Remote Patient Monitoring (RPM) Compliance Consulting
Last updated: October 2026
Remote patient monitoring (RPM) compliance consulting is a review of an RPM program's billing, documentation and policies against Medicare's published requirements before an auditor looks at it.
Integral Healthcare Solutions (IHS), founded in February 2002 by Thomas G. Goddard, JD, PhD, former Chief Operating Officer and General Counsel of URAC, produces RPM gap assessments, policies and procedures and mock audit reviews for medical practices, hospital systems, home health agencies, health centers and digital health vendors. IHS does not sell RPM devices or software platforms. IHS is a consulting firm, not a law firm, and this page is not legal advice. Your billing lead or counsel confirms the billing conclusions.
See also the RPM billing guide.
What does the federal government say about RPM compliance risk?
The Office of Inspector General (OIG) found that about 43 percent of Medicare enrollees who received RPM did not receive all three components of it. The finding is in OIG report OEI-02-23-00260, issued September 19, 2024 (page and report opened October 4, 2026). The report used 2022 data. OIG also reported:
- Slightly more than 570,000 enrollees received RPM in 2022, compared with about 55,000 in 2019.
- Payments in traditional Medicare and Medicare Advantage were more than 300 million dollars in 2022, compared with 15 million dollars in 2019.
- About 28 percent of enrollees who received RPM had no claim or encounter record for education and setup, about 23 percent had none for a device, and 12 percent never had one for treatment management.
OIG made five recommendations to CMS, including requiring that RPM be ordered and that information about the ordering provider appear on claims. The CMS remote patient monitoring page (opened October 4, 2026) says CMS does not currently require an order or ordering provider information on the claim, and tells providers to "be sure you provide all 3 main components." The OIG figures describe 2022 and the earlier code set. They are not a measure of any one program.
What are the three components of RPM billing?
CMS describes three main components: education and setup, device supply, and treatment management. The CMS page says the device must collect and transmit data at least 2 days every 30 days, and that Medicare covers RPM for chronic and acute conditions using internet-connected devices. For 2026, CMS adopted the CPT code changes in the CY 2026 Physician Fee Schedule final rule, 90 FR 49266 (CMS-1832-F), opened October 4, 2026. The rule describes two new codes, 99445 for device supply covering 2 to 15 days of data transmission in a 30-day period and 99470 for the first 10 minutes of treatment management. It says the 2 to 15 day codes (99445) and the 16 to 30 day codes (99454) "are not additive," and that billing practitioners "would only bill for one of those codes." The first 10 minute code (99470) and the first 20 minute code (99457) are also not additive. IHS builds these rules into billing logic and staff decision trees, and your billing lead confirms them against current CMS and payer text.
How do FQHCs and rural health clinics fit?
For rural health clinics and federally qualified health centers, the same Federal Register document says: "RPM and RTM services are currently paid separately from the RHC AIR and FQHC PPS as care coordination services." IHS drafts RPM policies and workflows for these organizations, and their billing staff confirm payment treatment against the current rule.
What RPM compliance services does IHS offer?
RPM gap assessment and baseline audit
IHS reviews your program against the three components CMS describes, the gaps OIG reported and the 2026 code changes. The review covers clinical workflows, EHR capabilities, time tracking records, patient consent records and device documentation. The deliverable is a written gap report with a ranked remediation list. It suits any organization that bills RPM, plans to start, or is preparing for an audit.
CPT billing logic review
IHS maps your billing workflow to the code set in the final rule above, so that device supply and treatment management codes follow the non-additive rules the rule describes. IHS drafts the logic, the EHR trigger specifications and the staff decision aids.
Mock audit review against OIG findings
IHS tests your records against the gaps in the OIG report: missing components, missing ordering information and thin documentation. It produces remediation documentation your organization can use in its own response to any audit request. Your counsel handles any contact with an auditor or agency.
Policy and procedure development
IHS drafts the program, policies and clinical content for your clinicians to review and approve. The set covers patient consent and identity verification, time tracking, escalation of abnormal readings, device logistics and EHR integration records.
State Medicaid RPM overlay
IHS reads the published policy of each state agency in which you operate against your program and produces a state checklist layered on your federal baseline. Your billing lead confirms it with the agency.
How does an RPM compliance engagement work?
- Gap assessment of workflows, EHR capability and billing practice.
- Policy and procedure drafting and billing logic rebuild.
- Workflow integration: consent protocols, EHR data flow and staff credentialing checks.
- Staff education and a mock audit review of your records.
- Remediation of what the mock review found, and a readiness checklist.
The length of each step depends on program size and gap severity, and IHS sets the plan at the discovery session. If you are pursuing accreditation for the program, see accreditation consulting.
Who does RPM compliance consulting serve?
| Organization | Typical focus |
|---|---|
| Medical practices | Billing logic, documentation, staff training |
| Hospital and health systems | Enterprise gap assessment, policy development |
| FQHCs and rural health clinics | Standing up a program, policies and workflows |
| Home health agencies | Device logistics, data transmission and escalation records |
| RPM platform vendors | Review of compliance documentation against Medicare requirements |
| Investors in digital health | Compliance review of an RPM program before or after a transaction |
What does RPM compliance consulting cost?
The cost has three parts: your own staff time, any outside billing or legal review, and the consulting fee. CMS sets Medicare payment rates in the fee schedule rule linked above, and IHS does not quote them. IHS sets a fixed fee for each engagement after a free discovery session, because scope, number of sites and gap severity change the work.
What this is not
IHS is not a law firm and does not give legal advice or a billing opinion. Your billing lead and counsel make those calls.
IHS does not file claims, respond to auditors or contact CMS or payers for you. Your organization's named contact does, using text IHS drafts.
IHS does not guarantee an audit outcome or payment.
Frequently asked questions
What are the main RPM compliance risks?
OIG found that about 43 percent of Medicare enrollees who received RPM in 2022 did not receive all three components, and that Medicare lacked ordering provider information. It also cited fraud concerns about companies signing up enrollees who did not need the service. IHS reviews your program against these findings.
What new CPT codes apply to RPM in 2026?
The CY 2026 Physician Fee Schedule final rule describes two new codes: 99445 for device supply covering 2 to 15 days of data transmission and 99470 for the first 10 minutes of treatment management. See the RPM billing guide for the code set.
Can federally qualified health centers and rural health clinics bill RPM?
The final rule says RPM and RTM services are currently paid separately from the RHC AIR and FQHC PPS as care coordination services. Their billing staff confirm the payment treatment against the current rule. IHS drafts the program policies and workflows.
Does IHS sell RPM software or devices?
No. IHS does not sell RPM devices, software platforms or monitoring subscriptions. IHS offers consulting. IHS also offers Starfinch.
Who communicates with the regulator, IHS or my organization?
Your organization does. IHS drafts the text and your named contact or counsel sends it under your name.
How long does it take to build a compliant RPM program?
It depends on program size, number of sites and gap severity. IHS sets the plan and schedule with you after a free discovery session.
Who is this not for?
It is not for an organization that wants a legal opinion on a billing question or wants IHS to respond to an auditor for it. IHS does neither. It suits organizations that bill or plan to bill RPM and need gaps found and policies drafted.
Ready to review your RPM program?
A free discovery session covers your current billing, documentation and policies and what a gap assessment would involve.
Schedule a Free Discovery Session
Related Services
- Telehealth Accreditation: URAC Telehealth Accreditation consulting for organizations delivering care through digital modalities.
- RPM vs. RTM vs. CCM: side-by-side comparison of Remote Patient Monitoring, Remote Therapeutic Monitoring and Chronic Care Management.
- RPM Billing Guide: the CPT code reference for RPM.
- RPM Compliance FAQ
- Compliance Services: the full list of IHS compliance work.