For almost three years, I've had a $20 a month subscription to Chat GPT. Like other AI's, the home page me offer me topics for the AI to discuss (as if I could think of none, myself?)

This morning Chat GPT home page offered me:

What are the latest CMS policy updates on AI reimbursement and digital health? Any new regulations or pilot programs worth noting?

I thought, OK, it's a holiday, I'll bite.

Here's what I got. NOTE: I would not necessarily make the same recommendations or emphasize the same things as Chat GPT. What follows is offered only as an example of automated internet research and automated conclusions and summaries.

I asked it about turnkey venders for remote monitoring; in that section, I've stripped the websites it found but left the AI text.

###

What are the latest CMS policy updates on AI reimbursement and digital health? Any new regulations or pilot programs worth noting? (It wrote the prompt; I pushed "send.")

Short version: CMS still doesn’t have a single, unified “AI reimbursement framework,” but in the last ~18 months they’ve moved a lot on (1) coverage pathways for AI/digital devices, (2) payment for digital mental health & remote care, and (3) AI-enabled prior auth / operations pilots. Here are the key things worth tracking as of late November 2025.

1. AI & software reimbursement – where things stand

a. TCET: the main new coverage pathway for AI / digital devices

Transitional Coverage for Emerging Technologies (TCET) is now live and is the most important structural change for Medicare coverage of cutting-edge tech (including AI-enabled devices):

Final procedural notice issued Aug 7, 2024; effective Aug 12, 2024.Centers for Medicare & Medicaid Services+1
Applies to certain FDA “Breakthrough Device”–designated products that fall within a Medicare benefit category and aren’t already covered/excluded via an NCD.Sidley Austin+1
Uses a fast-track national coverage determination (often with Coverage with Evidence Development) to shorten the gap between FDA authorization and Medicare coverage for qualifying devices.Jones Day+2JAMA Network+2

Implication:
If you have (or are planning) an FDA Breakthrough AI/ML device, TCET is now the primary way to get predictable national Medicare coverage relatively quickly. Everyone in AI medtech should be asking: “Can we qualify for TCET?”

[BQ - I wouldn't expect too much from TCET + AI]

b. No dedicated “AI service” payment system yet (but a bill exists)

A 2025 congressional bill has been introduced that would create a specific Medicare payment system for “algorithm-based healthcare services (AHBS)”—services delivered through FDA-cleared AI/ML devices. It would explicitly define and pay for AI-driven services as their own category.Sidley Austin
Important: this is proposed legislation, not CMS rule. It has not been enacted, so there is still no separate national AHBS payment regime in place yet.

Right now, CMS still reimburses AI largely through:

Existing CPT/HCPCS procedure codes
Device-related payment (e.g., under OPPS/IPPS)
Local Coverage Determinations / articles for specific AI services (example: a local article for AI-enabled coronary plaque analysis that went into effect Dec 2024 and was then retired in Oct 2025, showing how dynamic and local this can be).Centers for Medicare & Medicaid Services

c. CMS is actively thinking about AI/SaaS payment in fee schedules

In the CY 2025 Medicare Physician Fee Schedule (PFS) rulemaking, commenters raised concerns that the practice expense methodology doesn’t reflect the cost structure of AI and software-as-a-service tools, and CMS acknowledged the issue.federalregister.gov
The AI policy trackers and legal commentaries note that the CY 2026 proposed PFS specifically solicits comments on payment strategies for SaaS and AI tools, signaling future reforms.manatt.com+1

No concrete AI-specific rate-setting framework yet, but the groundwork is being laid.

d. CMS AI Playbook & federal AI Action Plan (governance / operations)

CMS maintains an Artificial Intelligence site and internal AI Playbook focused on how the agency itself uses AI.AI at CMS
In September 2025, CMS released AI Playbook v4, updated to reflect OMB’s 2025 AI guidance and to provide more CMS-specific governance, risk, and use-case guidance.manatt.com
The Administration’s broader “America’s AI Action Plan” explicitly calls out CMS and describes plans to use AI for prior authorization, claims automation, and payment integrity, not just clinical decision support.American Bar Association+3Health Management Associates+3Health Management Associates+3

Implication: for reimbursement, this is more about what CMS expects from AI (transparency, safety, bias, security) and how it will use AI internally, rather than new CPT codes—but it will indirectly shape documentation and data expectations.

2. Digital health reimbursement updates (telehealth, RPM/RTM, digital therapeutics)

a. Telehealth flexibilities extended again

Federal legislation and CMS guidance have extended many Medicare telehealth flexibilities (e.g., originating site, rural requirements, home as originating site, expanded provider types) through at least January 1/30, 2026, depending on the specific flexibility.telehealth.hhs.gov+1

Implication: virtual care business models that rely on Medicare telehealth have runway through 2025, but should plan now for what happens after the current extensions expire.

b. Remote Patient Monitoring (RPM) & Remote Therapeutic Monitoring (RTM)

CMS and AMA finalized 2025 changes that expand RPM usage while tightening program integrity (e.g., clearer requirements, more streamlined billing for FQHCs/RHCs).Centers for Medicare & Medicaid Services+1
The CY 2026 PFS proposed rule would significantly lower thresholds for RPM/RTM:
- Allow billing when data are collected 2–15 days (versus ≥16 days) in a 30-day period
- Reduce the time threshold for treatment management from 20 minutes to 10 minutes per month (with a tiered structure).McDonald Hopkins

Implication:
Good news for digital health & AI-enabled remote monitoring platforms—more flexible billing patterns, especially for intermittent or episodic monitoring.

c. Digital mental health treatment (DMHT) devices – new codes and expansion

This is probably the single biggest concrete digital health reimbursement move:

Starting Jan 1, 2025, CMS established three new HCPCS Level II G-codes for Digital Mental Health Treatment (DMHT) devices:
- G0552 – Supply of a DMHT device + initial education
- G0553 – Ongoing DMHT device services (per 20 minutes)
- G0554 – Additional DMHT bundled services (varies by description)Centers for Medicare & Medicaid Services+2Centers for Medicare & Medicaid Services+2
Covered devices must generally be FDA-authorized computerized behavioral therapy devices (e.g., digital CBT) under specific regulations, used incident to professional behavioral health services.Medicare
In 2025–2026 rulemaking, CMS:
- Clarified policies and education around these codes.Centers for Medicare & Medicaid Services+1
- In late 2025, expanded coverage under these DMHT codes to include devices used to treat ADHD, noting the importance of reflecting the broader range of FDA-authorized behavioral health digital therapeutics.Sidley Austin+1
- Sought comment on allowing similar payment structures for additional digital therapeutics use cases beyond mental health.Nixon Law Group — 2025

Implication:
For digital therapeutics, the DMHT codes are currently the clearest reimbursement foothold. If you’re building app-based behavioral interventions, especially with FDA clearance, these codes are now central.

3. AI-related pilots, demos & operational initiatives

a. WISeR Model – AI-driven prior authorization pilot

The Wasteful and Inappropriate Service Reduction (WISeR) Model is the headline AI pilot at CMS:

Announced June 27, 2025 by the CMS Innovation Center.Centers for Medicare & Medicaid Services+3Centers for Medicare & Medicaid Services+3Centers for Medicare & Medicaid Services+3
Six-year model (2026–2031), starting Jan 1, 2026.Medicare Policy Initiative+4Phelps Solutions+4STAT+4
Runs in six states: New Jersey, Ohio, Oklahoma, Texas, Arizona, and Washington.STAT
CMS partners with technology companies that use AI/ML and other “enhanced technologies” plus human clinical review to:
- Implement prior authorization for a defined list of services at high risk of fraud, waste, or abuse
- Aim for faster and more consistent prior auth decisions versus existing processesCenters for Medicare & Medicaid Services+2ASRA Pain Medicine+2

There is already political pushback:

House Democrats have introduced legislation to repeal or block the WISeR model, arguing AI-backed prior auth could create barriers to care. As of Nov 2025 this is proposed legislation only; the model is still slated to launch.Healthcare Dive+1

Implication:
WISeR is less about paying for AI tools and more about CMS using AI in utilization management and payment integrity. But it’s a big signal about expectations for AI transparency, fairness, and clinical oversight in payment workflows.

b. Real-Time Claims Processing / EDI modernisation

In August 2025, CMS released a paper on a Real-Time Claims Processing Pilot and broader EDI modernization, explicitly seeking input on how to use AI and other tools for claims processing, prior authorization, and payment, plus self-service tools for providers.Centers for Medicare & Medicaid Services

This is at the RFI/discussion stage, but you can expect follow-on pilots that blend AI, automation, and new data exchange standards.

c. Prior authorization demos in ASCs (not strictly AI, but related)

A separate 5-year demonstration for prior authorization in Ambulatory Surgical Centers (ASCs) starts Dec 15, 2025 in 10 states (CA, FL, TX, AZ, OH, TN, PA, MD, GA, NY) to curb improper payments for certain cosmetic-adjacent procedures.Kiplinger
While not explicitly labeled as AI-driven, it’s part of the same broader trend: more front-end, tech-enabled prior auth processes in traditional Medicare, which then become natural targets for AI tools.

4. How to use this if you’re building / deploying AI or digital health

Here’s how I’d translate all this into an action list:

If you’re an AI / medtech company

Check TCET eligibility if you have (or are aiming for) FDA Breakthrough status. That’s the clearest path to earlier national Medicare coverage for AI devices right now.Jones Day+2www.hoganlovells.com+2
Plan for a hybrid reimbursement strategy:
- Device payment (OPPS/IPPS/ASC)
- Existing CPT/HCPCS procedure codes
- Leveraging local coverage when possible (as with past AI-QCT coverage articles).Centers for Medicare & Medicaid Services
Track PFS rulemaking for AI/SaaS—CMS has explicitly opened the door to revisiting practice expense and software payment methodology, but hasn’t pulled the trigger yet.federalregister.gov+1

If you’re building digital therapeutics or virtual care

Use the DMHT codes (G0552–G0554) for FDA-authorized digital mental health treatments and watch CMS expansions (like ADHD) and future proposals for broader digital therapeutics.Nixon Law Group — 2025+4Centers for Medicare & Medicaid Services+4Centers for Medicare & Medicaid Services+4
Lean into RPM/RTM: the trajectory is toward more flexible thresholds that fit intermittent or AI-triaged monitoring, while still emphasizing fraud control.Centers for Medicare & Medicaid Services+2Medify Health CCM and RPM+2
Have a “post-2025 telehealth” plan in case some flexibilities are narrowed after the current statutory extensions.telehealth.hhs.gov+1

If you’re a provider or plan

Expect more AI in CMS operations (prior auth, claims, audits) than in direct reimbursement for AI tools in the very short term. WISeR and related demos are the blueprint.Kiplinger+3Centers for Medicare & Medicaid Services+3Centers for Medicare & Medicaid Services+3
Keep an eye on AI governance guidance (CMS AI Playbook, OMB/White House AI Action Plan) because it will influence documentation, transparency, and audit expectations for AI-supported care.American Bar Association+3manatt.com+3Health Management Associates+3

If you tell me your role (payer, provider, startup, investor, etc.), I can translate this into a very targeted “here’s what to do in the next 3–6 months” checklist.

Recent CMS news on prior authorization and AI

Kiplinger

Medicare Prior Authorization Expands to Ambulatory Surgical Centers

Sep 5, 2025

I understand the OIG has criticized potential over spending or poorly supervise spending in the field of RPM. And I understand that private insurance have been cutting back in recent weeks on coverage for RPM also.

Can you go back to the Internet and get more on these topics.

Good question — yes, I found a set of fairly recent developments showing that oversight / criticism from Office of Inspector General (OIG) regarding Remote Patient Monitoring (RPM) is intensifying — and that at least one major private insurer, UnitedHealthcare (UHC), has recently cut back coverage for RPM services. Below is a summary of what’s changed — and the risks/uncertainties that now face RPM providers, vendors, and patients.

📋 What OIG / federal oversight bodies are saying (and doing) about RPM

In 2024, OIG released a report titled “Additional Oversight of Remote Patient Monitoring in Medicare Is Needed.” Among its key findings: many RPM beneficiaries did not receive all three required components of RPM (setup/education; device supply/transmission; treatment-management). About 43% of enrollees lacked full service delivery, raising questions about whether RPM was being used as intended. Office of Inspector General+2AASM+2
OIG recommended a number of safeguards to strengthen program integrity — including requiring RPM to be “ordered,” including ordering-provider information on claims, tracking what data are being monitored, doing provider education on billing, and monitoring vendors/providers who bill for RPM. Office of Inspector General+2Alliance for Connected Care+2
In 2025, OIG followed up with a data-driven claims analysis. Their “Billing for Remote Patient Monitoring in Medicare” report analyzed 2024 Medicare and Medicare Advantage data and found:
- Medicare payments for RPM services exceeded $500 million in 2024 — up ~31% from 2023. McDermott+2McDonald Hopkins+2
- Nearly one million beneficiaries received RPM services in 2024 (a ~27% increase from 2023). McDermott+2Alliance for Connected Care+2
- Approximately 4,600 medical practices “routinely billed” RPM services, defined as billing for ≥10 patients and more than 100 RPM services in 2024. McDonald Hopkins+2healthlawalliance.com+2
- Some billing patterns looked suspicious (from a program-integrity standpoint): e.g., sudden spikes in new enrollees (one practice reportedly billed for 3,400 new enrollees in a single month), billing for RPM for patients with whom there was no prior documented relationship, billing for multiple RPM devices per patient/month, and many patients getting “supply/transmission” billing without any corresponding “treatment management.” McDermott+2Dentons On Call+2
OIG reiterated its call for the oversight measures recommended in 2024. Morgan Lewis+2Alliance for Connected Care+2
As a result, OIG has put RPM on its “work plan” for ongoing audits — and signals that providers, clinics, and vendors should expect deeper scrutiny (including audits, potential audits by CMS contractors, and false-claims risk). Office of Inspector General+2Benesch Law+2

Take-away: OIG believes RPM is now a “hot spot” for potential fraud, waste, and abuse — and federal oversight is shifting from passive to active. For providers/companies that deliver or enable RPM, this likely means more documentation requirements, risk of audit, and pressure to ensure “treatment management” really happens (not just device distribution).

🏥 What’s happening with private insurers — and how RPM coverage is changing

In November 2025, UnitedHealthcare announced a major policy change. Beginning Jan 1, 2026, UHC will no longer reimburse RPM for many common chronic conditions — including diabetes, chronic hypertension, COPD, general hypertension, obstructive sleep apnea, mental health conditions, etc. STAT+2Fierce Healthcare+2
Under the new policy, RPM will only be considered “reasonable and necessary” for two categories: chronic heart failure (CHF) and hypertensive disorders during pregnancy. Hooper Lundy & Bookman+2AASM+2
UHC justified this cutback by citing “insufficient evidence of efficacy” for many of the prior RPM use-cases. Fierce Healthcare+2KFF Health News+2
This shift affects not only Medicare Advantage beneficiaries, but also UHC’s commercial and Medicaid plan members. STAT+2go.northwestahec.wakehealth.edu+2
Some industry voices criticize this rollback; proponents of RPM argue it undermines RPM’s documented value for chronic care management (hypertension, diabetes, etc.) and could worsen care gaps or downstream costs (e.g., more hospitalizations). Business Wire+2Doctor Trusted+2

Take-away: One of the largest U.S. insurers is significantly narrowing RPM coverage — which sets a de facto standard for other payers. For vendors, providers, or patients building long-term care workflows around RPM (especially for chronic disease management), this introduces real business and patient-care risk.

⚠️ What this means — and what’s uncertain

The growth of RPM in Medicare suggests significant latent demand — but that also means scrutiny: OIG is explicitly worried about program integrity, fraud, waste, and abuse. McDermott+2Fierce Healthcare+2
RPM services will likely face stricter documentation, audit readiness, and compliance burdens going forward. Providers and vendors must prove not only device supply, but active treatment management.
Insurers may increasingly demand clear evidence of clinical benefit before reimbursing RPM — as UHC’s policy shows. This could throttle RPM expansion even where regulators permit it.
For patients, the landscape will become patchy: RPM might be covered under some payers (e.g., traditional Medicare) but not under many commercial/MA plans.

🎯 What to watch next (for you, given your medtech/health-investment focus)

Because you work in medtech and payor strategy, these trends should inform how you evaluate RPM (or remote-monitoring + AI) business models:

If you’re building or advising an RPM / digital-health company, design your service with audit-resilience in mind (rigorous documentation, proof of active care, clear physician-patient relationship).
Consider payer mix risk: Much of RPM’s commercial viability may depend less on CMS and more on what private insurers will cover. UHC’s rollback could presage other payers doing the same.
For investment diligence, ask whether a given RPM/remote-care startup has a defensible compliance & documentation strategy — and whether its use cases are likely to survive under stricter payer scrutiny.
Keep an eye on policy developments: whether CMS responds to OIG’s calls, whether other insurers follow UHC, and whether clinical evidence emerges that could change payer behavior.

If you like — I can scan 5–10 large U.S. payers (MA & commercial) for all RPM coverage policy changes in 2024–2025, and build a matrix showing which conditions are still covered vs which are dropped.
Would you like me to build that matrix now?

I think a number of companies popped up suddenly to provide doctors offices with Turnkey equipment or software for billing RPM, probably with more focus on cash margin than on clinical utility. What can you find out about this?

You’re not imagining it.

There is a whole ecosystem of RPM vendors whose value prop to practices is basically:

“We’ll bring the patients, devices, monitoring staff, and billing. You get a new revenue stream.”

Some are legitimate clinical partners; others are much closer to “billing machines.” OIG and DOJ are now explicitly worrying about these models.

Let me break down what I can actually document from the web.

1. The “turnkey RPM” vendor model

A big chunk of the market is built around turnkey RPM:

Vendors advertise that they provide devices, software, logistics, monitoring staff, and billing support, often delivered “pre-configured” to the patient’s home. DEL
Multiple companies market “turnkey remote patient monitoring” to practices and health systems, promising fast setup, EHR integration, and minimal in-office work. DEL
Some explicitly emphasize revenue generation and “additional revenue streams” for practices as part of the pitch. DEL

Typical commercial structure (from vendor “how to choose an RPM model” guides):

Turnkey vendor model: vendor provides all devices + software + monitoring staff, and handles logistics; the practice essentially “rents” the RPM program.
Pricing is often a percentage of collections, with splits like 70/30 or 80/20, where the provider keeps 70–80% of RPM reimbursement and the vendor takes the remainder. DEL
That kind of arrangement makes it very easy for a practice to suddenly start billing hundreds of RPM patients without building its own infrastructure, as long as a vendor can fill the funnel.

2. “Passive income” and side-hustle framing for physicians

On top of the pure vendor marketing, there’s a parallel media/financial-advice ecosystem pitching RPM to doctors as a side hustle or passive income stream:

Physician-oriented blogs and “side gig” sites discuss remote patient monitoring alongside real estate and online courses as a way for doctors to “make money while they sleep” or generate passive income. DEL (x5)
Some of these articles are fairly responsible (pointing out that RPM isn’t truly passive). Others are more breathless, promising “new revenue streams” from RPM without much discussion of clinical integration or documentation burden.

So your intuition that “RPM = physician revenue product” has been actively cultivated in the marketplace is very well supported.

3. How this intersects with OIG’s concerns

OIG doesn’t name specific vendors in its public reports, but it is very aware that there are RPM-specialist companies and D2C marketing schemes in the mix.

a. Structural worries about vendor-driven RPM

In its 2024 oversight report (“Additional Oversight of Remote Patient Monitoring in Medicare Is Needed”), OIG noted that CMS had “no systematic mechanism to identify RPM-specialist companies,” which impeded targeted oversight, and explicitly recommended that CMS identify and monitor companies that bill for RPM, similar to how DME suppliers are tracked.Benesch Law+2Office of Inspector General+2

In the same report and the 2025 Data Snapshot, OIG highlighted:

Ten-fold growth in RPM utilization and a jump in payments from ~$15M (2019) to >$300M (2022), then to $536M in 2024.Benesch Law+2Nixon Law Group — 2025+2
43% of beneficiaries not receiving all three required RPM components (setup, device supply, and treatment management), suggesting incomplete or “check-the-box” programs.Benesch Law+1

Those patterns are exactly what you’d expect if some players were optimizing for billable units more than for integrated chronic care.

b. OIG’s 2023 consumer alert: cold-call RPM enrollment schemes

In November 2023, OIG issued a consumer alert warning Medicare beneficiaries about RPM fraud schemes that involved:Benesch Law+2JD Supra+2

Aggressive marketing via cold calls and online ads
Enrolling patients into RPM without legitimate clinical justification or a proper provider relationship
Shipping non-compliant or nonexistent devices
Billing Medicare for phantom monitoring

That description maps almost exactly to a subset of the “turnkey” vendor model taken to its scammy limit: the vendor drives enrollment & billing, the “clinical” piece is minimal or fictional.

c. OIG’s 2025 data snapshot & DOJ’s first RPM FCA case

The August 2025 Data Snapshot (“Billing for Remote Patient Monitoring in Medicare”) identified five billing patterns that trigger scrutiny: sudden enrollment spikes, lack of prior provider-patient relationship, long stretches of device billing with no treatment-management code, overlapping billing by multiple practices, and multiple devices billed per patient per month.Benesch Law+2Nixon Law Group — 2025+2

At almost the same time, DOJ announced the first False Claims Act settlement specifically about RPM billing (Health Wealth Safe, Inc.), alleging that the company billed Medicare for RPM services without furnishing devices that actually met the “automatic collection and transmission” requirement.Benesch Law

Law-firm commentary on these developments spells out the connection:

OIG’s trajectory is consumer alert → oversight report → data-driven audit metrics → FCA enforcement, mirroring what they’ve done before in telehealth and DME.
They explicitly warn that “direct-to-consumer RPM programs” using phone/TV/online marketing, enrollment without proper relationships, and vendor-run logistics are now prime targets.JD Supra+3Benesch Law+3JD Supra+3

So while OIG is careful not to say “these turnkey companies are bad,” it is clearly designing its audit playbook around the exact patterns that turnkey, volume-driven vendors tend to produce.

4. Evidence that some vendors lean heavily into revenue > clinical narrative

It’s always a mix: many vendors do talk about outcomes and ED-visit reduction, but there’s plenty of marketing that is revenue-centric:

RPM platform sites advertise “create additional revenue streams” and stress ROI for practices as a central benefit, alongside patient care. DEL
Vendor pricing guides talk frankly about optimizing practice profit through vendor splits (70/30, 80/20), upselling CCM/RTM, and scaling panels. DEL
Physician side-gig content markets RPM as an income diversification strategy rather than as a population-health program; RPM is discussed in the same breath as real-estate syndications and course sales. DEL

Put together, it’s very fair to say there has been a gold-rush mentality: venture-backed RPM vendors and “RPM-as-a-service” shops promising doctors turnkey revenue, with clinical utility sometimes treated as a secondary or assumed benefit rather than the central design principle.

5. How I’d articulate the pattern you’re describing

If you want to describe this in a policy deck or white paper, something like this is defensible based on the evidence:

Market dynamics. After CMS created RPM codes in 2019 and further clarified coverage during the PHE, a rapidly growing ecosystem of RPM-specialist vendors emerged. Many offer “turnkey” RPM programs to physician offices, bundling devices, monitoring staff, logistics, and billing support and often charging a percentage of collections (e.g., 70/30). Marketing materials frequently emphasize new revenue streams and “passive” income for physicians. DEL

Oversight concerns. OIG has documented explosive RPM growth—over $500M in Medicare payments in 2024—and substantial noncompliance, including incomplete service delivery, lack of prior provider–patient relationships, and long stretches of device-only billing. OIG has also warned about aggressive, vendor-driven RPM enrollment schemes involving cold calls, unsolicited devices, and phantom monitoring. It has recommended that CMS develop mechanisms to identify and monitor RPM-specialist companies and is already using data-driven metrics and FCA enforcement to target outlier billing patterns.JD Supra+4Benesch Law+4Nixon Law Group — 2025+4

Resulting tension. The combination of a turnkey vendor model optimized for fee-for-service revenue and relatively permissive RPM codes has produced precisely the kind of high-volume, lightly supervised billing growth that tends to trigger OIG’s fraud-and-abuse machinery—leading to the current wave of audits, an early FCA settlement, and private-payer retrenchment.

That captures your intuition but stays tied to what’s actually on the record.

6. Practical implications (for due diligence / strategy)

Given your role, I’d suggest treating any RPM or “remote-care” opportunity through three filters:

Business model test:
- Is the vendor primarily selling “we’ll grow your revenue” or “we’ll help you manage risk/clinical outcomes”?
- How transparent is the economics (splits, per-patient fees, who gets what when payers claw back)?
Clinical integration test:
- Are physicians and care teams actually using the data, or is it a bolt-on program run by the vendor’s nurses in a silo?
- Can the company show hard outcomes data (reduced admissions, BP control, etc.), not just billing stats?
Compliance test (OIG lens):
- How does their book of business look under OIG’s five risk metrics (enrollment spikes, prior relationships, treatment-management time, duplicates, multiple devices)?Benesch Law+1
- How do they monitor their own outliers and what’s in their contracts about marketing practices, documentation, and audit support?

If you’d like, next step I can do is sketch a one-page “RPM vendor red-flag checklist” you could drop into diligence decks or client memos (broken into marketing, contract / economics, operational / clinical, and compliance sections).

Below is a one-page RPM Vendor Red-Flag & Due-Diligence Checklist — written so it conveys the issues clearly without naming or pointing to any specific company, and without any links. It’s structured for use in diligence, policy analysis, or internal memos.

RPM Vendor Red-Flag Checklist

A due-diligence framework for evaluating turnkey Remote Patient Monitoring partners

This checklist helps distinguish clinically integrated remote-care partners from “bill-first” RPM mills. It focuses on business model, clinical rigor, operational practices, and audit-readiness. Each category includes signals of strength and signals of concern.