Remote patient monitoring use raises HHS-OIG concerns

Amid the steep rise in remote patient monitoring in recent years, a new federal report highlights concerns about the appropriate use of the services and the potential for fraud.

The U.S. Department of Health and Human Services' Office of the Inspector General (HHS-OIG) developed the report to better understand how RPM is used and identify vulnerabilities that may limit oversight.

Medicare began covering RPM in 2018, allowing healthcare providers to bill for RPM services using a set of procedure codes that represent three different components of RPM, the report stated. The components are education and setup, device supply and treatment management. Since 2018, RPM utilization has skyrocketed, largely due to the COVID-19 pandemic.

For the report, HHS-OIG analyzed Medicare fee-for-service claims from the National Claims History File and Medicare Advantage encounters from Part C Encounter data spanning Jan. 1, 2019, through Dec. 31, 2022.

The HHS-OIG found that the number of Medicare enrollees who received RPM was more than 10-fold higher in 2022 than in 2019. In 2022, a little over 570,000 Medicare enrollees received RPM, compared to about 55,000 in 2019. As a result, Medicare payments for RPM soared from $15 million in 2019 to $300 million in 2022.

Additionally, the average Medicare payment per enrollee for RPM doubled. Traditional Medicare and Medicare Advantage payments averaged $545 per enrollee for RPM in 2022, up from $266 per enrollee in 2019.

An overwhelming majority of Medicare enrollees (94%) received RPM to treat chronic conditions in 2022. The most common conditions RPM was used to treat were hypertension, diabetes with and without complications and sleep-wake disorders. Only 7% of Medicare beneficiaries received RPM for an acute condition.

Certain groups received RPM at higher rates than others in 2022. The analysis revealed that Black enrollees received RPM at a rate of 15 per 1,000 enrollees compared to 7 per 1,000 enrollees among white enrollees. Similarly, people eligible for Medicare and Medicaid received RPM at a rate of 14 per 1,000 Medicare enrollees versus Medicare-only enrollees who received RPM at 7 per 1,000 Medicare enrollees.

However, 43% of Medicare enrollees who received RPM in 2022 did not receive at least one of the three components. About 28% of enrollees did not have a claim or encounter record for education and setup, 23% did not have one for device supply and 12% did not have one for treatment management. This raises concerns about whether RPM services are being used as intended, the HHS-OIG noted.

Further, the report highlighted the concerns of the OIG and the Centers for Medicare and Medicaid Services (CMS) regarding attempts to sign Medicare enrollees up for RPM services regardless of their need. The agencies stated that some companies make unsolicited contact with enrollees, either signing them up for RPM that never occurs or providing devices without having enough staff to conduct the monitoring, among other fraud risks.

Not only that, but CMS lacks necessary information about the types of health data collected and the types of devices used.

"This lack of transparency limits CMS's ability to ensure that remote patient monitoring services meet requirements," the report stated.

The HHS-OIG made several recommendations to CMS to strengthen RPM oversight, including requiring that a qualified healthcare professional order all RPM services and that information about the ordering provider be included on claims and encounter data.

The report noted that CMS has concurred with or said it will consider all the recommendations.

However, virtual care associations are criticizing the report and its recommendations. The Alliance for Connected Care sent a letter to HHS-OIG on Sept. 24, 2024, stating that the report contains numerous inaccuracies and is highly subjective.

For instance, the letter noted that concluding that RPM services are not being used as intended if patients do not receive all three RPM components is a "sweeping inaccurate generalization," adding that there are several reasons a provider may not bill for certain components.

"We request that you consider retracting the report, and amending it to accurately reflect the way that RPM services are required to be delivered in Medicare, as well as reducing the bias language," Krista Drobac, executive director of the Alliance for Connected Care wrote.

Anuja Vaidya has covered the healthcare industry since 2012. She currently covers the virtual healthcare landscape, including telehealth, remote patient monitoring and digital therapeutics.