This post is co-authored by Seth Orkand, co-chair of Robinson+Cole’s Government Enforcement + White-Collar Defense Team.
On August 25, 2025, the Department of Health and Human Services Office of Inspector General (OIG) issued a new report (Report) highlighting trends in remote patient monitoring (RPM) Medicare billing, recommending stronger oversight to ensure compliance in billing for RPM services. The Report builds on OIG’s September 2024 report, which also called for increased oversight for RPM billing. OIG’s new Report highlights the rapid growth of RPM: in 2024, Medicare payments for RPM services exceeded $500 million—a 31% increase from 2023—with nearly one million Medicare beneficiaries receiving RPM services.
OIG’s Findings
The use of RPM for Medicare enrollees has grown substantially and continuously since 2019, when Medicare began widely covering RPM services. In 2019, Medicare payments for RPM were just $15 million, growing to $536 million by 2024. Just between 2023 and 2024, the number of Medicare enrollees receiving RPM services increased by 27%. Approximately 4,600 medical practices routinely billed for RPM in 2024.
The OIG Report identified trends signaling a need for improved RPM billing oversight. Certain medical practices, for example, billed for over 100 new enrollees each month, compared to an average practice’s five new enrollees per month. The Report recommended program integrity measures to better monitor the potential for fraud and abuse, and recommended that the Centers for Medicare and Medicaid Services (CMS), Medicare Advantage Organizations (MAOs), and other entities involved in auditing adopt these measures.
OIG’s Recommended Program Integrity Measures
OIG first recommended that CMS and MAOs monitor medical practices that bill for large numbers of Medicare enrollees with no prior history of a patient-provider relationship. Before a medical practice can bill for RPM services for a patient, the medical practice must have established a patient relationship through either an in-person or telehealth service (with an exception for RPM services provided without a prior patient relationship during the COVID-19 public health emergency). However, the OIG Report found 45 practices that did not have a prior medical relationship with over 80% of patients for whom they billed RPM services. OIG determined whether the patient had an established relationship with the provider by looking at the date of the first RPM service billed in 2024, and then looking back to January 1, 2021, to determine whether the enrollee had seen a provider (either in person or via telehealth) prior to the first billed RPM service. If not, OIG found that there was no prior patient-provider history.
OIG also recommended monitoring the rates at which practices bill for treatment management—a service in which a provider spends at least 20 minutes per month assessing an enrollee’s RPM data to adjust their treatment plan. Most practices were compliant, with fewer than 1% of most practices’ enrollees never receiving treatment management. However, a small number of practices never billed treatment management for 75% or more of their enrollees, suggesting an alarming lack of oversight. OIG further noted that in some cases, some enrollees were receiving RPM services from two or more medical practices simultaneously, raising concerns about medically unnecessary and duplicative care. To that end, OIG recommended that CMS and MAOs monitor how regularly a practice is billing for the same enrollees as other practices.
Finally, OIG discussed billing practices for multiple monitoring devices per enrollee. Generally, practices may only bill Medicare for one RPM device—such as a blood pressure cuff or connected weight scale—per month. But OIG found that a small number of practices were billing for two or more devices per month per enrollee. OIG suggested that this pattern may indicate double billing or billing for medically unnecessary services.
Implications and Conclusion
OIG’s Report signals that regulators may be taking a fresh look at RPM billing for Medicare enrollees. Given RPM’s meteoric growth in the past five years, it is not surprising that OIG is recommending increased scrutiny of potentially problematic billing practices. Providers should proactively review internal billing practices for RPM services and implement policies to better comply with RPM billing requirements. We will continue to monitor CMS and MAO adoption of OIG’s recommendations.