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

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

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, February 15, 2023

Recorded event now available

or call 1-800-926-7926

This CLE course will guide healthcare counsel on remote patient monitoring. The panel will examine reimbursement standards for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM). The panel will also address privacy, security, and compliance challenges of remote patient monitoring.


Since Medicare began paying for RPM services in 2018 the Centers for Medicare & Medicaid Services (CMS) has expanded RPM coverage with additional codes and guidance, and in 2022 began covering RTM. On Nov. 1, 2022, CMS released the CY2023 final rule for services reimbursed under the Medicare Physician Fee Schedule (MPFS). The final rule changes to Medicare Part B professional payment policies and rates for 2023. The final rule allows payment under new RTM device codes for cognitive behavioral therapy and loosens supervision standards for RTM. CMS did not finalize its proposal to replace RTM codes with new G codes, which CMS recognized was creating confusion.

CMS has revised Medicare payment policies for remote patient monitoring so that RPM and RTM can be provided "incident to" under general supervision, thereby making it less burdensome for providers to furnish remote patient monitoring services.

Those utilizing RPM or RTM must ensure they comply with licensure, scope of practice, coding and related 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 or RTM 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 recent changes impact the landscape for remote patient monitoring. The panel will also address the challenges of remote patient monitoring, such as privacy and security, as well as related compliance considerations.



  1. Reimbursement standards
    1. RPM
    2. RTM
  2. RPM and RTM contracting, collaboration, and supervision structures
  3. Risks
    1. Privacy
    2. Security
    3. Payor audits
    4. Fraud and abuse
  4. Compliance considerations
    1. Professional qualifications for supervision and billing
    2. Self-referral and anti-kickback
    3. Payment and regulatory flexibilities during the COVID-19 PHE
    4. State and federal data privacy and security requirements


The panel will review these and other key issues:

  • How have reimbursement standards for RTM changed under the 2023 MPFS?
  • What are the key distinctions between the RTM and RTM billing codes?
  • How can healthcare providers collaborate with clinical staffing companies, IT, and medical device vendors and others to furnish remote patient monitoring?
  • What are the privacy and security risks associated with remote patient monitoring?
  • 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 and RTM 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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