Oksana Pokoyeva, billing and audit specialist, WCH
How healthcare providers can achieve 0% error rates in the face of escalating scrutiny
The remote patient monitoring (RPM) landscape is about to face unprecedented scrutiny. A recent HHS Office of Inspector General (HHS-OIG) report revealed that Medicare payments for remote patient monitoring reached $536 million in 2024, prompting the agency to develop new measures to monitor RPM billing. This represents a staggering 31% increase from $408 million in 2023, setting the stage for intensive audit activity in 2026.
The Numbers Tell a Story
The HHS-OIG assessment covered 10,388 medical practices that billed for at least one RPM service in 2024, with 4,639 practices routinely billing for RPM services (defined as billing for 10 or more Medicare enrollees and more than 100 RPM services). The growth metrics are striking:
- Medicare RPM payments jumped 31% year-over-year
- Nearly 1 million Medicare enrollees received RPM in 2024 (27% increase)
- Average practice billed RPM for approximately 70 Medicare patients annually
But it’s the outliers that have caught the OIG’s attention. One practice billed RPM for nearly 3,400 new enrollees in a single month – a pattern that historically signals fraud in other Medicare services.
Red Flags Leading to Enhanced Scrutiny
The OIG investigation uncovered several concerning billing patterns that will likely trigger 2026 audits:
Prior Relationship Violations: 45 medical practices lacked the mandated prior medical relationship with more than 80% of patients for whom they billed RPM services.
Duplicate Billing: 34 practices frequently billed Medicare for the same enrollees as two or more other practices.
Multiple Device Billing: 20 practices often billed for two or more devices per month per enrollee.
These patterns have prompted the OIG to announce comprehensive RPM audits throughout 2025, with implementation of enhanced oversight measures expected to intensify in 2026.
The Audit Storm Approaching
Healthcare compliance experts are warning that OIG’s Remote Patient Monitoring audits have arrived, emphasizing the need for providers to ensure thorough documentation, clear orders for RPM services, and well-supported medical necessity. The audit focus will likely concentrate on:
- Data Collection Compliance: CMS requires data collection for at least 16 days in a 30-day billing period for RPM supply and transmission codes
- Prior Medical Relationships: Verification of established patient-provider relationships
- Documentation Standards: Complete medical necessity justification
- Billing Pattern Analysis: Identification of unusual spikes or patterns
- Device Utilization: Appropriate billing for monitoring devices
2026: A Changing Landscape
The timing of increased oversight coincides with significant regulatory changes. CMS’s 2026 Proposed Rule introduces new flexibilities for RPM, including new codes for shorter monitoring periods (2-15 days) and expanded patient eligibility. While these changes offer new revenue opportunities, they also create additional compliance complexity.
The new CPT codes will allow billing for shorter monitoring periods and briefer clinical interaction times – scenarios that previously weren’t reimbursable. However, with expanded billing opportunities comes expanded audit risk.
Key Success Strategies:
1. Professional Billing Optimization
- Automated capture of all required data points
- Real-time compliance monitoring
- Comprehensive audit trails
2. Credentialing and Relationship Verification
- Systematic prior medical relationship documentation
- Patient consent management
- Provider credentialing verification and maintenance
3. Internal Audit and Monitoring Systems
- Automated flagging of unusual billing patterns
- Regular internal audits and compliance reviews
- Comparative analysis against industry benchmarks
4. Technology Integration
- HIPAA-compliant data transmission
- Automated 16-day data collection verification
- Real-time alert systems for compliance gaps
The Stakes Have Never Been Higher
With RPM payments exceeding half a billion dollars and fraud patterns emerging, 2026 will likely see among the most intensive RPM audits to date. Previous OIG reports noted that about 43% of enrollees who received remote patient monitoring did not receive all three required components, raising questions about proper utilization.
The providers who will thrive are those who recognize that compliance is not just about avoiding penalties – it’s about building sustainable, audit-resistant RPM programs that can withstand the most rigorous scrutiny.
My Advice to Providers
From my audit desk at WCH, I see the RPM industry at a critical juncture every day. The dramatic growth that attracted OIG attention also demonstrates the tremendous potential of remote monitoring technology and the expanding reimbursement opportunities in 2026. However, maintaining proper documentation has always been fundamental to healthcare billing – not only to receive payment for medically necessary services but also to retain those payments when audited.
My recommendation to healthcare organizations serious about capitalizing on RPM opportunities: maintain documentation standards that assume an audit could happen at any time. In my experience, providers who maintain comprehensive compliance practices daily are the ones who operate confidently regardless of audit timing.
The best audit is the one that never needs to be performed. That’s why proactive compliance management is essential – maintaining audit-ready documentation.
Healthcare organizations must prepare continuously, not just when regulatory pressure intensifies. The audit spotlight is always there, and only those with comprehensive daily compliance practices can confidently operate in any oversight environment.
Let professionals check your records before the insurance does!
WCH provides comprehensive billing, auditing, and credentialing services to healthcare providers nationwide.
Sources:
- U.S. Department of Health and Human Services, Office of Inspector General. “Billing for Remote Patient Monitoring in Medicare.” 2025.
- TechTarget. “Medicare RPM payments spike spurs HHS-OIG oversight.” 2024.
- Prevounce Blog. “OIG to Audit Remote Patient Monitoring (RPM) Throughout 2025.” April 2025.
- Nixon Law Group. “OIG’s Remote Patient Monitoring Audits Are Here: What You Need to Know.” June 2025.
- McDonald Hopkins. “CMS updates Medicare remote patient monitoring standards.” 2024.
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