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Are remote patient monitoring rules changed for cardiac monitoring in 2024 or 2025?
Executive Summary
Medicare clarified remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) rules in the 2024 Physician Fee Schedule final rule that took effect January 1, 2024, but those clarifications were broad and not cardio‑specific. No new, final Medicare rule specifically changing cardiac monitoring policy was implemented in 2024 or 2025; instead federal oversight actions and a CMS proposal for 2026 billing changes emerged in 2024–2025 and remain the primary developments to watch [1] [2] [3] [4] [5].
1. Why 2024 looked like a rules year — and what actually changed
Medicare’s 2024 Physician Fee Schedule final rule clarified RPM and RTM definitions, billing scenarios, and the established‑patient requirement for remote physiologic monitoring while excluding that same requirement for RTM, and it confirmed data‑collection and concurrent‑billing guidance that applies across physiologic modalities, including cardiac monitoring by default. These clarifications were effective January 1, 2024, and they provided operational certainty for providers billing RPM/RTM services, but they did not institute cardiac‑specific carve‑outs or new cardiac devicespecific rules; the changes were framed as programwide policy clarifications rather than discipline‑specific mandates [1] [2].
2. What the federal audit found — oversight, not rulemaking
The Office of Inspector General’s September 19, 2024 report found substantial program integrity and compliance gaps in Medicare RPM use, noting about 43% of enrollees missed at least one required RPM component, raising questions about appropriate use and billing. The OIG recommended stronger safeguards, provider education, and potential ordering requirements; CMS closed some recommendations like education by June 23, 2025, while others — including adding ordering requirements and technical safeguards — remained open with updates anticipated in 2026. The OIG action reflects enforcement and oversight pressure rather than a new statutory rule changing how cardiac monitoring is defined or reimbursed [3].
3. 2025 developments: proposals for 2026, not retroactive changes
In mid‑2025 CMS proposed substantive RPM billing code changes for implementation on January 1, 2026, including new CPT codes for shorter monitoring intervals and refinements to work RVUs, aimed at simplifying billing and expanding flexibility. Those proposals were published in the 2026 Physician Fee Schedule proposed rule and remain proposals until finalized; they do not retroactively alter 2024–2025 policy. Stakeholders flagged that the 2026 proposals could materially affect cardiac monitoring reimbursement mechanics, but the proposals themselves are dated to take effect in 2026 and therefore do not constitute changes to 2024 or 2025 rules [4] [5].
4. How guidance applies to cardiac monitoring in practice today
Because RPM policy changes in 2024 were broad, cardiac remote monitoring continues to operate under the general RPM/RTM framework: clinicians must meet the data‑collection and billing criteria, document the nature of physiologic monitoring, and adhere to established‑patient rules when RPM codes are used. Private payers may vary, and the OIG’s findings prompted CMS to emphasize provider education and better documentation; however, there is no federal Medicare rule enacted in 2024 or 2025 that uniquely alters clinical or billing requirements exclusively for cardiac devices or telemetry beyond the general RPM clarifications [2] [1] [4].
5. Where stakeholders disagree and what to watch for next
Provider groups and RPM vendors favor the 2026 proposals that add flexibility and shorter‑duration codes, arguing these changes will broaden access and simplify billing; auditors and some CMS reviewers emphasize stricter safeguards to curb inappropriate billing, including potential ordering requirements and monitoring of component completion. These are conflicting agendas: expansion versus tightening. The agenda items under active consideration include finalized 2026 code changes, OIG‑recommended safeguards, and payer‑specific coverage policies — each capable of shifting incentives for cardiac RPM use [5] [3].
6. Bottom line for clinicians and program managers
For operations in 2024–2025, apply the 2024 Physician Fee Schedule clarifications, follow OIG‑prompted compliance guidance and educational materials CMS closed in 2025, and prepare for possible 2026 coding and oversight changes that could affect cardiac RPM billing. There was no distinct Medicare rule adopted in 2024 or 2025 that specifically changed cardiac monitoring policy; instead, expect evolving enforcement, provider education, and proposed 2026 billing reforms to shape practice in the near term [1] [3] [4].