring technologies can improve outcomes and reduce spending, but that clinical effectiveness and duration of benefit vary significantly based on condition. For example, the authors observed that RTM improves patient musculoskeletal outcomes during targeted physical therapy episodes of two to four months, but ongoing use of RTM for most musculoskeletal conditions is not supported by the evidence, and that clinical benefits depend on the provider engaging with the data and being able to act on the information to improve outcomes, such as by quickly adjusting hypertension medication based on blood pressure readings.

Although only a small minority of patients received RPM or RTM in 2023, the rapid expansion of RPM and RTM since these billing codes were introduced, the prevalence of conditions (such as hypertension, diabetes and musculoskeletal disorders) that can benefit from RPM or RTM, and the lack of limits on duration of payment, the authors note the potential for exponential growth in spending for remote patient monitoring.  The authors recommend payment RPM and RTM policy changes, including:

• Payor development of condition-specific billing guidelines to align coverage and payment with clinical benefits, such as adopting time limits and tying coverage and payment rates to medical conditions based on clinical effectiveness
• Promoting the use of high-impact remote monitoring tools and services, minimizing or eliminating the use of poorly performing digital applications, and providing patients with access to appropriate RPM and RTM digital tools
• Requiring RPM and RTM claims and encounter submissions to include information on the digital solutions used, the data collected, the conditions treated or monitored, and the identity of the ordering provider.

Some of these suggestions overlap with recommendations by the OIG in its September 2024 report on RPM that CMS expand its oversight of remote patient monitoring and that claims and encounter data capture additional information. The OIG observed that a lack of transparency and key information regarding remote patient monitoring devices, providers ordering and furnishing the monitoring, data collected, conditions monitored, and related issues limit the ability of CMS to ensure that billing requirements are satisfied, assess the effectiveness of remote patient monitoring and implement future changes.  

For more information on remote patient monitoring and related issues, please contact attorney Rick Hindmand.