It was a big deal a few years ago when CPT created, and CMS accepted, remote monitoring codes of several types.
Part of the issue was that Medicare didn't traditionally pay for much, from a physician, that was provided explicitly "incident to" himself/herself, e.g. in the office. For example, home-use allergens for desensitization were a line-item special statutory benefit, billed by the Part B physician but used at home. And oral anti-emetics require a statutory benefit, too (1861(s)(2)(T).)
For the first couple years, there was limited usage of the remote home telemonitoring codes, at least in Medicare. And there were no LCDs to address them, either.
Look for two updates, one from the OIG, one from the Peterson Center for Healthcare. Hogan Lovells recently posted about the two reports.
HOGAN LOVELLS
Find the Hogal Lovells update here, dated April 21, 2025. It points to the Peterson Center study, and to a report last fall from OIG.
PETERSON CENTER
Find their report here. It clocks in at 24 pages.
https://petersonhealthcare.org/news/evolving-remote-monitoring-report/
OIG (Fall 2024)
Find the OIG report, "Additional Oversight Needed," 31 pages, September 2024.
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AI CORNER
Chat GPT reads the two reports and discusses.
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OIG 2024 Report: “Additional Oversight of Remote Patient Monitoring in Medicare Is Needed”
This 31-page report from the HHS Office of Inspector General (OIG) focuses on the explosive growth of remote physiologic monitoring (RPM) in Medicare from 2019 to 2022 and highlights critical oversight vulnerabilities. Key findings include a tenfold increase in utilization and a twentyfold increase in Medicare spending on RPM, mostly for chronic conditions like hypertension. Alarmingly, 43% of patients received incomplete services — lacking one or more of the three components (education/setup, device transmission, treatment management). OIG emphasizes that many services are billed without clear evidence of medical necessity, often lacking provider identifiers or condition-specific diagnoses. The report raises concerns about potential fraud, especially from companies aggressively enrolling patients without need. Recommendations include requiring provider orders, adding claim modifiers, collecting data on devices and health metrics, and conducting provider education. CMS agreed to consider most of these changes, although some require formal rulemaking.
Peterson Center 2025 Report: “Evolving Remote Monitoring: An Evidence-Based Approach”
This 24-page report from the Peterson Center on Healthcare and its research arm PHTI takes a clinical and policy reform approach, synthesizing claims analysis with rigorous evaluations of RPM and RTM (Remote Physiological Monitoring, Remote Therapeutic Monitoring) technologies. It differentiates itself by presenting condition-specific effectiveness data, showing that RPM is most effective for hypertension (notably within the first 6 months) and RTM for musculoskeletal issues (typically within 2–4 months). Diabetes RPM yielded limited long-term clinical benefit. Peterson’s data shows growth in both patient volume and episode duration, mirroring OIG’s findings. However, their focus is forward-looking, recommending that coverage and payment be tied to demonstrated clinical value — including time-limited payment windows, mandatory coding of health metrics and device types, and outcome-based models. Peterson also critiques the flat reimbursement structure that fails to account for condition-specific effectiveness or clinical engagement.
Comparison
Both reports converge in identifying rapid growth, data gaps, and the need for greater oversight in Medicare's use of remote monitoring services. However, they diverge in their lens and strategic focus. OIG adopts a regulatory and compliance framework, driven by fraud prevention and proper claim submission, while Peterson provides a clinical and economic optimization strategy, advocating for alignment of coverage with actual health outcomes. OIG emphasizes billing integrity and administrative safeguards, whereas Peterson advances evidence-based reimbursement and a more nuanced use of digital health tools. OIG's approach is more reactive and compliance-driven; Peterson’s is more proactive and reform-oriented, targeting payment policy reform to drive higher-value care.
