CMS just proposed banning third-party vendors from delivering Medicare remote patient monitoring — keeping the codes, killing the business model built on them. So what does that business model actually look like in the billing data? Two fingerprints: how concentrated the billing is, and how intensely each patient gets billed.
Remote patient monitoring (RPM) is a handful of CPT codes — set up a device (99453), supply it and pull data every 30 days (99454), bill the clinician's management minutes (99457/99458). In traditional Medicare fee-for-service, the physician-claims spend on those five codes went from about $1.2M in 2018 to $256M in 2024 — a 210× run. CMS now wants to keep paying for the clinical service while cutting off the vendors who deliver it "on behalf of" a doctor.
Horizontal: RPM patients per billing provider — high means a few NPIs are running a lot of patients (the "delivered on your behalf" pattern). Vertical: device-months billed per patient — high means each patient is billed close to every month, the recurring-revenue signal. Dot size is total RPM dollars. The shaded corner is the vendor fingerprint: concentrated and intensely billed. Then drag the sample-size floor and watch which "outliers" were just tiny states.
The proposed rule keeps codes 99453/99454/99457 and stops paying when a third-party vendor delivers the monitoring. The signal underneath: Medicare wants to pay for digital health as a clinical service a provider renders, not a product a vendor rents to a practice. Remote therapeutic monitoring (RTM) is the escape valve — for now — and its spend is climbing fast off a tiny base.
mimi_ws_1.datacmsgov.mupphy_geo, mimi_src_file_date=2024-12-31) via MIMI Labs. RPM = HCPCS 99453/99454/99457/99458/99091; "patients" and "providers" anchored on device-supply code 99454; "$ paid" is Medicare's payment after deductible/coinsurance. This is traditional Medicare FFS only — not Medicare Advantage, not commercial, not facility claims — so it is a floor: industry estimates that put total RPM payments near $500M in 2024 include allowed amounts, cost-sharing, and other payers. Concentration is a proxy for the vendor model, not proof: vendor-delivered claims bill under the clinician's NPI and are invisible here.