Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM): A Deep Dive into Proposed Medicare Changes

The 2021 Final Rule by CMS emphasized that Remote Patient Monitoring (RPM) services are exclusively available to "established patients." CMS justified this by noting that physicians with existing patient relationships would have conducted an initial Evaluation and Management (E/M) service, gathered pertinent medical history and performing relevant exams. This information is crucial for comprehending the patient's current health status and requirements before implementing RPM for data collection and treatment planning. During the Public Health Emergency (PHE), CMS temporarily waived this "established patient" restriction but decided not to extend it beyond the PHE in the 2021 Final Rule. Consequently, practitioners generally need to conduct a new patient E/M service before commencing RPM. In the 2024 Proposed Rule, CMS clarifies that patients who initially received remote monitoring services during the PHE are now considered established patients. It's worth noting that CMS specifically mentions RPM and not Remote Therapeutic Monitoring (RTM) in the context of the "established patient" requirement. Stakeholders should seek CMS clarification on whether this requirement applies to both RPM and RTM services.