RPM in healthcare, or remote patient monitoring, is a care model in which patients take readings such as blood pressure, weight or blood glucose at home on a connected device, and the care team reviews the data and adjusts treatment between visits. For a provider, it is a program to run, not only software to buy.
This guide covers running that program: who to enroll and how, device and logistics choices, how the CY 2026 Medicare codes fit a month, who does which job, what consent and documentation are needed, and the checks that keep a program defensible in an audit.
What does it take to run an RPM program?
Setting up remote patient monitoring?
Agnotic builds remote patient monitoring software for the client, including enrollment, device data intake, care team workbenches and billing ledgers.
Running an RPM program means a provider enrolls established patients who need monitoring, supplies a connected device, makes sure readings arrive automatically, assigns clinical staff to review data and talk with patients, and documents the work so each 30-day period and calendar month can be billed correctly under Medicare's remote physiologic monitoring rules.
The software is one part of that. The rest is clinical ownership, device logistics, staffing and a monthly routine that turns readings into treatment decisions.
Programs that start with one condition and one care team are easier to run well. Each added condition brings its own devices, targets and escalation rules.
Which Medicare rules govern an RPM program?
Medicare's core RPM rules were restated in the CY 2024 Physician Fee Schedule final rule, and a program needs each of them in its written policies. These are the ones that shape daily operations.
- Established patients: Since the end of the COVID-19 public health emergency, RPM may be furnished only to established patients.
- Devices and billers: Data must come from at least one device that meets the FDA definition of a medical device, and only one practitioner can bill the setup and device codes for a patient in a 30-day period, however many devices the patient uses.
- Combinations: RPM or RTM, but not both, can be billed with CCM, TCM, BHI, PCM or chronic pain management for the same patient when time and effort are not counted twice.
Turn each rule into a check the software runs, not a line in a policy binder. Enrollment should refuse a patient with no prior visit, the device ledger should refuse a second biller in the same period, and the time ledger should refuse a minute already counted toward another service.
Payment rules for remote monitoring also change from year to year. Read each new Physician Fee Schedule rule for changes to who may furnish monitoring and what must happen before an episode starts, and keep those settings in configuration rather than code.
How do the CY 2026 codes fit a month?
The CY 2026 codes split device supply by days of data in each 30-day period and treatment management by minutes in each calendar month. A program has to track both clocks for every patient.
- 99453 setup: Initial setup and patient education on the equipment, at the start of monitoring.
- 99445 device supply: 2 to 15 days of data in a 30-day period, new for 2026.
- 99454 device supply: 16 to 30 days of data in a 30-day period. CMS states that 99445 and 99454 are not additive, so one of them is billed per period.
- 99470 management: The first 10 minutes of treatment management in a calendar month, new for 2026. CMS adopted the CPT language that 99470, 99457 and 99458 require a live, interactive communication with the patient or caregiver.
- 99457 and 99458 management: The first 20 minutes, then each additional 20 minutes. CMS states that 99470 and 99457 are not additive; the practitioner picks the code that fits the month's time.
The two clocks rarely line up. A 30-day device period that starts on the 12th crosses a calendar month boundary, so the software and the staff routine must show both the current device period and the current management month.
Days with readings drive the device codes, while minutes and the live conversation drive the management codes. A month with plenty of readings but no conversation with the patient supports device supply only.
Who should be enrolled, and how?
Enroll patients whose treatment the data will actually change, with a clinician's order and a documented reason. Recording who ordered monitoring, and why, costs little at enrollment and answers the first question any reviewer asks.
- Clinical reason: The condition, the measure to watch and the decision the readings will inform, such as titrating blood pressure medication.
- Established relationship: Confirm the patient is already established with the billing practitioner's practice before enrollment.
- Consent: Record that the patient agreed, who obtained it, when, and what the program involves.
- Fit and ability: Check cuff size, scale weight limits, vision, dexterity and whether a caregiver will take the readings.
- Connectivity: Choose cellular devices for patients without a reliable smartphone or home internet.
- Exit criteria: Define when monitoring ends, such as targets met for an agreed period or the patient declining further readings.
Exit criteria are easy to leave blank. Patients who stay enrolled after the data stops changing their care cost staff time every month and weaken the case that monitoring is necessary, so review each patient against the exit criteria at least once a quarter.
Run enrollment as a short, repeatable visit: confirm the order, record consent, fit and pair the device, take a first reading together, and book the first review call. A patient who leaves without a successful first reading is the most likely to miss the day thresholds in the first period.
Devices and logistics
Device choice and logistics decide how many patients reach the day thresholds. A device that is hard to pair or charge loses readings no matter how good the clinical team is.
- Cellular or Bluetooth: Cellular devices send readings without a phone; Bluetooth devices rely on a paired app that the patient must keep running.
- Shipping and setup: Decide whether devices are handed out in clinic or shipped, and who walks the patient through the first reading.
- Replacement: Keep spares and a process for batteries, failed units and lost devices, with each swap recorded against the patient.
- Returns and reuse: Track returned devices, clean them and clear any stored data before reissue.
- Patient-owned devices: Accept them only if they meet the device definition and transmit automatically, and record the make, model and serial number like any program device.
Track every device by serial number against a patient and a date range. When a payer asks which device produced a period's readings, the answer should come from the record, not from memory.
How should an RPM program be staffed?
An RPM program needs non-clinical staff for devices and outreach, clinical staff for treatment management, and a billing practitioner who directs care. Education and device work can sit with coordinators, while reviewing readings and talking with patients about treatment is clinical work.
- Program coordinator: Enrollment paperwork, device shipping, pairing problems and missed-reading calls.
- Clinical staff: Registered nurses or other clinical staff who review readings, hold the live conversations and document management time.
- Billing practitioner: A physician or other practitioner eligible to bill RPM, who sets targets and takes escalations.
- Billing lead: Reviews each month's codes against the device and time ledgers before claims go out.
Decide early which of these roles are employed and which are contracted. Medicare policy on outsourced monitoring staff has been under review, so any contract for outside monitoring staff should allow the work to move in-house if the rules change.
Write a daily routine for the clinical staff: work the urgent readings first, then the patients with no readings in several days, then the scheduled monthly conversations. A routine keeps live interactions spread across the month instead of crowded into its last week.
What should a monthly RPM audit check?
A monthly audit should confirm that each billed patient received the full service, not only the device. OIG found that about 43 percent of Medicare enrollees who received RPM in 2022 did not receive all three components: education and setup, device supply, and treatment management.
- Order and reason: Every enrolled patient has a documented order and clinical reason.
- Consent on file: Dated before or at the start of services.
- Device days: Days with automatic readings counted per 30-day period and matched to the code billed.
- Management time: Minutes per calendar month by staff member, with the live interaction identified.
- Single biller: No other practitioner billed setup or device codes for the same period.
- No overlap: Time not counted toward CCM, PCM or another service as well as RPM, and no RTM billed in the same period.
- Action taken: A sample of months where readings changed treatment, showing the data is used.
Run the audit before claims go out, not after. Corrections at that point cost minutes; corrections after payment cost refunds and trust.
How Agnotic can help
Running RPM well depends on software that keeps devices, readings, minutes and conversations in one record. Agnotic Technologies builds RPM software for provider groups and digital health teams: enrollment with order and consent capture, device data intake, nurse workbenches, device inventory, and ledgers that track 30-day device periods and monthly management time side by side.
Agnotic also builds the pre-claim audit reports and EHR summaries a billing lead needs, so the program can show what was done for each patient in each period.
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