Remote Patient Monitoring: Contract Structures, Medicare Coverage, and Regulatory Compliance

Recording of a 90-minute CLE video webinar with Q&A

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Conducted on Tuesday, February 1, 2022

Recorded event now available

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Course Materials

This CLE course will guide healthcare counsel on remote patient monitoring (RPM). The panel will examine reimbursement issues and how the Medicare Physician Fee Schedule 2021 and 2022 Final Rules and other recent changes impact the landscape for RPM reimbursement. The panel will also address challenges of RPM, such as privacy and security, and will discuss compliance considerations.


The Medicare Physician Fee Schedule 2021 Final Rule and subsequent guidance revised Medicare payment policies for remote physiologic monitoring. RPM can be provided "incident to" under general supervision, thereby making it less burdensome for providers to furnish RPM services. Medicare regulations define an "incident to" service as one performed under the supervision of and billed to Medicare by a qualified healthcare professional.

The Medicare Physician Fee Schedule 2022 Final Rule expands Medicare RPM payment codes to include remote therapeutic monitoring (RTM), in addition to previously covered remote physiologic monitoring codes. Those utilizing RPM must ensure they comply with licensure, scope of practice, and other requirements to be eligible for reimbursement.

Further, patient monitoring has historically been set up in healthcare facilities, while RPM and the associated monitoring equipment are deployed in the patient's home. This difference presents risks, including to data privacy and security. Among other issues, wireless networks, platforms, and devices are susceptible to being hacked, allowing access to sensitive health information, and many questions have arisen about considerations for patients' privacy and the security of their information.

As healthcare provider organizations seek to invest in and utilize RPM solutions, particularly as patients have become accustomed to remote care during the pandemic, they should consider the risks and compliance challenges to RPM and understand the reimbursement landscape.

Listen as our authoritative panel of healthcare attorneys examines reimbursement and how the Medicare Physician Fee Schedule, as well as other changes, impact the landscape for RPM. The panel will also address the challenges of RPM, such as privacy and security, as well as compliance considerations.



  1. Reimbursement standards
    1. Remote physiologic monitoring
    2. Remote therapeutic monitoring
  2. RPM contracting, collaboration, and supervision structures
  3. Risks
    1. Privacy
    2. Security
  4. Compliance considerations
    1. Licensure
    2. Scope of practice
    3. Payment and regulatory flexibilities during the COVID-19 Public Health Emergency
    4. State and federal data privacy and security requirements


The panel will review these and other key issues:

  • How has reimbursement for RPM changed under the 2022 Medicare Physician Fee Schedule, and what should we anticipate for 2022?
  • What are the key distinctions between the RTM and remote physiologic monitoring billing codes?
  • How can healthcare providers collaborate with clinical staffing companies, IT, and medical device vendors and others to furnish RPM?
  • What are the privacy and security risks associated with RPM?
  • How should HIPAA covered entities, business associates, and others implement such devices while protecting data privacy and security?
  • What steps should healthcare providers take to ensure compliance with RPM requirements?


Hindmand, Rick
Rick L. Hindmand

McDonald Hopkins

Mr. Hindman focuses his practice on healthcare regulatory, data privacy, cybersecurity, corporate, and...  |  Read More

Peters, Iliana
Iliana L. Peters


Ms. Peters is recognized by the healthcare industry as a preeminent thinker and speaker on data privacy and security,...  |  Read More

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