OIG's September 2024 report found about 43 percent of Medicare RPM enrollees did not receive all three components (setup, device data, treatment management) and Medicare could not see who ordered monitoring. Its August 2025 follow-up found RPM payments over $500 million in 2024 and flagged enrollees with no prior practice history and multiple devices per month.
OIG found that remote patient monitoring (RPM) in Medicare grew quickly, that about 43 percent of enrollees who received it did not receive all three of its components, that RPM has drawn fraud concerns, and that Medicare could not even tell who ordered the monitoring. Its follow-up a year later said Medicare paid more than $500 million for RPM in 2024 and named the billing patterns that warrant scrutiny. CMS cited both reports when it proposed tightening RPM for 2027. A practice that runs OIG's checks on itself first is in a far better position than one that waits.
What did the September 2024 report find?
"Additional Oversight of Remote Patient Monitoring in Medicare Is Needed" (OEI-02-23-00260, September 2024) found:
- RPM use in Medicare "increased dramatically from 2019 to 2022."
- "About 43 percent of enrollees who received remote patient monitoring did not receive all 3 components of it, raising questions about whether the monitoring is being used as intended." The three components are education and setup, device supply with data transmission, and treatment management.
- OIG and CMS "have raised concerns about fraud related to remote patient monitoring."
- "Medicare lacks key information for oversight, including who ordered the monitoring for the enrollee."
OIG made five recommendations: more safeguards on use and billing, a requirement that RPM be ordered with the ordering provider on the claim, methods to identify what health data is monitored, provider education, and identifying and monitoring companies that bill for RPM. CMS concurred with or said it would consider all of them.
What did the August 2025 follow-up add?
"Billing for Remote Patient Monitoring in Medicare" (OEI-02-23-00261, August 2025) reported that RPM use kept growing in 2024, with Medicare payments exceeding $500 million and nearly 1 million enrollees receiving RPM. OIG developed measures to identify practices whose RPM billing warrants more scrutiny, including:
- billing for a high proportion of enrollees who have no prior history with the medical practice; and
- billing for multiple monitoring devices in a month for one enrollee.
OIG said these measures can help CMS, Medicare Advantage organizations and others find practices to look at more closely.
How did CMS respond?
In the CY2027 physician fee schedule proposed rule (91 FR 43842), CMS cited both reports and proposed:
- an initiating face-to-face visit, in person or by telehealth, at the start of RPM or RTM;
- established-patient status for RTM, as already required for RPM, citing OIG's finding that some practices had no prior relationship with the patients they billed;
- payment only when clinical staff are direct employees of the billing practice, citing third-party companies "cold calling" beneficiaries;
- a possible move to monthly G-codes that would require treatment management every month, which CMS said would ensure beneficiaries receive treatment management when they receive monitoring.
The final rule is expected in early November 2026. See the direct employee proposal.
How should a practice read these findings?
OIG has told everyone what it will measure. Each finding becomes a question about your program:
- Do your patients get all three components? A patient billed for device supply month after month with no treatment management is the 43 percent.
- Did you know the patient before RPM? Enrollees with no prior history with the practice are a named measure.
- How many devices per patient? Multiple devices are sometimes right, but each needs a clinical reason, and only one practitioner may bill device supply per patient per 30 days regardless of device count.
- Who ordered it, and why? Even before any ordering requirement, the chart should show the clinician's decision and the condition being monitored.
- Who did the outreach? Programs that recruit patients by outbound calls from a vendor look like the pattern OIG described.
Which internal reports answer OIG's questions?
- Patient-months with device supply billed but no treatment management code, by clinician.
- Patients enrolled in RPM with no visit in the practice in the prior year.
- Patients with more than one device billed in a month, with the documented reason.
- Share of enrollments that came from vendor outreach rather than a clinician's referral.
- Average monitoring duration and discharge reasons; programs where nobody is ever discharged need a look.
Run them monthly, review them with the medical director quarterly, and keep the reviews. If an auditor ever asks, the record that you looked and acted is as valuable as the numbers.
Is there a False Claims Act angle?
Yes. A claim for a service that did not meet its requirements can become a false claim, and remote monitoring has been the subject of government fraud concerns, as OIG noted. The False Claims Act basics for practices are on our billing sister site. If an internal review finds overpayments, talk to counsel about the 60-day rule for reporting and returning them.
Our RPM Program Setup ($5,950) builds these reports into the program from the start. See setting up an RPM program and pricing.
Common questions
- What are the three components of remote patient monitoring?
- Education and setup of the device, device supply with data transmission, and treatment management by the practitioner or clinical staff. OIG found about 43 percent of Medicare RPM enrollees did not receive all three.
- What RPM billing patterns does OIG watch?
- Its August 2025 report named billing for a high proportion of enrollees with no prior history with the practice and billing for multiple monitoring devices in a month for one enrollee, among other measures for identifying practices that warrant scrutiny.
- Did CMS change RPM rules after the OIG reports?
- CMS cited both reports in its CY2027 proposed rule, proposing an initiating visit, established-patient status for RTM, and payment only when clinical staff are direct employees of the billing practice. The final rule is expected in early November 2026.
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