RPM Manual
The practical 2026 guide to device rules, day thresholds, management time, and audit defensibility for Remote Patient Monitoring.
Read the RPM Guide →The "Enrollment Spike" Red Flag: Why Growing Too Fast Triggers Audits
The Bottom Line
- The Trigger: Going from 0 to 500+ patients in a single month is a statistical anomaly that data miners at the OIG automatically flag.
- The Suspicion: Rapid spikes suggest you are enrolling a "roster" or "lead list" (business decision) rather than identifying individual clinical needs (medical decision).
- The Reality: True clinical necessity arises organically. It is highly unlikely that 500 patients all developed a need for RPM on October 1st.
- The Defense: If you must onboard quickly (e.g., a new program launch), you need individual "Medical Necessity" notes for every single patient, dated specifically to their encounter, not a bulk import date.
The "Hockey Stick" Curve: What the OIG Sees
The Office of Inspector General (OIG) uses data mining to identify fraud before they ever ask for a medical record. One of their primary signals is the Enrollment Velocity. They compare your billing patterns against the "natural" rate of disease progression in a population.
| Organic Clinical Growth (Safe) | "Roster Activation" (High Risk) |
|---|---|
| Start Date: Scattered throughout the month. | Start Date: 300 patients on the 1st of the month. |
| Pattern: Slow, steady ramp-up as patients come in for visits. | Pattern: Vertical spike ("Hockey Stick") indicating a bulk upload. |
| Implied Cause: Identifying need during office visits. | Implied Cause: Marketing campaign or vendor sales pressure. |
The "Cold Call" Problem
The OIG's recent report (OEI-02-23-00261) specifically targeted providers who used call centers to "cold call" beneficiaries and enroll them en masse. Even if you are a legitimate practice, using a vendor to bulk-call your own patient list to "sign them up" for RPM mimics this fraudulent behavior.
"We found that [high-risk providers] often billed for a large number of beneficiaries... immediately following enrollment, without evidence of a prior established relationship."
– OIG Report OEI-02-23-00261
Video Transcript
0:00 Here is a red flag that will get your RPM program audited faster than almost anything else: The Enrollment Spike.
0:06 We all want to grow. But if the OIG looks at your data and sees that you had zero RPM patients in September, and then 500 RPM patients on October 1st... that is not a clinical pattern. That is a marketing pattern.
0:18 Think about it. Did 500 people suddenly develop uncontrolled hypertension on the exact same Tuesday? Probably not.
0:25 When you see that vertical line on a graph, it tells the auditor that you prioritized filling the program over evaluating the patient. It looks like you bought a lead list or just "turned on" a roster.
0:36 Real clinical necessity happens one patient at a time, usually during an office visit. So, flatten the curve. Grow organically. Because if you spike, you better have 500 individual notes proving why every single one of them needed a device on that exact day.
Are you preparing for an OIG audit?
Don't guess what they will look for. Download our checklist of the Top 5 OIG Red Flags for Remote Patient Monitoring.
