Patient Eligibility
Per current CMS guidance, remote physiologic monitoring requires an established patient relationship, a condition (acute or chronic) that requires monitoring, and monitoring that is medically reasonable and necessary. See our Medicare RPM Eligibility guide.
Initiating Visit
Established/New Patient Considerations
Currently, remote physiologic monitoring (RPM) requires an established patient relationship. RTM currently does not have this requirement — though CMS has proposed adding an established-patient requirement to RTM specifically for CY2027 (not yet finalized).
Device Requirements
The device used to collect and transmit data must meet the FDA's definition of a medical device.
Medical Device Considerations
Data must be electronically collected and automatically uploaded to a secure location where it's available for analysis and interpretation by the billing practitioner — not manually entered or self-reported outside the device's own transmission.
Data Collection
For the device-supply code, current guidance describes data-collection windows of 2-15 or 16+ days out of 30, depending on the specific code descriptor — confirm the exact threshold for your billed code with your coding advisor or the CMS Physician Fee Schedule Look-Up Tool.
Transmission
Data transmission must be automatic and electronic to a secure location the billing practitioner can access for analysis — not a process requiring the patient to manually report readings by phone or in person.
Monitoring Period
Only one practitioner can bill remote monitoring services per patient in a 30-day period.
Treatment-Management Interaction
Treatment-management billing (99457/99458) requires at least one real-time, interactive communication with the patient or caregiver during the calendar month, in addition to the qualifying time.
Minimum Time
Treatment-management codes are time-based (99457's first 20 minutes, 99458's additional 20-minute increments) — the day-count requirements described above for the device-supply code don't apply to these time-based codes.
Clinical Staff
Physician/QHP Involvement & Supervision
Only physicians and non-physician practitioners eligible to bill evaluation and management services can bill remote monitoring. General supervision (not direct, in-person supervision) is sufficient under current rules.
Proposed Employment Restriction
Consent
Patient consent is required at the time RPM services are provided.
Documentation
Document the qualifying data-collection period, the treatment-management time and interactive communication, and evidence the device meets the FDA's medical device definition and transmits data electronically to a secure location.
Billing Combinations
You can't bill remote physiologic monitoring and RTM together for the same patient. You may bill RPM or RTM (but not both) concurrently with chronic care management, transitional care management, behavioral health integration, principal care management, or chronic pain management for the same patient, as long as time and effort aren't counted twice toward both services.
Same-Month Services
For patients who receive a procedure or surgery covered under a global surgery payment, remote monitoring services may still be billed if they address an underlying condition unrelated to the global procedure.
Current Rules Summary
Common Billing Errors
- Billing device-supply or treatment-management codes without meeting the applicable data-collection or time/communication requirement
- Billing RPM and RTM together for the same patient
- Double-counting the same time toward RPM and another care-management code in the same month
- Missing or undocumented patient consent
- Using a device that doesn't meet the FDA's medical device definition
- More than one practitioner billing remote monitoring for the same patient in a 30-day period