RPM Manual
The practical 2026 guide to device rules, day thresholds, management time, and audit defensibility for Remote Patient Monitoring.
Read the RPM Guide →How to Review RPM Data, Track CPT 99457, and Eliminate "Ghost Minutes"
The Bottom Line
- Automated Time Tracking: FairPath automatically tracks time for CPT 99457/99458 as you review data; no manual stopwatches are required.
- Bulk Reviews: You can select multiple trending data points and apply a single clinical note, consolidating time into one efficient block.
- Integrated Dialer: The system logs outgoing calls, creates transcripts, and performs sentiment analysis automatically for audit defense.
- No Ghost Minutes: Every billable minute is tied to a specific clinical action or communication, preventing audit failures.
Understanding the "Interactive Communication" Requirement
One of the most common audit pitfalls in Remote Patient Monitoring (RPM) is the failure to distinguish between data review and interactive communication. As demonstrated in the video, CPT Code 99457 requires 20 minutes of time, but CMS guidelines specify that this time must include interactive communication with the patient or caregiver.
| Traditional Workflow (High Risk) | FairPath Workflow (Audit Safe) |
|---|---|
| Staff logs time manually in a spreadsheet ("15 mins reviewing"). | System tracks time deterministically based on active window focus. |
| Phone calls are made from personal cells; no record exists. | Integrated dialer records, transcribes, and timestamps the call. |
| "Ghost Minutes" appear where billed time > actual work performed. | Every minute is tied to a specific data point or call log. |
The "Ghost Minute" Risk
"Ghost Minutes" occur when a practice bills for time that cannot be substantiated by an audit trail. In the video (timestamp 1:38), you see FairPath's timer running automatically. Crucially, if the user navigates away or stops interacting, the timer stops. This ensures that when the OIG asks, "Did you really spend 2 minutes on this blood pressure reading?" you have the metadata to prove it.
"We expect that the billing practitioner's time... includes time engaged in interactive communication... which contributes to the total time."
– CMS Final Rule ContextVideo Transcript
0:00 Hi, I'm Justin Brochetti again from Fairpath. In video one, we built a combined hypertension and diabetes care plan. In video two, we asked nurse Amy what we should do based on that care plan and the RPM data coming in. So, now I want to show you exactly what we need to do to actually review those readings, track the RPM minutes and talk to the patient without chasing a stopwatch.
0:24 All right, so I'm back on the RPM page for this patient. And if you notice, we have our care plan. We've also got a clinical summary that nurse Amy and our AI perfect agent has actually generated for us. And you'll notice that we've already started tracking several readings coming in. This is 17 readings over 10 days. Minutes associated with patient care and communication are automatically tracked.
0:47 So, not only are these readings coming in automatically tracked and identified and curated for 30-day billing cycles, but the 99457 and 99458 data is also automatically tracked via these billable event bars. Obviously, once they're full, they're ready to be billed. And what this does is it automatically lets me know where I'm at with this patient before I even start the process of reviewing the readings coming in.
1:16 So now back to the reviewable RPM event for this patient. Their blood pressure has been trending upward and nurse Amy has recommended that we reach out and reconcile some of the loose ends that are associated with this patient and things we need to communicate. We can come to the reviewable RPM event section. The timer is automatically running at 2 minutes and 53 seconds. So I'll say patients blood pressure is trending upwards. Will continue to monitor future readings and I'll save review.
1:47 Now, when I save that review, if you notice, it automatically applies that 3 minutes to the 99457 billable event. Now, we can also review multiple at once. If a bunch of data points come in for this patient, I can review a bunch of these trending data points all at once. So then I can set and put custom "will be calling the patient today" and then I can save time.
2:20 This means when I have similar readings and similar events, I don't don't need to open them one by one. I can select three or more at a time, apply a single review note, and Fairpath will add 2 minutes I spent on that block to the month's total. And if I scroll back up, you can see that two more minutes has been added to the 99457 billable event.
2:43 Now that I've reviewed a few of these readings, I need to reach out and communicate with the patient about some of the things that nurse Amy had mentioned that I contact the patient about. Plus, we know that their blood pressure is trending upwards. So, I'm going to scroll back up and you'll notice that there is a call feature right next to the primary phone number.
3:03 Okay, this call feature unlocks a live connection window which allows me to call out directly to that patient. I can change the caller ID, which is where the phone number is being dialed from. I can also change where the number I'm calling from is located. So, I can add my mobile device number to this dialer and call from my mobile phone instead. And if you notice, it starts the tracking, it starts tracking time immediately.
3:42 I'm on the phone with myself and I'm going to say, "Hi, my name is Justin Brochetti. I'm calling on behalf of the doctor's office and I wanted to contact you because we've noticed that that the latest blood pressure readings have been trending upwards. How are you feeling? How's your diet going? What's your allergies looking like for your medication? Can you confirm that you do have a penicillin allergy? And once I'm done, I simply hang up.
4:11 And you'll notice that at the bottom in the notes section, you have a live call summary outgoing type clinical two-way communication. Yes. And you have an auditable compliance timestamped tracking log of that conversation that has live transcription and sentiment analysis. You'll also note that in the notes section, the care plan appears as well. This is for easy retrieval as well as the text messages that we sent previously.
4:40 So, in summary, we've done a bunch of things for this patient, all easily from Fair Path. Fair Path handles everything from you from beginning to end. We've built a care plan that matches their dual chronic conditions. We've used nurse Amy to do all of the work and decide what's the best course of action for this patient. And we've reviewed the patients readings in real time and documented an outbound call all in one place with very little work.
5:10 That's how you keep RPM APCM clean without ghost minutes, extra spreadsheets, or a third-party vendor sitting between you and your patients. So if you're trying to build remote care in house and stay audit safe, this is the workflow we built Fair Path around.
Worried your current claims have "Ghost Minutes"?
If you are using spreadsheets or estimating time for CPT 99457, you are at risk of an audit clawback. See how FairPath makes compliance automatic.
