2026 OIG Audit Survival Guide
23 must-have items that saved our clients millions.
Download free →Exploring RPM, APCM, RTM, or CCM?
Design a Remote Care Program That Actually Works in 2026.
RPM, APCM, RTM, and CCM don’t require an army of staff or a “full‑service” vendor. FairPath is the compliance‑first operating system that lets your practice run these programs on a single spine— so RPM becomes one tool in your stack, not your only strategy.
Who this is for
Practices designing modern remote care.
FairPath is for practices and MSOs that are:
- Studying RPM, APCM, RTM, and CCM options and want to implement them correctly.
- Already using an RPM vendor and questioning whether it is safe, sustainable, or profitable.
- Looking to make remote care a stable, clinically grounded revenue layer—not a speculative bolt‑on.
If you want remote care to behave like part of your core practice—not a side hustle—you’re in the right place.
Program Design
What a Healthy RPM Program Looks Like in 2026
Before you think about vendors, software, or staffing, it helps to define what “good” looks like. In 2026, healthy RPM programs are targeted, layered on top of broader management models like APCM and CCM, and measured by outcomes and workload—not just codes.
Structured Patient Selection
RPM is not simply “for everyone with hypertension.” Robust programs start with a structured qualification process:
- Clinical need: diagnoses, risk, and potential benefit from monitoring.
- Payer behavior: who actually reimburses based on your own history.
- Fit with APCM/CCM: who belongs in comprehensive management instead.
FairPath’s 1–5 Eligibility Score is one example: it consolidates diagnosis, utilization, and payment patterns into a simple, panel‑wide view of who truly fits RPM, APCM, CCM, or some combination.
RPM as a Layer, Not the Foundation
The most stable clinics treat RPM as a layer on top of a broader remote‑care spine:
- APCM (and/or CCM) as the structural base: predictable, panel‑based primary‑care management.
- RPM/RTM layered on top for patients who genuinely benefit from continuous monitoring or therapeutic tracking.
RPM‑only strategies are fragile. RPM on top of APCM/CCM is resilient and better aligned with where payers and regulators are going.
Outcomes & Workload, Not Just Codes
Healthy programs optimize for:
- Keeping high‑risk vitals in range.
- Improving adherence and self‑management.
- Supporting behavior change at scale.
And they do this while minimizing manual tracking and multiple portals, keeping staff focused on clinically meaningful work instead of “threshold management.”
FairPath was built to embody these principles: structured eligibility scoring, an APCM‑first design with RPM/RTM/CCM layered on top, and queues that direct your team to the few tasks that matter rather than chasing raw code volume.
Operations & Scale
Manage 100 or 10,000 Patients with the Same Team
The most common objection to bringing RPM, APCM, RTM, or CCM in‑house is bandwidth. FairPath’s queue‑based architecture lets you work as little or as much as you want: whether you have 30 minutes a day or a dedicated team, the system prioritizes work so you 1) never waste time, 2) eliminate repetitive manual steps, and 3) keep the focus on patient health first.
[Screenshot: Eligibility Score Dashboard & ERA Map]
3.1 Eligibility & Panel Design:
Stop Guessing, Start Targeting
Most practices struggle with remote care because they improvise who to enroll. FairPath replaces guesswork with structured, scalable decision‑making.
- The 1–5 Eligibility Score: FairPath scans your panel and assigns a simple viability score based on chronic conditions, insurance, utilization, and clinical history—showing exactly who fits APCM, RPM, or CCM without manual chart review.
- ERA & Payment Intelligence: By ingesting your own 835/ERA files, the system learns from your actual claims history to predict which payers and codes will reimburse—and which will deny—before you enroll a single patient.
- Condition‑Level Mapping: One dashboard maps diagnoses to programs (e.g., HTN + CKD → APCM + RPM) with logic tunable to your clinical policies.
The Operational Shift: You never waste time chasing ineligible patients. Every enrollment minute is directed at a clinically appropriate, reimbursable candidate.
[Screenshot: PriorityQ & Nurse Amy Log]
3.2 Daily Engagement:
Work Only Where It Matters
The fear about in‑house operations is endless phone calls. FairPath is designed so you decide how hands‑on you want to be—and the software absorbs the rest.
- Nurse Amy (Automated Engagement): Handles routine friction—sending nudges to keep patients on track for RPM requirements (e.g., 16 days), troubleshooting connectivity, and delivering structured symptom surveys via text or voice.
- PriorityQ (Queue‑Based Work): Instead of reviewing every reading, your team works from a single queue of exceptions: critical vitals, worsening trends, and “no data” patterns. The same interface works for 50 or 5,000 patients; only the queue length changes.
- Browser‑Based Onboarding: Staff call patients from the browser using guided scripts, capture verbal consent, and assign device serial numbers in one flow—no spreadsheets required.
The Operational Shift: You choose how little or how much to personally touch; FairPath ensures that whatever reaches your staff is worth their time, defined by exceptions rather than panel size.
[Screenshot: BillingQ Pre-Flight Check]
3.3 Compliance & Billing:
BillingQ Makes Work → Valid Codes
Compliance is treated as a systems problem, not a training problem. We encode the rules so you don't have to memorize them.
- Cross‑Program Rules Engine: The system understands that RPM, RTM, CCM, and APCM interact. It detects overlapping codes, bundles APCM services correctly, and enforces RPM’s structural rules (like 16 days of data) before a period is marked billable.
- Embedded Regulatory Mapping: OIG red flags and MAC guidance are encoded directly into BillingQ. If a patient hasn’t met thresholds or components, the claim never appears in the “ready to bill” list.
- Automatic Time Tracking: Every interaction—calls, reviews, messages—is timestamped and categorized automatically, aggregating time toward the correct codes without manual tallies.
The Operational Shift: No wasted motion. Every action is tracked for reimbursement, and the system warns you if an activity won’t support a compliant claim—protecting both revenue and your license.
Why Run RPM at All? Because the Clinical Data Is Real.
When RPM is managed correctly—as part of a thoughtful remote‑care stack—the clinical lift is significant. In a controlled study of 192 chronic‑care patients, structured monitoring delivered:
-
17% Drop in High‑Risk Vitals
Out‑of‑bounds readings dropped from 59% to 42% in just 90 days.
-
Higher Adherence
Daily reading frequency increased by 22% as patients engaged with the feedback loop.
The FairPath angle: Those results don’t require a call‑center vendor taking 60% of the revenue.
FairPath’s automation lets your existing staff reach similar outcomes as part of an APCM‑first, in‑house program
for a flat software fee, under your license and with your audit trail.
Patient Health Stabilization
59%
Month 1
42%
Month 2
42%
Month 3
Reduction in Out‑of‑Bounds Readings
Due Diligence Briefing
Understanding Third-Party RPM Vendors: Key Considerations
Remote care programs can be run internally by the practice using its own staff and software, or outsourced to a third-party vendor that bundles devices, staff, and workflows. Vendors initially appeared to solve practical problems—logistics, outreach, and coding—but a set of recurring patterns has emerged. The points below summarize those patterns at a model level. They don’t accuse any specific company, but they do outline risks and trade-offs that compliance officers and regulators increasingly highlight.
1. Revenue and Cost Structure
[Diagram: 100% Width x 200px Height]
A “waterfall” chart showing a $100 reimbursement being eroded.
Bar 1: Total Reimbursement ($100).
Bar 2: Vendor Rev Share (−$50).
Bar 3: Device Fees/Shipping (−$15).
Bar 4: Admin Fees (−$10).
Final Bar: Practice Net Margin ($25).
A “waterfall” chart showing a $100 reimbursement being eroded.
Bar 1: Total Reimbursement ($100).
Bar 2: Vendor Rev Share (−$50).
Bar 3: Device Fees/Shipping (−$15).
Bar 4: Admin Fees (−$10).
Final Bar: Practice Net Margin ($25).
Many RPM vendors take a percentage of reimbursement and layer per-patient “monitoring” or “clinical” fees on top. When you add device charges, shipping, and administrative fees, it is common to see vendors consuming 50–70% of total program revenue.
- Fees may still be owed even when patients fail to meet 16-day or minute thresholds.
- Vendor charges may persist when claims are denied, downcoded, or clawed back.
- Device costs often remain on the practice if hardware is lost, damaged, or unreturned.
“I don’t care if the doctor makes money.”
— CEO of a leading remote care company, describing their RPM business model
Key question: What is your realistic net RPM margin after all vendor-related costs across different real-world scenarios?
2. Incentives and Utilization
[Diagram: 100% Width x 150px Height]
A circular “Incentive Loop” diagram.
Step 1: Vendor Paid on Volume → Step 2: Aggressive Enrollment → Step 3: “Stretched” Time/Reading Rules → Step 4: Increased Compliance Risk.
A circular “Incentive Loop” diagram.
Step 1: Vendor Paid on Volume → Step 2: Aggressive Enrollment → Step 3: “Stretched” Time/Reading Rules → Step 4: Increased Compliance Risk.
When vendor income scales with enrolled patients and billed codes, the economic incentive tilts toward volume:
- Broad enrollment of anyone who “qualifies on paper,” even with marginal clinical indication.
- Maintaining billing even as engagement and readings decline, to preserve revenue.
- A tendency to “stretch” time and component interpretations to reach thresholds.
These dynamics intersect with specific regulatory frameworks:
AKS (Anti-Kickback Statute)
Concerns about volume-based payments tied to federal program business.
Stark Law & FCA
Stark: Financial relationships tied to referrals.
FCA Risk: If billing systems systematically overstate time, components, or necessity.
A contract can be technically defensible on paper and still push behavior toward the edge of what regulators will tolerate. The practice’s NPI and TIN are ultimately on the claim.
3. Oversight and Policy Responses
[Graphic: 100% Width x 150px Height]
Split-view graphic.
Left: “OIG Findings” with warning icon (e.g., “43% incomplete”).
Right: “Payer Reaction” with lock icon (e.g., “UHC 2026—Narrowed Criteria”).
Split-view graphic.
Left: “OIG Findings” with warning icon (e.g., “43% incomplete”).
Right: “Payer Reaction” with lock icon (e.g., “UHC 2026—Narrowed Criteria”).
Oversight bodies have begun to respond directly to vendor-driven RPM usage patterns. In its RPM review, the Office of Inspector General reported that:
- A substantial portion of RPM enrollees did not receive all required components of service.
- Some claims were submitted despite minimal or no device activity.
- Certain management-time patterns did not match plausible clinical work.
Payer policies—such as UnitedHealthcare’s 2026 RPM changes—are also narrowing coverage criteria, often in direct response to high-volume, low-documentation patterns associated with vendor-centric models.
Implication: High-volume, vendor-heavy RPM programs now operate under increased scrutiny and need particularly strong documentation and oversight.
4. Patient Selection, Equity, and Experience
[Diagram: 100% Width x 150px Height]
“The Cherry-Picking Filter”
Top of funnel: “All Patients.”
Filter: “Vendor Selection Logic.”
Output: Only “Clean Claims / No Copay” patients enrolled; high-risk/complex patients excluded.
“The Cherry-Picking Filter”
Top of funnel: “All Patients.”
Filter: “Vendor Selection Logic.”
Output: Only “Clean Claims / No Copay” patients enrolled; high-risk/complex patients excluded.
Vendors often prioritize patients with “clean” coverage and minimal copay friction. That can lead to:
- Exclusion of clinically complex or economically vulnerable patients who could benefit most.
- A misalignment between who receives RPM and who has the highest risk profile.
Because outreach, calls, and bills appear to come from the practice, any of the following are experienced as coming from your brand, not the vendor’s:
- Scripted, impersonal interactions.
- Aggressive reminders aimed primarily at hitting thresholds.
- Coinsurance or small-balance surprises.
5. Data Control, Audit Trails, and Exit
[Icon Graphic: 100% Width x 150px Height]
“The Black Box”
A locked server icon representing the vendor portal. Arrows show data flowing in, with “Stop” icons blocking export of raw audit logs.
“The Black Box”
A locked server icon representing the vendor portal. Arrows show data flowing in, with “Stop” icons blocking export of raw audit logs.
In many vendor models, the most complete record of RPM activity—readings, calls, documentation—lives inside the vendor’s portal.
- Full, structured exports of patient-level history and audit logs may be difficult or costly to obtain.
- Contracts may include auto-renewals, minimums, and exit penalties that complicate transitions.
For regulatory and governance purposes, an organization should be able to reconstruct independently:
- Who was enrolled and when.
- What was done, by whom, and at what time.
- How device usage and clinical contacts supported the codes billed.
Relying on a third party as the sole source of truth introduces inherent risk, especially in an audit scenario.
6. Strategic Fit as Remote Care Evolves
[Diagram: 100% Width x 150px Height]
“The Modern Stack”
Base Layer (Large): APCM & CCM (stable, service-based).
Top Layer (Smaller): RPM (device-based).
Contrasted with a vendor-only model that relies almost entirely on RPM volume.
“The Modern Stack”
Base Layer (Large): APCM & CCM (stable, service-based).
Top Layer (Smaller): RPM (device-based).
Contrasted with a vendor-only model that relies almost entirely on RPM volume.
RPM is increasingly just one component of a broader remote-care stack that includes APCM, CCM, and RTM. APCM in particular:
- Does not rely on device thresholds or minute counting in the same way.
- Rewards integrated, ongoing primary-care management.
- Is structurally harder for third-party RPM vendors to attach themselves to without appearing as high-fee middlemen.
A vendor model optimized around RPM volume and hardware margin often aligns poorly with an APCM-first strategy where RPM is used more selectively as a clinical tool.
Summary Checklist: Questions to Ask Before Signing
Before entering or renewing a “full-service” vendor agreement, a practice should be able to answer clearly:
- What is our realistic net RPM margin after vendor costs and denials?
- How has the compensation structure been reviewed against AKS, Stark, and FCA risk?
- What are OIG and major payers currently saying about patterns similar to this model?
- How are patients selected and excluded, and what does that mean for equity and reputation?
- Can we obtain a complete, structured export of our data on demand, and what happens if we choose to exit?
The Market Is Moving Away From Vendor‑Run "RPM Factories"
OIG’s RPM findings and payer policy changes are not abstract. They are direct responses to the high‑volume, low‑documentation patterns that vendor‑driven models created.
The Headwind: RPM Factories
Regulators are targeting "device quotas" and high-volume billing without clinical context.
- OIG Scrutiny: Flagging claims with minimal device activity.
- Payer Cuts: UHC 2026 narrowing "medical necessity" for devices.
- Vendor Risk: Outsourced models create the exact patterns audits look for.
The Tailwind: APCM + In-House
CMS is actively incentivizing panel-based management models like Advanced Primary Care Management (APCM).
- Panel Stability: Ongoing management rather than device counts.
- Layered Care: RPM/CCM added only where clinically appropriate.
- FairPath Alignment: Our OS is built to run this exact stack in-house.
A Simple Scenario to Stress‑Test the Economics
Every practice is different, but the math is consistent. Here is where the money goes on a standard 200-patient panel.
Monthly Profit Comparison (200 Patients)
| Cost Category | Vendor Model 60% Rev-Share |
FairPath Model Software Fee |
|---|---|---|
| Total Reimbursement | $20,000 | $20,000 |
| Who Gets Paid? | -$12,000 (Vendor Share) | -$1,000 (Software Fee) |
| Hidden Fees (Device/Admin) | -$1,500 | -$1,000 |
| Your Monthly Net Profit | $6,500 | $18,000 |
Your Numbers Are Unique.
See Them Now.
The RPM Vendor P&L Analyzer takes "we’re probably getting ripped off" and turns it into hard numbers. Enter your vendor, patient count, and rev-share to see:
- Line-by-line breakdown of what you earn vs. what they keep.
- Risk detection for device-day gaps and code stacking.
- Exact comparison of your margin on a software-fee model.
[Screenshot: P&L Analyzer Interface]
Showing Inputs (Patients, Rev-Share) -> Output Graph
FairPath Is the Remote-Care OS for Practices
Not another vendor. The software you use to replace the vendor.
Multi-Program Spine
Runs APCM, RPM, CCM, and RTM on one integrated platform.
Compliance-as-Code Engine
Eligibility scoring, Nurse Amy, PriorityQ, and BillingQ automate the work.
100% Data Sovereignty
Works alongside your EMR under your governance. Your data, always.
FairPath works alongside the EMR you already use:
Your RPM, APCM, & Compliance Questions, Answered
These FAQs focus on how a modern, in‑house RPM/APCM/RTM/CCM stack works on FairPath—and how to think about vendors if you’re currently using one.
No, and this is a critical risk. Payer policies are tightening. UnitedHealthcare’s 2026 policy states RPM is only “necessary” for heart failure and hypertensive disorders of pregnancy, meaning RPM for other common conditions can be denied.
This is why relying only on RPM is dangerous. FairPath integrates Advanced Primary Care Management (APCM), a CMS‑approved program with stable, predictable revenue that isn’t diagnosis dependent. We help you build durable APCM revenue and layer RPM where it is both clinically appropriate and financially secure.
This is the “Vendor Trap.” That 50–70% rev‑share erases your margin.
The Math: You bill $100. They keep $70. You keep $30.
The FairPath Model: You bill $100. You pay a simple software fee. You keep the rest.
We stay transparent, while rev‑share vendors obscure true practice profit and push billing patterns that leave you holding the liability. FairPath provides the operating system; you keep the revenue you earn.
No. FairPath sits alongside your existing EMR. We integrate with your current workflows so your team doesn’t have to relearn everything or juggle another core system.
Stop trying to do it manually. FairPath’s Compliance‑as‑Code engine prevents bad claims before they are submitted by:
- Running a “Pre‑Flight Check” on every claim against OIG and MAC‑specific rules.
- Preventing code‑stacking conflicts (e.g., RPM vs. CCM/APCM overlaps) automatically.
- Monitoring the 16‑day transmission requirement and alerting you before the month ends.
- Generating an immutable audit trail so you can defend every claim.
Your staff doesn’t have to memorize billing rules—our software already knows them.
Start by requesting two things: a complete patient data export and the exit fee. Vendors that resist either are signaling lock‑in.
We are the anti‑vendor. FairPath is built on 100% Data Sovereignty. From day one you have full access to patient lists, device logs, and claim history, and you can export them anytime. Use the RPM Vendor P&L Analyzer and our Exit Blueprint to understand both the economics and the operational path out.
You take back control. Rev‑share vendors often lock you into pricey hardware leases to create hidden margins.
FairPath is device‑agnostic. We integrate with low‑cost commodity hardware and support patient‑owned devices where appropriate so you can reduce overhead and keep the margin you earn—without making hardware a new point of lock‑in.
Payer policy will change, and it will be disruptive. UHC’s 2026 update proves RPM‑only programs sit on unstable ground.
FairPath is a multi‑program platform that centralizes RPM, RTM, CCM, and especially APCM. When payers tighten RPM, you can pivot to APCM instead of watching revenue collapse. Our goal is to keep your practice stable, diversified, and ready for whatever comes next. If you want to understand the APCM‑first model in detail, read our APCM‑First strategy guide →.
Plan on 60–90 days. We start by stabilizing your current panel, then run FairPath alongside your vendor so you can validate eligibility scoring, PriorityQ, and BillingQ against their work. Once the data and payouts match, we wind down the vendor contract—without forcing you to hire new staff.
Ready to Design RPM and APCM on Your Own Terms?
Whether you are just exploring remote‑care options or actively evaluating a vendor, you don’t have to guess. See how FairPath would run your stack, and benchmark your current model against a software‑driven, APCM‑first approach.
