10 Common RPM Mistakes to Avoid for Successful Virtual Care

While many “RPM” initiatives continue to be small, they certainly punch above their weight. Simply put, RPM continues to offer immense benefits for patients and healthcare providers alike. Learn what crucial mistakes not to make when selecting a vendor to move your clinic to virtual care.

Among other things, patients can get more access to healthcare, leverage improved quality of care, and have much more support and peace of mind. On the other side, healthcare providers get a much closer look at their patients’ health data, which can lead to reduced readmissions, better patient outcomes, and better outcomes overall.

RPM can be a win-win for both patients and healthcare providers. But having said this, healthcare providers aiming to launch and run an RPM program need to tread lightly. There are many different kinds of pitfalls and mistakes that can occur. Because of this, let’s take a deep dive into ten mistakes that you and your colleagues should avoid in your RPM program.

10. Failing to Have a Face-To-Face Visit

Face-to-face visits are a critical first step for delivering RPM care. As the billing practitioner, you need to have at least one face-to-face meeting with new patients or patients that you haven’t seen within one year before billing CPT code 99457.

CPT code 99457 is a relatively new CPT code that deals with remote physiologic monitoring treatment management services. This visit should be billed separately and can occur during annual wellness visits, level 2–5 office visits, or initial preventive physical exams.

9. Not Documenting Patient Consent

You must obtain documentation showing that your patients have consented to RPM. The Centers for Medicare & Medicaid Services (CMS) doesn’t explicitly say how you should obtain documented consent, but it is critical to have proof that patients are actively opting in. It’s also a good idea to note in the patient’s medical record why RPM is justified. 

8. Failing to Use the Correct CPT Codes

Like other healthcare services, you must use the correct CPT codes when providing RPM. While CPT code 99091 was introduced in 2018, several more were added in 2019 and 2020.

For Medicare beneficiaries, CPT 99453, CPT 99454, CPT 99457, and CPT 99458 are the standard codes for Remote Patient Monitoring services.

7. Not Using Medical Devices as Defined by the FDA

The 2019 Medicare Physician Fee Schedule requires that billing practitioners use FDA-defined “medical devices” to bill for RPM.

While devices do not necessarily need to be FDA-approved, they must meet the FDA’s definition of a medical device. Choosing compliant, clinically reliable devices is essential for both care quality and billing compliance.

6. Failing to Have RPM Services Ordered by Qualified Providers

RPM services must be initially ordered by physicians or other qualified healthcare professionals. While clinical staff can provide services under CPT codes 99457 and 99458 after the initial order, they cannot place the initial order themselves.

5. Failing to Reinforce Daily Reading Protocol

During the initiating visit, reinforce the “daily reading protocol.” Just one routine reading a day significantly improves adherence and provides more actionable data for the patient’s care plan. Avoid recommending only 1–2 readings per week, which often leads to non-adherence.

4. Failing to Track Interactive Time (or Doing It Manually)

CPT codes 99457 and 99458 require a minimum of 20 and 40 minutes respectively of interpreting patient data and adjusting care plans.

To ensure compliance, use an automated platform—like accuRPM—that tracks interactive time accurately and can produce evidence in the event of a Medicare inquiry.

3. Double Billing Interactive Time

When billing under CPT 99457 and 99458, you may also bill for certain CCM, TCM, and behavioral health integration codes—but you cannot count the same interactive time twice. Additionally, you cannot count any time on a day when you bill for an evaluation and management service for the same patient.

2. Failing to Capitalize on “Incident-To” Billing Rules

Under CPT 99457 and 99458, clinical staff can deliver RPM services under the general supervision of the billing practitioner—meaning the practitioner does not need to be in the same location. This flexibility allows you to leverage an auxiliary care model to expand capacity.

1. Not Getting Patient Feedback

RPM is about better patient outcomes. Beyond reviewing data, engage patients directly for feedback on their experience. Understanding what they like and what could improve helps refine your program for better results.

Bottom Line:

Tread carefully—many RPM mistakes are entirely avoidable. With diligence and the right partner, you can maximize the benefits of remote patient monitoring.

Tellihealth’s accuRPM platform is designed to prevent these common pitfalls, ensuring compliance, efficiency, and better outcomes from day one.