FairPath: Run Your Own RPM Program

Addressing Every Remote Care Challenge

Key Features

Eligibility Verification

Coverage errors derail claims early

FairPath’s AI verifies patient eligibility across Medicare, Medicare Advantage, and dual plans before RPM enrollment—flagging capitated, ineligible, or uncovered patients. This prevents the most common RPM error: onboarding patients whose data can’t be billed.

Benefit: Prevents denials from the outset and protects your program from CMS ratio flags.

Smart Claims Coding

Coding mistakes lead to rejections

FairPath’s AI is built to handle RPM, RTM, and CCM codes with payer-specific nuance. It manages timing gaps, validates ICD-10 mappings, and aligns each CPT with the correct episode—ensuring your 99453, 99454, 99457, and 99458 codes reflect real services.

Benefit: Clean claims mean faster approvals and compliance with Medicare episode timing rules.

Automated Prior Authorization

Slow approvals delay revenue

Prior auths for RPM devices and CCM services can drag on. FairPath automates payer submissions—collecting consent, patient condition data, and historical usage to pre-fill forms and trigger faster reviews.

Benefit: Cuts approval times significantly and documents medical necessity automatically.

AI-Driven Claim Status Tracking

Manual insurer calls waste hours

FairPath’s system bypasses long payer hold times. It navigates IVRs, retrieves up-to-date statuses, and flags at-risk claims automatically—while our team escalates only when needed.

Benefit: Speeds up resolution with zero staff effort and prevents denials from aging out.

Denial Management & Appeals

Denials are costly and time-consuming

Using OIG-aligned pre-checks, FairPath detects risks before submission—like insufficient days of readings or duplicate 99453s. When denials do occur, our team handles appeals with full documentation history and justification letters.

Benefit: Recovers revenue while shielding your team from the audit and appeals process.

Seamless Documentation

Missing records trigger rejections

FairPath captures every RPM and CCM interaction—calls, consents, education, readings, time logs—into a HIPAA-compliant audit trail. We integrate with your EMR or portal to log every event with timestamps and transcripts.

Benefit: Eliminates a top denial cause and defends against OIG clawbacks and audits.

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Addressing Every Remote Care Challenge

Key Features

FairPath equips practices with a complete toolkit for remote patient monitoring (RPM), chronic care management (CCM), and remote therapeutic monitoring (RTM). Each feature is designed for compliance, audit readiness, and clinician efficiency. Below is a breakdown of the main modules, each supported with examples, FAQs, and screenshots.

Device Inventory & Assignment

Why it matters: Every RPM program starts with devices. Mismanaged equipment leads to billing errors, patient frustration, and compliance gaps.

How it works:

Physicians and staff can add devices into the system, each tagged with a unique serial number and status (active, inactive, returned).
Devices can be directly assigned to patients, ensuring accountability for CPT 99454 billing (16+ days of transmitted data).
Staff can filter by device type (blood pressure cuff, weight scale, glucometer, pulse oximeter) or status to quickly identify which patients are missing equipment or which devices need replacement.

Patient Onboarding & Consent Capture

Why it matters: Medicare requires documented patient consent before billing RPM (CPT 99453). FairPath automates this process.

How it works:

New patients can be added with demographic details (name, DOB, insurance, language preference, contact info).
Consent forms are captured directly in the system—via electronic signature, verbal consent logging, or scanned uploads.
Training sessions are documented to ensure CPT® 99453 compliance, and shipping addresses are validated for device delivery.

Priority Q Clinical Dashboard

Why it matters: Clinicians need to see the right data at the right time—without digging through endless charts.

How it works:

The Priority Q dashboard organizes all tasks into a queue: critical alerts (abnormal readings), pending reviews, missed transmissions, and required follow-ups.
Each task includes direct links to the patient profile, most recent readings, and audit trail of prior actions.
Clinicians can triage alerts, document interventions, and log time for CPT® 99457/99458.
Recent patients appear at the top, helping providers return quickly to ongoing reviews.

Integrated Communication: Calls & SMS

Why it matters: Engaging patients boosts compliance. Medicare audits require documentation of patient outreach attempts.

How it works:

Built-in click-to-call feature lets staff call directly from the platform, with call logs stored automatically in the patient record.
Automated or manual SMS reminders can be sent for device usage, upcoming check-ins, or missed data transmissions.
Communication logs ensure outreach is documented and available during audits.

Patient Review & Profile Workflow

Why it matters: Clinicians must document monthly reviews to support compliance and continuity of care.

How it works:

Each patient profile displays 1-month average, trend graphs, and compliance tracking for CPT code progress.
Providers can log review notes, intervention outcomes, and total time spent in compliance with 20+ minute monthly review requirements.
The profile centralizes demographics, device assignments, communication history, and review tasks—all in one screen.

Billing, Compliance & Reporting

Why it matters: Billing accuracy determines whether practices are reimbursed—or audited.

How it works:

FairPath automatically tracks patient days of device usage, review time, and provider interventions against CPT requirements (99453, 99454, 99457, 99458).
Billers can view a BillingQ screen to confirm claim readiness, sort by code completion, and identify gaps.
End-of-month reports outline performance per patient and per code, ensuring providers bill only what they’ve earned—and are protected in audits.

Smart Claims Coding

Coding mistakes lead to rejections

Benefit: Clean claims mean faster approvals and compliance with Medicare episode timing rules.

Automated Prior Authorization

Slow approvals delay revenue

Benefit: Cuts approval times significantly and documents medical necessity automatically.

AI-Driven Claim Status Tracking

Manual insurer calls waste hours

FairPath’s system bypasses long payer hold times. It navigates IVRs, retrieves up-to-date statuses, and flags at-risk claims automatically—while our team escalates only when needed.

Benefit: Speeds up resolution with zero staff effort and prevents denials from aging out.

Denial Management & Appeals

Denials are costly and time-consuming

Benefit: Recovers revenue while shielding your team from the audit and appeals process.

Seamless Documentation

Missing records trigger rejections

Benefit: Eliminates a top denial cause and defends against OIG clawbacks and audits.

Request a Demo →

In-House Remote Care Programs Overview

What Are the Benefits and Challenges of Running RPM, CCM, and RTM Programs In-House?

Healthcare organizations face a critical decision: should they manage Remote Patient Monitoring (RPM), Chronic Care Management (CCM), and Remote Therapeutic Monitoring (RTM) programs internally or outsource to external vendors?

What Are the Key Benefits of In-House RPM, CCM, and RTM Programs?

Operating RPM, CCM, and RTM programs internally provides healthcare organizations with full control over every aspect of patient care delivery. This autonomy enables complete customization of clinical protocols, care workflows, and patient interactions to align perfectly with organizational values and existing care standards.

Organizations can adapt programs in real-time based on patient feedback and clinical outcomes without waiting for vendor approval or lengthy implementation timelines. This flexibility allows for immediate responses to patient needs and regulatory changes.

How Does In-House Management Improve Care Continuity?

In-house programs create seamless integration with existing clinical workflows and electronic health record (EHR) systems. Patients benefit from consistent communication with familiar care team members who understand their complete medical history and personal preferences.

This continuity enables better coordination between primary care providers, specialists, and remote monitoring staff, resulting in improved patient satisfaction scores and superior clinical outcomes compared to fragmented vendor-managed programs.

What Are the Financial Advantages of Internal Program Management?

Direct billing and revenue management allows healthcare organizations to capture 100% of reimbursement potential from Medicare, Medicaid, and commercial payers. Without vendor fees or revenue-sharing arrangements, healthcare systems retain complete financial benefits while building sustainable long-term revenue streams.

Organizations maintain complete flexibility in pricing strategies and can quickly adapt to changing reimbursement landscapes, maximizing profitability from CMS billing codes including CPT 99453-99458 (RPM) and 99490-99491 (CCM).

How Does In-House Management Enhance Quality Control?

Internal program management provides direct oversight of clinical quality measures, staff training protocols, and regulatory compliance standards. Organizations ensure care delivery meets their specific quality standards and can implement improvements immediately based on performance metrics and patient outcomes.

This direct control proves particularly valuable for maintaining Joint Commission accreditation requirements, NCQA recognition standards, and Medicare quality reporting obligations without relying on third-party compliance.

Why Is Data Ownership Important for Healthcare Organizations?

All patient data, clinical outcomes, and program performance metrics remain within the organization's complete control, enabling comprehensive analytics and quality improvement initiatives. This data ownership supports internal research opportunities, population health management strategies, and evidence-based program enhancements.

Healthcare systems can leverage this data for value-based care contracts, risk adjustment modeling, and clinical research partnerships without sharing sensitive information with external vendors.

How Does In-House Management Address OIG Oversight Concerns?

The September 2024 OIG report "Additional Oversight of Remote Patient Monitoring in Medicare Is Needed" highlighted significant oversight challenges with third-party RPM providers. The OIG found that about 43 percent of enrollees who received remote patient monitoring did not receive all 3 components of it, raising questions about whether the monitoring is being used as intended.

In-house programs provide direct control over all three RPM components: patient education and device setup (CPT 99453), device supply (CPT 99454), and treatment management (CPT 99457/99458). This ensures complete service delivery and reduces audit risk from incomplete care documentation that triggers OIG fraud investigations.

What Are the Main Challenges of Running Programs In-House?

What's the Investment Required for Remote Care Programs?

RPM, CCM, and RTM program implementation typically involves substantial upfront costs that vary significantly depending on program scope. These expenses cover program management software licenses, monitoring device inventory, clinical staff expansion, and ongoing operational requirements.

Beyond the initial setup, organizations also need to plan for continuous technology updates, staff training, and compliance systems—investments that can take over a year to generate returns. For many practices, especially smaller ones, this traditional approach creates budget constraints that can delay or prevent program launch altogether.

The FairPath Solution

FairPath eliminates the need for large upfront investments. Through a simple flat fee per patient, you gain access to a comprehensive software suite that enables your practice to effectively run its own remote care program. FairPath was designed to help teams of all sizes—from small practices to large healthcare organizations—efficiently operate and scale these programs while delivering quality patient care and maintaining compliance and auditability.

What Technology Infrastructure Challenges Should You Expect?

Successful programs demand robust technology platforms capable of seamless device integration, real-time data management, clinical workflow automation, and comprehensive regulatory reporting. Organizations must either develop these capabilities internally or invest in enterprise-grade software solutions.

Additional requirements include IT support for system maintenance, cybersecurity compliance for HIPAA regulations, data backup systems, and 24/7 technical support infrastructure that many healthcare organizations lack internally.

The FairPath Solution

FairPath was designed to address all these needs and has already been used to review millions of patient readings, generating revenue while preventing hospitalizations. The integrated AI technology provides complete audit trails and documentation for every patient interaction, code achievement, and clinical milestone. FairPath serves as the comprehensive technology infrastructure you need to successfully operate your own remote care program.

What Staffing and Training Requirements Are Involved?

RPM, CCM, and RTM programs require specialized clinical staff trained in remote care protocols, technology platform operation, and complex Medicare billing requirements. Organizations face challenges recruiting qualified registered nurses, care coordinators, and clinical supervisors in competitive healthcare employment markets.

Comprehensive training programs require 40-80 hours per staff member, covering clinical protocols, technology systems, billing compliance, and patient communication skills. Ongoing education requirements and staff turnover management add significant operational complexity.

The FairPath Solution

FairPath enables small teams to operate comprehensive remote care programs, and scale when needed. All clinical protocols and billing requirements are integrated into the AI-powered platform, and through Intelligence Factory's proprietary technology, updates to protocols, coding, and regulatory requirements can be implemented seamlessly. We also provide comprehensive training on program management, software utilization, and ongoing customer support.

How Complex Are Regulatory and Compliance Requirements?

Healthcare organizations must navigate intricate Medicare Advantage and traditional Medicare billing requirements, HIPAA privacy regulations, state telehealth laws, and CMS quality reporting obligations. The September 2024 OIG report identified significant compliance gaps, noting that Medicare lacks key information for oversight, including who ordered monitoring services for enrollees.

The OIG found that CMS cannot systematically identify companies providing RPM services because many RPM companies are not enrolled Medicare providers. This creates substantial audit risk for organizations using third-party vendors, as Medicare cannot track service delivery chains or verify appropriate clinical oversight.

In-house programs eliminate third-party compliance risks by maintaining direct control over ordering providers, service delivery documentation, and billing practices. Organizations can ensure proper physician orders, maintain complete claims documentation, and provide transparent audit trails that satisfy OIG recommendations for strengthened oversight.

The FairPath Solution

Intelligence Factory's proprietary technology enables FairPath to generate comprehensive, transparent audit trails that automatically adapt to regulatory changes in real-time. Whether responding to CPT code updates, the upcoming transition from ICD-10 to ICD-11, or evolving regulatory requirements, our system provides the tools and technology necessary to implement these changes seamlessly.

What Scalability Challenges Should You Anticipate?

As programs expand to serve additional patient populations and chronic conditions, organizations must proportionally scale technology infrastructure, clinical staffing, and operational processes. Managing growth while maintaining consistent quality standards and financial performance requires sophisticated resource planning.

Patient volume increases from 100 to 1,000+ enrolled patients demand corresponding increases in staff capacity, technology licensing, device inventory, and management oversight that can strain organizational resources.

The FairPath Solution

FairPath was designed for scalability: whether you're enrolling 100 or 1,000 patients, the system provides the tools and technology necessary to scale safely while maintaining compliance. FairPath's comprehensive onboarding and management module enables practices to track and manage every step of the program, including patient onboarding, consent documentation, device inventory management and integration, and device shipment coordination. The integrated proprietary technology also generates patient qualification scores for every patient, regardless of population demographics.

In-House Remote Care Programs Overview

How to Run an RPM, CCM, and RTM Program

Successfully operating Remote Patient Monitoring (RPM), Chronic Care Management (CCM), and Remote Therapeutic Monitoring (RTM) programs requires systematic implementation across six core operational areas: patient identification and enrollment, clinical workflow integration, data management protocols, staff training and support, billing and compliance procedures, and program measurement and optimization.

Patient Identification and Enrollment Process

How Do You Identify Eligible Patients?

Healthcare organizations must systematically review their patient base to identify individuals with chronic conditions like hypertension, diabetes, heart failure, and COPD who would benefit from continuous monitoring. Medicare requires established patient relationships, meaning patients must have had a previous evaluation and management visit before enrolling in RPM services.

The most effective approach involves targeting patients with specific diagnosis codes who demonstrate high healthcare utilization, frequent office visits, or recent hospitalizations. Organizations typically start with 50-100 patients in pilot programs before scaling to larger populations.

The FairPath Solution

FairPath leverages AI trained on millions of anonymized patient records, interactions, and billing patterns to generate comprehensive qualification scores that accurately determine patient eligibility. These qualification scores enable practices to efficiently identify the most suitable candidates for their programs while saving time and maintaining compliance.

What Is the Patient Enrollment Workflow?

Patient enrollment can occur through multiple channels while maintaining regulatory compliance. Traditional enrollment happens during in-person office visits, but Medicare guidelines also permit remote enrollment through structured phone calls, allowing healthcare organizations to expand their reach and improve enrollment efficiency without requiring office visits.

The enrollment process includes medical necessity determination, insurance verification, device selection based on patient conditions, comprehensive patient education, and proper consent documentation. Organizations must document medical necessity, patient consent, and device distribution in compliance with Medicare requirements, whether enrollment occurs in-person or remotely.

The FairPath Solution

Once a patient is determined eligible, the FairPath Onboarding Module provides users with detailed patient profiles that include diagnosis with ICD-10 codes, insurance information, device recommendations, and all necessary enrollment data. The integrated consent feature enables practices to obtain patient consent both in-office and remotely through phone calls. All interactions can be documented manually, while the system simultaneously provides automatic phone call transcription. This comprehensive documentation ensures practices maintain all required records for regulatory compliance.

Clinical Workflow Integration

How Do You Structure Daily Clinical Operations?

Remote Care Programs programs require dedicated clinical staff to review transmitted patient data, analyze health trends, and coordinate patient communications. For RPM, for instance, Medicare billing requires at least 20 minutes monthly of qualified healthcare professional time for treatment management activities.

Effective workflows typically assign one or more clinical staff members to review, depending on patient acuity levels and population. Clinical staff monitor incoming data alerts, conduct routine data reviews, communicate with patients about concerning readings, and coordinate with primary care providers for care plan modifications.

The FairPath Solution

While FairPath provides the flexibility for clinical teams to assign reviewers based on their patient populations, the platform's real-time workflow consolidation and intuitive design enable even single-person teams to efficiently perform patient reviews and communication. This streamlined approach saves time while ensuring patients receive the attention they need, both within the remote care program and during in-office visits.

What Are the Clinical Review Protocols?

Clinical staff must establish systematic protocols for triaging patient data based on severity levels. Critical readings requiring immediate intervention (such as severely elevated blood pressure) need same-day response protocols, while routine monitoring data can follow weekly or bi-weekly review schedules.

Organizations typically implement different alert systems based on internal operations: red alerts for emergency situations requiring immediate clinical intervention, yellow alerts for concerning trends needing clinical review within 24-48 hours, and green status for normal readings requiring routine monitoring.

The FairPath Solution

FairPath's clinical module provides clinical staff with the the tools necessary to review patients, keep track of CPT code achievements, all while prioritizing the most important patients. The ReviewQ is a smart inbox where new patient readings are sent and sorted based on urgency or level of attention required. The Patient Portal allows users to see the patient history, most recent reading, and CPT code completion. Additionally, the communication features allow clinicians to remotely contact patients, either by phone or text, and every single interaction is timestamped and documented ensuring compliance.

Data Management and Technology Operations

How Do You Handle Device Distribution and Management?

Healthcare organizations must establish systematic processes for device inventory tracking, patient distribution, technical support, and device retrieval. Successful programs maintain detailed records of device serial numbers, patient assignments, distribution dates, and return schedules.

Device management includes initial setup assistance, ongoing technical support, battery replacement coordination, and troubleshooting for connectivity issues. Organizations typically maintain 10-15% excess device inventory to accommodate patient needs and device replacements.

The FairPath Solution

FairPath streamlines device distribution and management through its integrated Inventory Portal, giving practices complete visibility into every device’s status, location, and assignment. Staff can track serial numbers, patient assignments, distribution dates, and return schedules in one place, while automated updates capture battery levels, last readings, and connectivity status. The system supports efficient onboarding, retrieval, and redeployment, helping maintain the recommended excess inventory without overstocking. By centralizing technical and logistical oversight, FairPath reduces manual tracking errors and ensures devices stay in service, charged, and connected—so remote care programs run smoothly from setup to return.

What Are the Data Collection and Transmission Requirements?

Medicare requires patients to transmit physiologic data at least 16 days every 30-day period for proper billing. Healthcare organizations must monitor patient compliance with data transmission requirements and implement protocols for addressing non-compliance issues.

Data management systems must automatically collect transmitted readings, store information securely in HIPAA-compliant platforms, integrate with electronic health records, and generate clinical reports for provider review. Organizations need robust cybersecurity measures and data backup systems to protect patient information.

The FairPath Solution

FairPath’s Clinical module, including PriorityQ, is built to meet Medicare’s data collection and transmission requirements by automatically capturing and storing patient readings in a HIPAA-compliant environment. The system records the date and details of each reading, flags out-of-bounds results, and displays last reading dates so staff can quickly identify non-compliance. Integrated patient status filters and event categories (e.g., “No Data” or “Device Problem”) allow teams to proactively address transmission gaps.

Staff Training and Operational Support

What Training Do Clinical Staff Need?

Clinical personnel require comprehensive training covering remote care technology platforms, clinical review protocols, patient communication techniques, Medicare billing requirements, and regulatory compliance standards. Initial training typically requires covering both technical and clinical competencies.

Ongoing education includes device troubleshooting, clinical protocol updates, regulatory changes, and quality improvement initiatives. Staff must understand chronic disease management principles, remote care communication strategies, and documentation requirements for audit compliance.

The FairPath Solution

With FairPath, we are committed to helping medical practices successfully operate their remote care programs, regardless of their prior experience. This commitment extends beyond software training to comprehensive program guidance. When you first onboard with FairPath, you will receive training on all the essential components necessary to run your own remote care program.

How Do You Establish Operational Procedures?

Successful remote care programs develop standardized operating procedures covering patient enrollment, clinical review workflows, alert response protocols, patient communication scripts, billing procedures, and quality assurance measures.

Documentation includes step-by-step clinical workflows, emergency response procedures, billing compliance checklists, patient education materials, and staff performance evaluation criteria. Regular workflow optimization based on operational experience improves program efficiency and clinical outcomes.

The FairPath Solution

FairPath incorporates proven, optimized workflows that have been designed and refined since Medicare began incentivizing remote care. This means you receive not only a state-of-the-art software platform, but also integrated workflows that scale and adapt to your internal operations. Every process step is thoroughly documented and, most importantly, maintains compliance with all current regulations and procedural standards.

Your RPM Foundation

What Is Remote Patient Monitoring?

Remote Patient Monitoring (RPM) revolutionizes healthcare by enabling providers to track patients' physiologic data—such as blood pressure, glucose, or heart rate—outside clinical settings using connected, FDA-approved devices. Launched by Medicare in 2018, RPM enhances chronic and acute condition management, delivering real-time insights that improve outcomes and reduce costs.At FairPath, we're here to demystify RPM, offering a comprehensive resource on billing codes, compliance, and best practices tailored for 2025. Whether you're starting out or optimizing your program, this guide answers your questions and establishes your confidence in RPM.

Understanding RPM CPT® Codes

RPM services are billed using specific CPT® codes, each tied to distinct tasks—setup, device supply, and management. Here's a detailed breakdown based on Medicare's 2025 guidelines:

CPT® 99453: Initial Setup and Patient Education

Description
Covers one-time setup of the RPM device and patient training.

Requirements
Billable once per episode of care (from RPM initiation to treatment goal completion). Requires at least 16 days of data collection in the first 30-day period (post-COVID PHE).

Who Can Bill
Physicians or qualified healthcare professionals (QHCPs) like MDs, DOs, NPs, or PAs eligible for E/M services. Clinical staff can perform under general supervision.

Documentation
Record device delivery date, training completion, and patient consent.

Payment:
~$19 (2025 Medicare estimate).

Common Question
"Can I bill 99453 if the patient uses it less than 16 days?"
No—16 days of data are required in the initial period.

CPT® 99454: Device Supply and Data Transmission

Description
Monthly payment for supplying the device and collecting physiologic data.

Requirements
At least 16 days of readings or alerts in a 30-day period (non-consecutive days count).

Frequency
Once per 30 days, covering all devices used.

Who Can Bill
Physicians/QHCPs; clinical staff monitor under general supervision.

Documentation
Log 16+ days of data transmission and a summary report (e.g., in EHR).

Payment
~$47 (2025 estimate, adjusted downward from 2024's $50 due to conversion factor).

Common Question
"What if I use multiple devices?"
Only one 99454 is billable per month, regardless of device count.

CPT® 99457: Treatment Management (First 20 Minutes)

Description
Covers 20+ minutes of management, including data review and interactive patient/caregiver communication.

Requirements
At least one synchronous contact (phone/video) per month; 16-day rule doesn't apply here.

Frequency
Once per calendar month.

Who Can Bill
Physicians/QHCPs; staff time counts under supervision.

Documentation
Log 20+ minutes with interaction details (e.g., "10-min call on 3/15 discussing BP trends").

Payment
~$48 (2025 estimate).

Common Question
"Does reviewing data alone count?"
No—interactive communication is mandatory.

CPT® 99458: Additional Management Time

Description
Add-on for each additional 20 minutes beyond the first 20.

Requirements
Full 20-minute increments (e.g., 40 min = 99457 + one 99458). Includes further interactive contact.

Frequency
Multiple units if justified by time.

Documentation
Detail additional time and interactions.

Payment
~$42 (2025 estimate).

Common Question
"Is there a limit?"
No strict cap, but medical necessity must support extra units.

How RPM Billing Cycles Work

RPM operates on a 30-day billing cycle for device codes (99453, 99454) and a calendar-month cycle for management codes (99457, 99458). Here's the process:

99453: Initial Setup
Bill once when initiating RPM, after confirming 16+ days of data in the first 30 days. Use the date thresholds are met as the service date.Add-on for each additional 20 minutes beyond the first 20.

99454: Device Supply
Bill every 30 days (e.g., Jan 15–Feb 13), ensuring 16+ days of data. Typically billed at period end (e.g., Feb 13).

99457/99458: Management
Bill once per calendar month (e.g., Jan 1–31), after accumulating 20+ minutes. Use the last day of the month or when time is met.

Common Question
"What if a patient starts mid-month?"
For 99454, count 30 days from start (e.g., Jan 15–Feb 13); for 99457, bill for January if 20 minutes are reached by Jan 31.

Tips
Align periods consistently (e.g., always calendar months) and track days/time meticulously to avoid gaps.

What Qualifies for RPM Billing?

RPM devices must meet strict criteria:

Automatic Transmission

Data must be electronically collected and transmitted—no manual patient input (e.g., a BP cuff syncing via Bluetooth qualifies; a paper log doesn't).

Physiologic Data

Measures vital signs, not self-reported symptoms (RTM covers the latter).

Examples

Digital scales, ECG patches, thermometers—all FDA-cleared with connectivity.

Common Question
"Can I use a smartphone app?""Is there a limit?"
Only if it's FDA-approved and paired with a device for physiologic data—not standalone symptom trackers.

Compliance Tip
Verify device FDA status and use a HIPAA-secure platform like FairPath.

Navigating RPM Compliance

RPM's growth has drawn regulatory scrutiny. Key considerations:

16-Day Rule

99453/99454 require 16+ days of data—fewer voids billing.

Interactive Communication

99457/99458 need real-time patient contact—document it.

Time Tracking

Log every minute for management codes; avoid overlap with CCM/TCM.

Fraud Risks

OIG (2024) flagged scams enrolling patients unnecessarily—ensure medical necessity.

Audits

Expect MACs to check data logs and consent.

Common Question
"What if I miss documentation?"
Incomplete records risk recoupment—FairPath documents everything for you.

Compliance Tip
Use RPM logs (e.g., "3/15: 10-min call, BP reviewed") and self-audit claims.

Who Pays for RPM?

Medicare (Part B)

Covers all codes; 20% coinsurance applies. Requires established patients and 16 days.

Medicare Advantage (MA)

Matches Medicare, but cost-sharing varies (e.g., $0 copays possible). May require prior auth.

Medicaid

42 states (2024) cover RPM; rules vary (e.g., Texas needs prior auth, NY targets chronic conditions).

Private Insurers

Most (e.g., UHC, Aetna, BCBS) align with Medicare's 16-day rule and codes; rates differ.

Common Question
"Will my insurer pay?"
Check plan specifics—Medicare standards often suffice.

Your CCM Foundation

What Is Chronic Care Management?

Chronic Care Management (CCM), launched by Medicare in 2015, supports patients with two or more chronic conditions through non-face-to-face care coordination—think phone calls, care plan updates, and medication management. CCM enhances outcomes by ensuring 24/7 access to a care team, fostering continuity for conditions like diabetes or heart disease.

FairPath's guide unpacks CCM's billing codes, compliance rules, and technology, giving you the tools to streamline care and reimbursement in 2025.

Understanding CCM CPT® Codes

Medicare's CCM CPT® codes vary by staff involvement, complexity, and time spent. Here's your 2025 breakdown:

CPT® 99490: Non-Complex CCM

Description
20+ minutes of clinical staff time monthly, supervised by a physician/QHP.

Requirements
Care coordination; comprehensive care plan in a certified EHR.

Who Can Bill
Physicians, NPs, PAs, CNSs, CNMs; staff under general supervision.

Documentation
Log exact time (e.g., "3/15: 10-min call, 10-min med review").

Payment:
~$60 (2025 estimate).

Common Question
"What if I log 19 minutes?"
You can't bill—20 is the strict minimum.

CPT® 99439: Additional Staff Time

Description
Add-on for each extra 20 minutes beyond 99490.

Requirements
Full 20-minute increments; medically necessary tasks.

Documentation
Specify additional efforts (e.g., "20-min specialist consult").

Payment
~$45 per unit (2025 estimate).

Common Question
"Can I bill for 35 minutes?"
Yes—99490 + one 99439 (up to 40 min total).

CPT® 99491: Non-Complex CCM

Description
30+ minutes by a physician/QHP personally—no staff time counts.

Requirements
Cannot mix with 99490 in the same month.

Documentation
Physician time only (e.g., "30-min care plan update").

Payment
~$80 (2025 estimate).

Common Question
"Can staff help?"
No—99491 is physician/QHP-only.

CPT® 99437: Additional Physician/QHP Time

Description
Add-on for each extra 30 minutes beyond 99491.

Requirements
Full 30-minute increments; physician-driven.

Payment
~$55 per unit (2025 estimate).

Common Question
"Is there a cap?"
No, but justify every minute.

CPT® 99487: Complex CCM

Description
60+ minutes of staff time with moderate/high complexity MDM.

Requirements
Intensive care plan revisions; complex decisions.

Documentation
Detail complexity (e.g., "60-min med adjustment, specialist sync").

Payment
~$130 (2025 estimate).

Common Question
"What's complex enough?"
Significant changes or multi-provider coordination.

CPT® 99489: Additional Complex Time

Description
Add-on for each extra 30 minutes beyond 99487.

Requirements
Sustained complexity; full increments.

Payment
~$70 per unit (2025 estimate).

Common Question
"Can I bill without complexity?"
No—MDM must support it.

HCPCS G0506: Initiating Visit Add-On

Description
One-time fee for extra care planning during an E/M visit (e.g., AWV).

Requirements
Bill with initiating visit; document added effort.

Payment
~$65 (2025 estimate).

Common Question
"Is it monthly?"
No—just once at CCM enrollment.

How CCM Billing Cycles Work

CCM operates on a calendar-month cycle:

Base Codes (99490, 99491, 99487)
Bill once monthly after meeting time thresholds, typically using the last day (e.g., March 31).

Add-Ons (99439, 99437, 99489)
Add as needed for extra time in that month.

G0506
Bill once with the initiating visit.

Common Question
"What if a patient starts mid-month?"
Bill for that month if thresholds are met by month-end (e.g., 20+ min by March 31).

Tips
Track time daily; bill only when requirements are fully met. FairPath helps you track code achievement and fully documents all patient interactions.

Navigating CCM Compliance

CCM faces scrutiny—stay compliant:

Time Accuracy

Log 20+ minutes precisely; no double-counting with TCM/RPM.

Care Plan

Must be comprehensive, updated, and EHR-accessible.

Consent

Document patient agreement and cost-sharing notice—verbal or written.

Fraud Risks

OIG audits flagged $1.8M in overpayments (2015–2016) for insufficient time or missing elements.

Common Question
"What if I forget consent?"
Claims can be recouped—always document. FairPath tools document every interaction.

Compliance Tip
Self-audit monthly with logs like "3/15: 10-min call, med review."

Who Pays for CCM?

Medicare (Part B)

Covers all codes; 20% coinsurance (often offset by Medigap/Medicaid).

Medicare Advantage (MA)

Matches Medicare; many plans offer $0 copays to boost use.

Medicaid

14+ states cover CCM (e.g., Colorado mirrors Medicare); rates vary (~$40 for 99490).

Private Insurers

Aetna, BCBS often pay; Cigna lags. Rates differ.

Common Question
"Will my insurer pay?"
Check plan specifics—Medicare standards often suffice.

Trend
Commercial adoption grows as CCM proves cost savings.

Your RTM Foundation

What Is Remote Therapeutic Monitoring?

Introduced in 2022, Remote Therapeutic Monitoring (RTM) empowers providers to track non-physiologic data—like therapy adherence, pain levels, or respiratory status—using FDA-approved devices or software, often with patient self-reports.Unlike RPM's focus on vital signs, RTM targets therapy progress, broadening its reach to physical therapists (PTs), occupational therapists (OTs), and other clinicians beyond traditional E/M providers.

FairPath's guide dives into RTM's billing codes, compliance rules, and practical applications, equipping you with the knowledge to enhance patient care and reimbursement in 2025.

Understanding RTM CPT® Codes

Medicare's CCM CPT® codes vary by staff involvement, complexity, and time spent. Here's your 2025 breakdown:

CPT® 98975: Initial Setup and Patient Education

Description
Covers one-time setup and training for RTM devices/software.

Requirements
Billable once per episode of care (treatment start to goal completion); tied to 16+ days of data in the first 30-day period (per CMS).

Who Can Bill
Physicians, NPs, PAs, PTs, OTs, SLPs, and other qualified providers within scope.

Documentation
List device/app and confirm patient instruction.

Payment:
~$19 (2025 Medicare estimate).

Common Question
"Can I bill 98975 without 16 days?"
CMS implies it's tied to subsequent monitoring—best to bill after 16 days are confirmed.

CPT® 98976: Device Supply (Respiratory System)

Description
Monthly supply for respiratory monitoring (e.g., inhaler use).

Requirements
16+ days of data (readings/alerts) in 30 days.

Frequency
Once per 30 days; only one practitioner bills.

Documentation
Specify FDA-approved device and 16+ days of use.

Payment
~$50 per unit (2025 estimate).

Common Question
"Does it cover multiple devices?"
No—just one code per period, regardless of devices.

CPT® 98977: Device Supply (Musculoskeletal System)

Description
Monthly supply for musculoskeletal monitoring (e.g., exercise adherence).

Requirements
Same as 98976—16+ days required.

Frequency
Once per 30 days; only one practitioner bills.

Documentation
Note device and data collection.

Payment
~$50 per unit (2025 estimate).

Common Question
"Can I bill for pain logs?"
Yes, if via an FDA-approved tool.

CPT® 98978: Device Supply (Cognitive Behavioral Therapy)

Description
Monthly supply for for CBT monitoring (new in 2024).

Requirements
FDA-approved digital tool; 16+ days of data.

Frequency
Once per 30 days; contractor-priced by Medicare.

Documentation
Specify CBT device/app and usage.

Payment
Varies by MAC (~$40-$60 estimated).

Common Question
"Is it widely covered?"
Check with payers—adoption varies.

CPT® 98980: Treatment Management (First 20 Minutes)

Description
20+ minutes of management, including data review and interactive communication.

Requirements
Real-time contact (phone/video); 16-day rule doesn't apply.

Frequency
Once per calendar month.

Documentation
Log time (e.g., "15-min review, 5-min call on 3/15").

Payment
~$50 (2025 estimate).

Common Question
"What if I miss the call?"
No interactive contact means no billing.

CPT® 98981: Additional Management Time

Description
Add-on for each extra 20 minutes beyond the first 20.

Requirements
Full 20-minute increments; further interaction recommended.

Frequency
Multiple units if justified.

Documentation
Detail additional time and actions.

Payment
~$40 per unit (2025 estimate).

Common Question
"How many units can I bill?"
No cap, but justify with complexity.

General Notes
RTM can't be billed with RPM for the same patient in the same period. Stackable with CCM if time is distinct.

How RTM Billing Cycles Work

RTM operates on distinct cycles:

Device Codes (98976–98978)
Bill once per 30-day period after 16+ days of data, using the period's end date (e.g., Feb 8 for Jan 10–Feb 8).

Management Codes (98980–98981)
Bill once per calendar month after 20+ minutes, typically on the last day (e.g., March 31).

Setup (98975)
Bill once per episode when monitoring begins.

Process
Track device use daily; log management time monthly.

Common Question
"What if a patient starts mid-month?"
Bill device codes after 30 days; management codes align to the month.

Navigating RTM Compliance

RTM demands vigilance:

16-Day Rule

Verify 16+ days of data for device codes.

Time Accuracy

Log 20+ minutes for 98980/98981; no double-counting with CCM/RPM.

Consent

Document patient agreement—best practice, though not mandated.

Vendor Deals

Structure third-party fees at fair market value to avoid kickback issues.

Common Question
"What if I miss 16 days?"
Skip billing—audits can recoup funds.

Who Pays for RTM?

Medicare (Part B)

Covers all codes; 20% coinsurance applies (~$10–$12 per code).

Medicare Advantage (MA)

Matches Medicare; some offer $0 copays.

Medicaid

Varies—states like Virginia cover RTM; others lag (rates ~$20–$30).

Private Insurers

Aetna, BCBS (e.g., MA, MI) pay; Cigna lags; rates ~120% of Medicare.

Common Question
"Will my payer cover 98978?"
Verify—new codes face adoption delays.

Trend
Coverage grows as RTM proves value.

Tools for RTM Excellence

FDA-Defined Devices

Apps or hardware (e.g., Propeller Health, Kaia Health) track therapy data.

Software Eligibility

FDA-cleared apps qualify (e.g., CBT tools for 98978); document status.

Communication

Synchronous calls or video count toward 98980/98981 time.

Common Question
"Can I use a non-FDA app?"
Risky—stick to approved devices for compliance.

FairPath: Run Your Own Remote Care Program with AI

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What is FairPath?

FairPath: Software Stack for Small to Mid-Sized Practices

Compliance First

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Full-Service Billing

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Key Features

Key Features

Device Inventory & Assignment

Patient Onboarding & Consent Capture

Priority Q Clinical Dashboard

Integrated Communication: Calls & SMS

Patient Review & Profile Workflow

Billing, Compliance & Reporting

Integration with Major EMRs

Why RPM Needs Oversight—And How FairPath Helps

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What Are the Benefits and Challenges of Running RPM, CCM, and RTM Programs In-House?

What Are the Key Benefits of In-House RPM, CCM, and RTM Programs?

How Does In-House Management Improve Care Continuity?

What Are the Financial Advantages of Internal Program Management?

How Does In-House Management Enhance Quality Control?

Why Is Data Ownership Important for Healthcare Organizations?

How Does In-House Management Address OIG Oversight Concerns?

What Are the Main Challenges of Running Programs In-House?

What's the Investment Required for Remote Care Programs?

The FairPath Solution

What Technology Infrastructure Challenges Should You Expect?

The FairPath Solution

What Staffing and Training Requirements Are Involved?

The FairPath Solution

How Complex Are Regulatory and Compliance Requirements?

The FairPath Solution

What Scalability Challenges Should You Anticipate?

The FairPath Solution

Unified Data with a Common Ontology

How to Run an RPM, CCM, and RTM Program

Patient Identification and Enrollment Process

How Do You Identify Eligible Patients?

The FairPath Solution

What Is the Patient Enrollment Workflow?

The FairPath Solution

Clinical Workflow Integration

How Do You Structure Daily Clinical Operations?

The FairPath Solution

What Are the Clinical Review Protocols?

The FairPath Solution

Data Management and Technology Operations

How Do You Handle Device Distribution and Management?

The FairPath Solution

What Are the Data Collection and Transmission Requirements?

The FairPath Solution

Staff Training and Operational Support

What Training Do Clinical Staff Need?

The FairPath Solution

How Do You Establish Operational Procedures?

The FairPath Solution

What Is Remote Patient Monitoring?

Understanding RPM CPT® Codes

CPT® 99453: Initial Setup and Patient Education

CPT® 99454: Device Supply and Data Transmission

CPT® 99457: Treatment Management (First 20 Minutes)

CPT® 99458: Additional Management Time

How RPM Billing Cycles Work

What Qualifies for RPM Billing?

Automatic Transmission

Physiologic Data

Examples

Navigating RPM Compliance