"Forever Codes" and RPM Billing Scrutiny: What Peterson Health's Criticism Means for Your Pricing Model

"Forever codes" is not a regulatory term. It is a criticism, and it has stuck because it describes something visible in the claims data: remote patient monitoring billed month after month, for years, in conditions where the clinical benefit of monitoring appears to fade after a few months.

The phrase came out of work by the Peterson Center on Healthcare and the Peterson Health Technology Institute, which synthesised three independent evaluations of digital health tools with an analysis of Medicare and Medicaid billing trends. One finding drove the headline: more than forty percent of traditional Medicare beneficiaries receiving remote monitoring for hypertension were monitored for longer than six months, past the point at which the evidence shows blood pressure control is typically achieved.

If your business model assumes an indefinite monthly recurring fee per enrolled patient, that finding is aimed at you.

Why the codes look like annuities

The Medicare remote physiologic monitoring family is structured as a setup code plus recurring monthly codes: device supply and data transmission for a thirty-day period, and treatment management time in twenty-minute increments. The recurring codes have no built-in duration limit and no requirement to demonstrate that the patient is still benefiting. Once a patient is enrolled and a device is in the home, revenue continues as long as data flows and someone reviews it.

That design made sense when the codes were created: the alternative was no payment at all for a category of care that plainly had value. The consequence, a decade on, is a payment stream that scales with enrollment rather than with outcomes, which is exactly the property independent analysts flag as wasteful.

The recommendations from that work are blunt. Align coverage and reimbursement with clinical value. Encourage high-impact use, particularly in rural settings, while discouraging ineffective use. Improve data collection so payers can tell which technology is actually in the home and what it is doing.

What is likely to change

Nobody has removed the codes. But the direction of travel across payers and policymakers is towards conditions on continued payment. The plausible mechanisms are already visible elsewhere in Medicare: documentation requirements tied to clinical response, duration limits or re-authorisation after a defined period, coverage tied to a named device category rather than "a device", and payment differentiated by condition because the evidence differs sharply between hypertension, diabetes and musculoskeletal care.

This sits alongside the broader move towards structured software payment. CMS's proposal to rename software-as-a-service items and create a dedicated payment status indicator, which we covered in the CY2027 OPPS SaMS rule and in OPPS status indicator O1, points the same way: more specific codes, more visibility, more ability to set payment deliberately rather than by default.

More visibility cuts both ways. It supports rate setting for products that work. It also makes long-duration, low-benefit billing easy to see.

What this means for your pricing model

Per-patient-per-month forever is the model under pressure. Four adjustments make a business more defensible.

Price to an episode, not to infinity. If your evidence supports benefit over a three-to-six-month intervention, sell a programme with a defined length and a defined outcome. You will lose tail revenue and gain a value story that survives a review. Products with a stopping rule are treated very differently from products without one.

Tie a portion of price to outcomes. Outcome-based contracting is no longer exotic in this segment, and a partial at-risk component is a strong signal that you believe your own data. Payers increasingly ask for it directly.

Separate the device economics from the service economics. If hardware supply and clinical review are bundled into one monthly fee, a payer cutting the monthly rate cuts both. Explicit components survive rate pressure better.

Segment by condition and by risk. A hypertension cohort near control and a poorly controlled heart failure cohort do not justify the same intensity or the same price. Being the vendor who says so is commercially safer than being the vendor whose average is challenged.

Documentation is now part of the product

The recommendation to improve data collection is the one most companies underrate. If a payer cannot tell from a claim which solution was used, what was measured and what clinical action followed, it will eventually resolve that ambiguity in the direction of paying less.

Build the record: device identity, transmission compliance, the clinical review that happened, the change in management that followed, and the outcome trajectory. That record is what supports continued payment under any tightened rule, and it is what an independent assessor needs if you want a favourable evaluation. Our market access guide covers how coding, coverage and payment interact; DevicePath helps keep the underlying documentation audit-ready.

It is also worth checking whether your clinical claims and your billing pattern tell the same story. If your marketing says patients stabilise in twelve weeks and your revenue model assumes thirty-six months of monitoring, someone will eventually put those two sentences next to each other.

The honest read

Remote monitoring works for some patients, in some conditions, for a defined period. That is a good product. It is not an annuity, and the companies pricing it as one are carrying policy risk they have not disclosed to their investors.

Founders who move first — episode pricing, outcome-linked components, condition-level evidence, clean documentation — will be negotiating from the same evidence base regulators and independent assessors are using. Everyone else will be negotiating against it.

MedTech Compass tracks reimbursement conditions and payment risk across 25+ markets, so you can see where a recurring-fee model is durable and where it is exposed before you build the forecast on it.

Sources

1. Peterson Center on Healthcare — New report outlines policy recommendations for remote health technologies: https://petersonhealthcare.org/news/report-outlines-policy-recommendations-for-remote-health-technologies/ 2. Peterson Health Technology Institute — Evolving Remote Monitoring: https://phti.org/evolving-remote-monitoring/ 3. Peterson Health Technology Institute: https://phti.org/ 4. CMS — Physician Fee Schedule: https://www.cms.gov/medicare/payment/fee-schedules/physician 5. CMS — Healthcare Common Procedure Coding System (HCPCS): https://www.cms.gov/medicare/coding-billing/healthcare-common-procedure-system 6. CMS — Hospital Outpatient Prospective Payment System: https://www.cms.gov/medicare/payment/prospective-payment-systems/hospital-outpatient 7. MedPAC — Report to the Congress: Medicare Payment Policy: https://www.medpac.gov/document/march-2026-report-to-the-congress-medicare-payment-policy/

This article is general information about coding and payment policy, not legal, regulatory or billing advice.