HHS-OIG Identifies Need for Increased Oversight of Remote Patient Monitoring
Remote patient monitoring allows patients to collect their own health data via connected medical devices that automatically transmit the data to their healthcare provider. Remote patient monitoring is broadly covered by Medicare for both chronic and acute conditions and can be incredibly useful in managing patients’ conditions. The use of remote patient monitoring in Medicare has increased dramatically in recent years. Between 2019 and 2022, the number of Medicare recipients receiving remote patient monitoring increased 10-fold, and billing for remote patient monitoring increased 20-fold.
Both the HHS Office of Inspector General (HHS-OIG) and the Centers for Medicare and Medicaid Services (CMS) have voiced concerns about fraud related to remote patient monitoring. In 2023, OIG issued a consumer alert about unscrupulous companies contacting Medicare enrollees to sign them up for remote patient monitoring when there was no medical need for remote monitoring. While the patient is signed up and the company bills Medicare for providing the service, the monitoring never happens.
Remote patient monitoring, also called remote physiologic monitoring, started to be covered by Medicare in 2018 and providers bill Medicare using a general set of procedure codes for different components of monitoring. Currently, there are no requirements under Medicare for remote monitoring services to be ordered by a physician or other qualified healthcare professional nor for information about the ordering provider to be included on the claim.
In order for remote patient monitoring to be included in Medicare fee-for-service, a Medicaid enrollee must have a chronic or acute condition that requires monitoring, must use an Internet-connected device that meets the FDA definition of a medical device that is capable of uploading data, and health data must be collected and transmitted at least for 16 days every 30 days. There is no limit on the length of time a patient can receive remote patient monitoring.
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HHS-OIG recently conducted a review and found there is a lack of information about how remote monitoring is being used, including the conditions it is being used for, who is ordering it, which patients are receiving it, and whether it is being used and billed appropriately in Medicare. The HHS-OIG review found that in 2019, around 55,000 patients received remote patient monitoring, which increased to around 570,000 Medicare recipients in 2022. Payments increased from $15 million in 2019 to $311 million in 2022, with the increase mostly due to the length of time that patients received remote monitoring services. In 2022 the majority of patients (94%) received remote patient monitoring for chronic conditions, with more than half receiving it for hypertension, around 15% for diabetes, and 5% for sleep-wake disorders.
There are three separate billable components under remote patient monitoring – education and setup, device supply, and treatment management. Each component is paid separately at the same rate, irrespective of the device used or the health data collected. HHS-OIG found that 43% of enrollees who received remote patient monitoring did not receive all 3 components, which suggests remote patient monitoring may not have always been provided as intended. In total, around 28% of enrollees who received remote patient monitoring did not have a claim or encounter record for education and setup, around 23% did not have a claim or encounter record for a device, and 12% did not receive treatment management. HHS-OIG determined that Medicare lacks critical information about the remote patient monitoring it pays for which creates challenges for oversight.
HHS-OIG made several recommendations to strengthen oversight to ensure that remote patient monitoring is being provided and billed appropriately. The CMS has been asked to implement additional safeguards to ensure it is being used and billed appropriately, require that patient monitoring be ordered and for information about the ordering provider be included on claims and encounter data, to develop a method to identify what health data is being monitored, to identify and monitor companies that bill for remote patient monitoring, and improve education about the billing of remote patient monitoring. The CMS concurred with all the recommendations or stated it would take the recommendations into consideration.
