1. Identify Target Patient Population
Identify patients with an acute or chronic condition that would benefit from ongoing physiologic monitoring — common examples include hypertension, diabetes, and weight management, where a connected device can track a meaningful trend.
2. Review Payer Requirements
Confirm current Medicare requirements (see our RPM Billing Requirements guide) and any additional requirements from other payers you bill.
3. Establish Eligibility Workflow
Build a repeatable process for confirming a patient has a qualifying condition, an established relationship with the billing practitioner, and that monitoring is medically necessary.
4. Select Monitoring Use Cases
Decide which conditions and device types your program will support first (e.g., blood pressure, weight, pulse oximetry) rather than trying to support every possible use case at launch.
5. Determine Device Strategy
Choose connected devices that meet the FDA's definition of a medical device and can automatically transmit data electronically to a secure location.
6. Establish Patient Consent
Build a consent process that documents the patient's agreement to participate before billing begins.
7. Configure Onboarding
Set up the device-setup and education workflow that CPT 99453 covers — this is a one-time step per patient, not a recurring one.
8. Create Monitoring Workflows
Define how incoming device data reaches the care team for review, and how often that review happens.
9. Define Alert Thresholds
Set clinically appropriate thresholds so out-of-range readings surface to the care team promptly, without overwhelming staff with false alerts.
10. Assign Care-Team Responsibilities
Decide who reviews data, who performs the monthly interactive communication required for treatment-management billing, and who handles documentation.
11. Configure Documentation
Ensure your workflow captures the data-collection period, treatment-management time, and interactive communication in a form that supports billing and audit.
12. Establish Billing Workflow
Confirm which codes apply each month for each patient (setup, device supply, treatment management, additional time) based on what actually occurred that month — never bill a code whose requirement wasn't met.
13. Track Outcomes
Monitor enrollment, device adherence, and clinical trends over time so program performance is visible, not just individual patient data.
14. Review Program Performance
Periodically assess enrollment rate, data-collection compliance, and treatment-management billing consistency against your workflow design.
15. Audit Compliance
Periodically re-verify that consent, device FDA status, data transmission, and treatment-management documentation remain in place for every actively billed patient.