The government’s concerns
HHS-OIG emphasized that RPM is designed to include three components: enrollee education/device setup, device supply and treatment management. However, the group determined that a significant number of enrollees are missing out on at least one step of the process. The most commonly missed component is enrollee education.
“Approximately 43% of enrollees who received remote patient monitoring did not receive a key component of the monitoring, raising questions about whether the monitoring is being used as intended,” according to the report. “Additionally, OIG and CMS have identified risks related to unscrupulous companies signing enrollees up for remote patient monitoring that they do not need. Further, a lack of transparency in billing for remote patient monitoring hinders oversight. 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 remote patient monitoring.”
The HHS-OIG report also detailed multiple practices seen in the United State it found to be concerning. Some companies appear to be “cold calling” potential enrollees without even having data that suggests they would benefit from RPM, for example, while others are providing more devices than they can realistically monitor.
“Further, Medicare does not have a systematic way to identify companies that specialize in remote patient monitoring,” according to the report. “Medicare does not consider remote patient monitoring companies to be a type of provider. Having information could help CMS better understand how common program integrity issues, such as inappropriate billing, are with companies specializing in remote patient monitoring, and help it address these program integrity risks.”
HHS-OIG recommendations on RPM oversight
The report includes several recommendations. For example, HHS-OIG believes CMS should take steps that will make it easier to know exactly who is providing RPM services when reviewing billing materials. The group also thinks CMS should regularly monitor Medicare data to identify providers that may be frequently billing enrollees for some RPM components, but not all of them.
“If an enrollee never receives treatment management, it raises question about the necessity and benefit of receiving remote patient monitoring,” according to the report. “CMS should then conduct additional follow-up on these providers, as appropriate.”
Those were just some of the group’s recommendations. Others included:
- CMS should pay closer attention to when RPM is being ordered to ensure it only being used for appropriate conditions.
- CMS should ensure Medicare Advantage plans have “safeguards in place” to protect patients from fraud, waste and abuse.
- Billing codes should be updated to reflect the type of data being monitored.
- Provider education on billing policies should be conducted
- Identify and monitor “unscrupulous” companies signing up patients for RPM who may not need it.
The full HHS-OIG report is available here.
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