Thomas Ferrante Shares Insight on Compliance Considerations for Remote Patient Monitoring

Foley & Lardner LLP partner Thomas Ferrante shared insight on compliance considerations for remote patient monitoring (RPM) in the Report on Medicare Compliance article, “RPM Changes Are on the Table; Hospital Settles CMP Case Over RPM Amid Greater Scrutiny.”

“The first thing RPM companies and providers realize can kick them in the teeth is how hard it can be to get patients to do 16 days of readings,” Ferrante explained. “This is one of the biggest friction points in the RPM world in terms of billing,” with providers sometimes recording 14 days of data but having “nothing to show for it” when it comes to reimbursement.

Ferrante highlighted the federal government’s elevated scrutiny on RPM, particularly concerning a treatment’s medical necessity and unscrupulous billing practices. He also pointed to a provider’s relationship with vendors used for RPM as another potential compliance vulnerability. “Providers may do the billing but outsource the majority of the RPM service line to the vendor,” Ferrante continued, noting that overreliance on a vendor could lead to complications.

“At the end of the day, the responsibility falls on the billing provider,” he added. “They will be on the hook for billing improprieties.”