10/10/2024    Paul Kessleman DPM

OIG Report on Remote Patient Monitoring

It was interesting to have read this report from
the OIG which is full of misleading facts and
information. For one, they suggest a significant
increase in the expenditures for Remote
Physiologic monitoring over a two year period of
time. Which years did they pick to compare? Not
the previous two years, but the year prior to and
the initial year after institution of the RPM
codes. The starting point has to be 0 (or almost
0) and the end point for the first year, one would
hope would be more than 0. So an exponential
increase? Where are the examples of abuse here?

As for patients not receiving all three CPT codes
each month? That would be incorrect on the face of
it and abusive. The only month patients are
entitled to be billed for all 3 codes, would be
the first 30 days of their episode of care.
That is because the first 30 days of their episode
of care they are entitled to the education CPT
(99453)

After that, patients are only entitled to 2 codes,
one for the supply of the device (99454) and the
use of the RPM device (99456/7).AND: If the
patient did not fulfil the required number of days
for a specific time (16/30) then billing is not
allowed.This is not an example of fraud or abuse,
but an example of providers actually being
compliant.

These are just two examples of the many other
errors in this report. There is currently a push
to have this report retracted and perhaps at the
very least it needs to be very heavily edited and
re-released!

It is important to note that at an NIH hearing I
spoke at last year on digital technology in
diabetes care was held last year and their
researchers came to the exact opposite conclusion.
The researchers from NIH were very positive on the
use of RPM in general and were intrigued in
tracking foot temperature and pressure in order
to reduce the costs and incidence of DFU and
amputations.

No doubt there are abuses with many coding
scenarios, including E/M etc. but for the OIG to
use baseless and misleading facts is also abusive.
Normally I embrace OIG reports as a wake up call
for crooked practitioners and for honest
practitioners to be sure they are documenting
correctly.

But this time at the very least, the OIG needs to
retract some of the baseless and damaging
accusations, which I fear will deter honest
practitioners from all specialties from
participating in RPM.

Paul Kesselman, DPM, Oceanside, NY

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