This overview is excerpted from Manatt on Health, Manatt’s subscription service that provides in-depth insights and analysis focused on the legal, policy and market developments. For more information on how to subscribe and to activate a complimentary one week trial to Manatt on Health, please reach out to Barret Jefferds.
On September 24, the HHS Office of Inspector General (OIG) released a report calling for “additional oversight of remote patient monitoring in Medicare.” Remote patient monitoring (RPM) is the collection and transmission of physiological health data—such as blood pressure, weight, or glucose levels—in a patient’s home that providers use to remotely monitor a patient’s health status and manage a patient’s condition. The OIG report notes that, since Medicare began making separate payment for certain RPM services in 2018, the use of and average payment for RPM in the Medicare program has significantly increased, with more than 570,000 enrollees at an average per enrollee cost of $545 in 2022 compared to about 55,000 enrollees and an average of $266 per enrollee in 2019. This increased use of RPM is likely to continue expanding as the Medicare population grows and more providers and patients become familiar with the availability of RPM services.
In its report, OIG outlines several concerns associated with the growing utilization of RPM services. For example, OIG found that approximately 43 percent of enrollees who received RPM did not receive a key component of the monitoring, “raising questions about whether the monitoring is being used as intended.” OIG also expressed concern with the lack of transparency in billing for RPM, noting that Medicare currently lacks complete information about the types of health data that enrollees are collecting and transmitting, what diseases or conditions are being monitored, and who ordered and delivered the RPM services. OIG also notes that it, along with CMS, has identified risks related to “unscrupulous” companies signing up enrollees for RPM services that are potentially not medically necessary.
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