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Device Supply Compliance
The “Block Stretching” Trap
Why extending RPM billing cycles to “reach 16 days” can create non-compliant 99454 claims.
Last updated: December 2025
For: Practice owners, billing leaders, compliance teams
Scope: Medicare RPM device supply (CPT 99454)
How to use this page: Operational compliance guide, not legal advice. Confirm payer-specific rules and document medical necessity, device qualifications, and dates of service.
Quick Snapshot
Billing target
99454 (RPM device supply)
Compliance trigger
16 days of data in the billed 30-day period
Risk pattern
Stretching service dates
Reallocating days
Documentation mismatch
Overview
CPT 99454 is the RPM device supply code. For Medicare RPM, CMS ties payment to collecting and transmitting physiologic data on at least 16 distinct days within each 30-day period. That creates a revenue cliff: 15 days means the period is not billable.
The failure pattern many operators call “block stretching” happens when programs keep the billing window open beyond 30 days to collect missing days, then submit 99454 as if those days belonged to the original period. This guide explains why that practice is audit-vulnerable and how to keep operations compliant.
Section Index
- Key takeaway in one sentence
- What 99454 is (and what it is not)
- What “block stretching” looks like in real operations
- Why it is non-compliant (the auditor’s logic)
- What to do instead (operationally compliant alternatives)
- How this relates back to FairPath
- FAQ
- References
1) Key Takeaway in One Sentence
If you extend a 30-day RPM device-supply billing period to “capture” additional reading days and then bill CPT 99454 for that stretched interval, you are misreporting the unit and dates of service—creating a claim that can fail an audit because the qualifying days belong to a different period.[1]
2) What 99454 Is (and What It Is Not)
What it is: a device supply billing unit tied to RPM data collection/transmission over a defined period. CMS describes RPM eligibility as collecting and transmitting physiologic data at least 16 days every 30 days.[2]
What it is not: it is not “a code for 16 readings.” The threshold is a condition of payment, but the unit of billing is the defined period. Billing 99454 requires documentation that the qualifying days occurred inside the billed 30-day service period, not across a custom window.
3) What “Block Stretching” Looks Like
Common operational sequence:
- Day 1: device supply period begins (setup is already completed or previously billed).
- Day 30: the patient has only transmitted on 12 distinct days.
- Instead of closing the period as non-billable, the program keeps the “cycle” open.
- Days 31–44: the patient transmits on 4 more days.
- The program bills 99454 as if those 16 days were inside the original 30-day unit.
This is often justified as “we are not double-billing and the device was supplied,” but the claim still represents a unit of service that does not match the evidence for that unit.
4) Why Block Stretching Is Non-Compliant
You are changing the billed unit
CMS frames RPM device-supply eligibility around a 30-day period with a 16-day threshold inside that period. Extending the window means the billed unit no longer matches the described unit.[1]
You are reallocating days between periods
If days 31–44 are used to qualify the claim for the prior period, those days are not available to support the next period. The evidence is assigned to the wrong service interval.
It cascades into audit flags
Stretching period A pushes every subsequent period off cadence, creating overlaps, gaps, and “custom” 30-day definitions. That pattern is detectable in claims history and hard to defend.
The risk is representation, not device cost
Even if connectivity costs are real, claims compliance hinges on matching the billed unit to the furnished unit. Qualification evidence outside the unit makes the claim vulnerable.
5) What to Do Instead
Option 1: Accept the period as non-billable if it misses the threshold
Operationally painful but compliance-clean: if the patient does not meet the required days within the 30-day period, do not bill 99454 for that unit. CMS’ 16-days-in-30 framing implies exactly that.[2]
Option 2: Fix adherence upstream, not dates downstream
- Set expectations during onboarding for the required days of readings.
- Run reminder workflows with auditable consent and timing.
- Escalate device troubleshooting quickly.
- Use dashboards that warn early when a patient is pacing below threshold (e.g., day 10 with only 2 reads).
Option 3: Use policy-aligned shorter-duration codes when applicable
For 2026, multiple rule summaries describe a new RPM device supply code for 2–15 days in a 30-day period (often referenced as CPT 99445). Verify applicability and payer adoption in the CY 2026 Medicare PFS final rule and your contracts before using it.[3]
How This Relates Back to FairPath
FairPath’s RPM billing logic tracks the billing unit explicitly, counts unique days inside the correct 30-day window, and surfaces the compliance outcome early:
- Billable: threshold met inside the window.
- Not billable: threshold missed inside the window.
- At-risk: pacing alerts highlight patients who are falling behind soon enough to intervene.
The goal is clarity, not “optimizing claims.” If a period misses 99454, the system makes that visible so teams can focus on adherence and patient behavior—not date manipulation.
FAQ
You should document those facts clinically, but they do not convert a below-threshold device-supply period into a compliant 99454 claim. The question is whether the required data days occurred inside the billed period.[2]
CMS frames RPM eligibility as every 30 days, not “calendar months.” Use a consistent 30-day interval and make sure the qualifying days fall inside that interval.[2]
The threshold is about distinct days with qualifying data, not total readings. Fifteen days leaves the period short.[2]
CMS-aligned guidance ties the day threshold to the device supply side. 99457/99458 are time-based management codes, so the 16-day requirement is not their payment condition.[4]
Yes. That is part of the RPM business model. The compliant response is to improve adherence and program selection—not to change the claimed unit of service.[2]
No. Many commercial payers mirror Medicare logic, but policies vary. Treat Medicare rules as the baseline and validate payer-specific policies before adjusting workflows.
References
- CMS, CY 2021 Physician Fee Schedule final rule fact sheet (clarifies 16 days of data each 30 days for 99453/99454). Centers for Medicare & Medicaid Services.
- CMS, Remote Patient Monitoring overview page (eligibility framing includes collecting/transmitting data at least 16 days every 30 days). Centers for Medicare & Medicaid Services.
- CMS CY 2026 PFS final rule fact sheet (high-level). Centers for Medicare & Medicaid Services.
- HHS Telehealth resource: Billing for remote patient monitoring (summarizes 16 days out of 30 for RPM). telehealth.hhs.gov.
- CMS MLN booklet: Telehealth & Remote Patient Monitoring. Centers for Medicare & Medicaid Services.
- American College of Physicians RPM billing/coding guidance. American College of Physicians.
- Example payer policy incorporating 99445/99454 day splits effective 2026. UHC Provider.
- Summary analysis discussing 2026 RPM updates. Nixon Law Group.
