RPM Patient Consent and Enrollment: What to Do Before the First Reading

RPM patient consent is the first thing a remote patient monitoring program has to get right, because everything after it depends on it: the device order, the first reading and the first claim. This checklist covers what to confirm before you ask, what to tell the patient, how to record the answer, and what to check before a device leaves the shelf. It is general guidance on federal Medicare rules. Those rules change every year and differ by payer and state, so confirm the details with current CMS guidance, your payer contracts, your MAC and your compliance adviser.

What does Medicare require for RPM consent?

Medicare expects the patient to agree to remote patient monitoring before you bill for it, and expects that agreement to be documented in the record. CMS has said a few things about how that can happen:

• Consent can be obtained at the time the services are furnished. It does not need a separate visit of its own.
• Auxiliary staff, such as a Medical Assistant, can obtain consent under the general supervision of the billing practitioner.
• The patient should be told that the service may carry cost sharing, such as a copay, before they agree.

Medicare also expects the monitoring to be ordered by a practitioner who has an established relationship with the patient. Commercial payers and Medicaid programs set their own rules, and some ask for more, such as a signed form or consent renewed on a schedule. Check each payer you bill before you settle on one process.

Before you ask: is the patient eligible?

Asking a patient who cannot be enrolled wastes their time and yours. Run these checks first.

• The patient has an established relationship with the practitioner who will order and bill the monitoring.
• The ordering practitioner has documented why monitoring is reasonable and necessary for this patient's condition.
• The patient's coverage is active, and you know whether their plan covers RPM.
• Nobody else is billing the device codes for this patient. Only one practitioner can bill the RPM device codes for a patient in a period, so ask whether the patient already has a monitor from another office.
• The patient can use the device. Ask about their phone, the cell signal at home, their eyesight and hands, and whether a family member helps. Our guide to cellular vs Bluetooth RPM devices covers how to match a device to the patient.
• The patient has a mobile number on file if you plan to text them, and their call and text preferences are recorded.

What to tell the patient before they agree

Consent only means something if the patient understood what they agreed to. Cover each of these in plain words, on the phone or in the room.

• What the device measures and how often their provider wants a reading.
• That readings go to the practice automatically, and who on the team looks at them.
• That monitoring is not an emergency service, and what to do in an emergency instead.
• That someone from the practice will call them about their readings, and will talk with them live at least once a month.
• That the service may carry cost sharing, such as a copay, depending on their coverage.
• That only one practice can bill for their monitoring, so they should tell you if another office already monitors them.
• That they can stop at any time, and that the device will need to come back if they do.
• How the device will arrive and who to call for help setting it up.

How to document RPM consent

Write the consent down so that someone who was not there can see what happened months later. A complete record answers each of these.

• Who gave consent: the patient, or a legal representative where your state rules allow it.
• When it was given: the date, and the time if your process records it.
• Who obtained it, their role, and the practitioner whose general supervision they worked under.
• How it was given: a signed form, an electronic signature, a reply by text, or a spoken yes on a call, as your form and your payers allow.
• That cost sharing was explained.
• Which version of your consent form the patient agreed to.
• Where the record lives, so it can be found at audit time.
• A refusal, too. Record when a patient declines, and the reason if they gave one.

Keep the original. When your form changes, keep the old version beside the new one, so you can always show exactly what a patient signed. For what else a patient month needs in the record, see our RPM documentation checklist.

A note on asking for consent by text

Sending a consent request by text is a call to a patient's phone, and it has its own rules: calling hours, opt-outs and the TCPA. A patient who has asked not to get texts, or who is on your Do Not Call list, should not get one. Talk to your counsel about how your texts are worded and sent. Our article on patient text message consent explains the general shape of those rules.

From signed consent to the first reading

Consent opens enrollment. These steps take the patient from a signature to readings arriving.

1. Place the device order only after consent is recorded.
2. Confirm the shipping address with the patient before the order goes out.
3. Make a short pre-ship call: tell the patient a box is coming, what is in it and when to expect it.
4. Follow the parcel, and call the patient when it is delivered.
5. Walk the patient through setup and how to use the device. CPT 99453 describes this initial setup and patient education.
6. Confirm the first reading arrived and came from the device itself, not typed in. Medicare expects physiologic data transmitted automatically from a device that meets the FDA definition of a medical device.
7. Have the provider set the patient's own limits, so readings are rated against them from day one.
8. Assign the patient to the staff member who will review their readings.

The long-standing device codes (99453 and 99454) call for readings on at least 16 days in a 30-day period. For 2026, CMS added shorter-period codes, including 99445 for 2 to 15 days of readings. How each payer treats these codes can differ, so check before you build your enrollment around one of them.

Common consent problems and how to fix them

• The patient never got the text. Check that the number on file is a mobile, not a landline, and that it is typed correctly.
• The link expired. Send a new one, then call if the second one goes unanswered too.
• The patient declined. Record it. Talk to them about their concerns, and ask again only if they want to.
• Your consent form changed. New sends use the new version. A patient who already signed keeps the version they signed.
• The patient has opted out of texts. Get consent another way, on a call or in person, and record how.

Frequently asked questions

Can a Medical Assistant get RPM consent?

CMS has said auxiliary staff, such as a Medical Assistant, can obtain consent under the general supervision of the billing practitioner. The practitioner stays responsible for the service. Your state's scope of practice rules and your payers may add conditions, so check both.

Does RPM consent have to be in writing?

Medicare's general guidance asks for consent to be obtained and documented, rather than naming one format. Some payers and some state rules ask for a signed form. A signed or electronically signed form is the easiest record to produce later.

How often does RPM consent need to be renewed?

Medicare's general guidance does not set a renewal schedule for RPM consent. Ask again when something material changes, such as a patient restarting after a break, and follow any renewal rule a payer sets in its contract.

What if the patient is already monitored by another practice?

Only one practitioner can bill the RPM device codes for a patient in a period. Ask the patient before you enroll them, and if another office already monitors them, sort out which practice will continue before a second device ships.

Sources

• Telehealth & Remote Monitoring (MLN901705), CMS
• CY 2021 Payment Policies Under the Physician Fee Schedule (final rule), Federal Register
• CY 2024 Payment Policies Under the Physician Fee Schedule (final rule), Federal Register
• CY 2026 Payment Policies Under the Physician Fee Schedule (final rule), Federal Register
• 47 CFR 64.1200, Delivery restrictions (TCPA rules), Legal Information Institute at Cornell Law School