Thomas Ferrante on Rise of RPM Company Audits – “It’s Just So Complicated”

Foley & Lardner LLP partner Thomas Ferrante commented on the federal government’s increased scrutiny of remote patient monitoring (RPM) company practices in the Fierce Healthcare article, “HHS watchdog raised concerns over remote patient monitoring companies. Audits are now on the rise.”

Ferrante said that with the government’s focus on RPM billing practices, health systems have begun internal reviews of their RPM programs and third-party RPM vendors. “The audits have ranged from mundane internal audits to criminal investigations,” and some have uncovered legitimate issues related to improper billing. One example is missing documentation of the medical need for the individual patient. “Key elements of the code criteria are just blatantly missing and those claims are still being submitted, and part of that is happening most prominently in situations where there’s the third-party RPM companies,” Ferrante said. 

Some of the misunderstandings or mistakes may stem from having to navigate complex new codes introduced in 2019. “It’s just so complicated,” he said. “There’s always some error rate of mistakes. So, not surprisingly, things come up in those audits. Sometimes it’s not worrisome. Sometimes it’s, ‘What the heck has been going on?’”