Five CPT codes turned remote patient monitoring into a $256M line of Medicare fee-for-service spend — a 210× run in six years. This week CMS proposed keeping the codes and banning the third-party vendors who built the curve. Watch the hockey stick draw itself, then see where the 2027 ban lands.
This is Medicare's actual paid spend on the five RPM codes (99453 setup, 99454 device supply, 99457/99458 management minutes, 99091 data review), traditional fee-for-service only. The red area is RPM. The green line is remote therapeutic monitoring (RTM) — a newer, therapist-billable code family that CMS's rule leaves alone: the escape valve, climbing fast off a tiny base. Press play.
RPM paid (99453/99454/99457/99458/99091)RTM paid (the escape valve)
year 2018
RPM this year: $1.2M
$256M
RPM paid, 2024 (FFS)
210×
growth since 2018
$19M
RTM paid, 2024 (~9× since 2022)
The story in the shape. The 2019–2021 wall is the codes taking effect and the pandemic pulling monitoring into the mainstream — RPM paid spend jumped roughly 8× in 2020 alone. By 2024 it's $256M across 476,000 patients, almost all of it flowing through the exact "vendor delivers it on the practice's behalf" arrangement CMS is now targeting. The green RTM line is what a hedged builder watches: small today, but designed to survive the rule.
The critical lens.(1) This is a floor, not the whole flow. These are traditional-Medicare paid dollars from the physician-claims file; industry estimates near $500M in 2024 add allowed amounts, patient cost-sharing, and Medicare Advantage — none of which are in this line. (2) A ban isn't a finalization. This is a proposed rule; comments close in September and the 2027 effective date could slip or soften. Don't draw the 2025–2027 segment as if it already happened — the chart marks it as projection for a reason. (3) "Fraud" is CMS's framing. The same curve reads as either abuse of a low-value service or as real access for 476,000 monitored patients — the data shows the dollars, not the intent.
Why a builder should care
When the curve gets this steep, the regulator eventually redraws it.
A 210× line is exactly the kind of spending shape that invites a rule. CMS isn't deleting the codes — it's changing who gets paid to deliver the service, from a vendor renting a subscription to a provider rendering care. The escape valve (RTM) and a per-provider SaaS license are the two shapes that survive.
Before you raise your next round on RPM monthly-recurring-revenue, draw your own version of this line — and then draw the one after the ban. The steepest curve in your deck is the one most likely to have a regulator standing at the top of it. Build the workflow a clinician renders, not the subscription a vendor rents.
⚠︎ AI-generated · not reviewed by a human · verify against the linked sources before relying on it. Provenance: CMS Medicare Physician & Other Practitioners — by Geography and Service, national rows, CY2018–2024 vintages (mimi_ws_1.datacmsgov.mupphy_geo) via MIMI Labs. RPM = HCPCS 99453/99454/99457/99458/99091; RTM = 98975/98976/98977/98980/98981 (first payable 2022). Dollars = Medicare payment after deductible/coinsurance, traditional FFS only — not Medicare Advantage, not commercial, not facility. The 2025–2027 segment is a projection/marker for the proposed CY2027 rule, not observed data. "476,000 patients" = distinct beneficiaries on code 99457 in 2024.