MEDICARE RPM Audit Preparation Guide

Most RPM vendors can’t hand you an audit packet. We can.

Medicare RPM is one of the more scrutinized billing categories in healthcare, and that scrutiny is increasing as RPM volume grows. The practices that hold up under review can show provider-directed care supported by a qualified connected device, sufficient transmitted data, and documented treatment management. That care also has to be tied to a diagnosed MSK condition, not “wellness.”

Prescribe FIT was built to produce this documentation by design. The MSK medical-necessity narrative is captured at order creation on the PACE order screen. Each patient billing report includes day counts, trend summaries, and data provenance, and the provider electronically signs and dates it during the Monthly Patient Review.

Practices that hold up under review have:

• A medical-necessity narrative tied to MSK disease, aligned with AAOS and ACR guidelines on weight loss for knee and hip OA
• Provider-directed care plans with patient-specific goals, not templated language
• FDA-defined connected devices with automatic data upload, not patient self-reported data
• Documented patient consent and an established patient relationship
• At least one real-time interactive communication in each month that treatment-management time is billed
• Per-patient audit packets with day-count reports, monthly management notes, time logs, and code-selection logic

What’s inside the guide:

• Documentation requirements mapped to each CPT code, including new 99445 and 99470
• A 2025 vs. 2026 rule comparison for audits spanning both years’ dates of service
• A medical-necessity talk track for orthopedic providers
• A talk track for practice administrators
• Program-level and per-patient audit-packet checklists
• Common red flags and practical mitigations

If you don’t have something like this from your current RPM vendor, ask why.