APCM & RPM Compliance Checklist for Remote Patient Monitoring

Obtain and document patient consent for both APCM and RPM, explicitly mentioning potential cost-sharing responsibilities.

Ensure the provider's note specifies why a physiological monitoring device is required for the patient's chronic conditions.

Confirm the patient has two or more chronic conditions for APCM and a clinical need for RPM tracking (e.g., hypertension).

Use AI call handling to record and transcribe verbal consent for device shipments, storing logs directly in the EHR.

Document that the patient was trained on how to use their specific device (BP cuff, glucometer, etc.) and understands the data flow.

Maintain a registry of device serial numbers confirming all equipment meets the FDA definition of a medical device.

Verify that the device has transmitted physiological data at least 16 days out of every 30-day billing cycle.

Ensure device data flows directly from the manufacturer cloud to your EHR without manual patient entry to prevent data tampering.

Deploy AI phone automation to contact patients who have not used their devices for 3 consecutive days to ensure compliance.

Document patient-specific thresholds (e.g., Systolic > 160) that trigger immediate clinical review or AI escalation.

Maintain separate logs for RPM (99457/99458) and APCM time; ensure no single minute of clinical work is counted for both.

Verify a full 20 minutes of interactive communication or data review was performed for each code before submitting claims.

Document at least one live sync (phone or video) with the patient specifically discussing their RPM data trends.

Use AI to transcribe monthly check-ins, highlighting clinical decisions made based on device data for audit proof.

Ensure the EHR reflects that RPM services were performed under the general supervision of the billing provider.