The Who

 When establishing RPM within an organization, it is important to first identify the need, ensuring that the efforts to establish the program align with the organization’s priorities. This can be difficult in a large organization. While there are many different opportunities for RPM, beginning with implementation of one RPM service may lend itself more successful to ensure sustainability. Once the initial service is established, then the program can be expanded to other RPM services and/or other locations. To ensure program success, key stakeholders need to be included as part of the implementation team. Team composition for a large-scale RPM implementation project can be categorized into clinical and operational stakeholders. Many of these team members are brought into the work after the initial business request (or case for change) has been submitted by a clinical lead and approved by the business/technology expansion committee. The following list describes roles that are often included, though may not be essential, in an institution’s RPM implementation project.

Clinical Stakeholders

• Executive Leadership: Director of Pharmacy, VP of Ambulatory Care, VP of Enterprise Clinical Services, etc.
  • Ensure alignment with institution’s over-arching vision, mission, and budget parameters.
  • Serve as Executive Sponsor for the formal project – provide final sign-off on the project charter and intended scope from the clinical leadership perspective.
• Pharmacy Lead
  • Write up and submit formal business request – pharmacist may be responsible (in whole or with physician) for this initial step, as many institutions value pharmacists as integral to innovative health monitoring programs.
  • Work closely with physician champion to establish qualifying criteria for patient enrollment, standard patient care process, and technical workflow.
  • Attend all project meetings and work groups to serve as liaison between clinical stakeholders and operational stakeholders.
    • Pharmacist is ideal patient-facing, “front-line” team member for this role.
  • Physician/Advanced Practice Provider (APP) Champion
    • Represent physician/APP team’s preferences regarding both patient-centered and practical aspects of workflow, including documentation and billing.

• Physician/APPs serve as “billing provider” when utilizing formal RPM billing.
• Provide, along with pharmacist, insight on scalability to other practice sites with differing staff make-up and patient populations.

Operational Stakeholders

• Project Manager
  • Host focus groups with clinicians to solidify scope of project and outline of goals based upon initial business request and IT department capacity.
    • Review and obtain approval from Executive Sponsor.
  • Hold consistent (often weekly - biweekly) “discovery calls” to allow a forum for essential information flow between operational and clinical stakeholders.
  • Set timelines, track progress and communicate consistently to entire team regarding successes, barriers, and recommended shifts in project focus.
• IT Lead
  • Confirm proper data transmission between health devices, patient applications, and medical chart (i.e., flow of data via Bluetooth technology).
    • Will often work with a team of informaticists or technicians.
  • Review clinician workflow requests and identify solutions or propose adaptations.
• Billing/Coding Supervisor
  • Review scope of project and relevant codes with charges provided by project manager.
  • Grant approval for integration of new codes with charges into institution’s catalog.
• EMR Education Manager
  • Ensure workflow is sensible and efficient within the electronic medical record (EMR).
  • Compile tip sheets and other relevant educational material regarding RPM workflow for clinicians and clinic staff.
• Legal Counsel
  • Assess and provide feedback on processes of billing and patient consent, enforcing compliance standards and minimizing any institutional liability.
• Marketing Representative
  • Review and certify any patient-facing educational materials or promotional messaging.
• Infection Prevention Staff
  • Advise on best practices for sanitizing and repurposing returned health devices.
    • Relevant if providing devices via a loan program, in which the patient returns the device upon achievement of health goals per provider discretion.

While the clinical stakeholders, project manager, IT lead, and informaticists will be involved throughout the entirety of the formal RPM implementation project, many of the other operational stakeholders are looped in as needed throughout various phases of development. It is typically the role of the project manager to identify and solicit guidance from appropriate contributors, with input from clinicians and leadership. Once a project manager is assigned to an RPM implementation project, the timeline to completion could be anywhere from 6 months to 18 months, depending on the necessary technology testing, EMR workflow build, and general communication and responsiveness from multiple stakeholders. These timelines can also be impacted by external influences such as policy changes related to RPM.

Upon completion of the development phase of the RPM project, a pilot should be launched – typically with the involved physician champion, pharmacist lead and a small number of patients. During this pilot, the project manager, IT lead, and other project support staff are available for troubleshooting issues and modifying existing workflow, as needed. Once the initial pilot is running satisfactorily, with the majority of “kinks” smoothed out, attention can be turned to expanding involvement and training to other clinical staff.

On-boarding efforts of new staff should first focus on attending physicians or qualified healthcare professionals (those who will be billing provider for the RPM service) and other clinical pharmacists who will help manage the remote monitoring program. Some health systems utilize medical residents, in concert with pharmacists, to monitor patients’ transmitted health data, communicate with patients, and perform clinical management. While pharmacists can be involved from start to finish in the RPM process – setting up the health device, educating the patient, monitoring data, making therapeutic adjustments under a Collaborative Practice Agreement (CPA), and documenting/billing for physician/ sign-off – it could be beneficial to train other staff for the RPM initiation step. This allows the pharmacist more time for patient care and clinical work.

Ideal staff members to assist with RPM initiation might include pharmacy technicians or medical assistants, who could walk patients through device set-up and technology syncing, and registered nurses, who could provide device and disease state education. It is essential that the trainer be knowledgeable to provide appropriate education to patients to gain clinically meaningful results. An alternative solution for the initiation step would be utilization of an external RPM vendor that provides medical equipment and education to the patient, allowing clinician review and oversight without pulling office/pharmacy staff from other job responsibilities.

The What

Devices

Must meet the FDA definition of medical device per Section 201(h)(1) of the Food, Drug, and Cosmetic Act¹: An instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or other similar or related article, including a component part, or accessory which is:
                (A) recognized in the official National Formulary, or the United States

                Pharmacopoeia, or any supplement to them,
                (B) intended for use in the diagnosis of disease or other conditions, or in the cure,

mitigation, treatment, or prevention of disease, in man or other animals, or
(C) intended to affect the structure or any function of the body of man or other animals, and which does not achieve its primary intended purposes through chemical action within or on the body of man or other animals and which is not dependent upon being metabolized for the achievement of its primary intended purposes. The term "device" does not include software functions excluded pursuant to section 520(o).

Data must digitally and automatically transmit

• Bluetooth enabled devices can be paired to a smartphone or in-home wifi “hub”
• Cellular enabled devices, though often more costly, connect directly to cell towers for data transmission, removing access to a smartphone or wifi as a requirement for engaging in this care model

Data may transmit:

• To an external platform supported by the device manufacturer or an RPM vendor requiring manual retrieval
• Through unidirectional EHR integration where data transmits to the EHR for viewing, but other actions related to device and data management may require accessing the external manufacturer or vendor platform
• Through bidirectional EHR integration, the EHR is equipped with device and data management tools, eliminating the need to access a separate platform

Devices engaged in RPM include but are not limited to:

• Blood pressure cuff
• Pulse oximeter
• Glucometer/glucose monitor
• Weight scale
• Thermometer
• Otoscope
• Spirometer
• ECG

Disease states

RPM can be used to manage acute or chronic conditions including but not limited to:

• Diabetes
• Hypertension
• Heart disease/Heart Failure
• COPD/Asthma
• Weight management
• Cellulitis
• UTI
• COVID-19
• Pneumonia

Consent process

Verbal or written consent must be documented before or at the point of engagement in an RPM service. While CMS does not dictate the specific components of RPM consent beyond billing and the treatment plan, the following may be considered for inclusion in consultation with organization legal and compliance representatives:

• An explanation that only one provider can bill for the service in a 30-day period, so that the patient is an informed participant in preventing duplicative billing
• What data will be transmitted and how that data will be used to inform the care plan
• The expectation for frequency of monitoring to encourage engagement
• When to seek urgent medical evaluation based on readings taken on RPM device
• That the RPM enrollment can be terminated and how to do so

Data and billing management

• Continuous data allows for proactive care but can be a challenge for integration into standard workflows. Options exist within some EHR platforms to set alert parameters so that the care team is notified of alert values in real time, but not of every value taken and can review aggregate data as needed. Organizations without these capabilities can partner with one of the increasing numbers of RPM vendors on the market for management of data and additional tools including RPM service documentation and billing management. Klas Research is one resource for evaluation and comparison of software and service companies in the RPM space.²

• Please refer to the Additional Resources section at the end of this toolkit for more information.

Table 3: Timeline of strategies for implementation³

The Where

RPM represents a versatile care model for pharmacists working in a variety of practice settings and can be utilized either to support a new service or to enhance an existing service. The following summaries of setting-specific considerations were prepared following one-on-one interviews and small group discussions among OPA Practice Advancement and Innovation Committee members and other Ohio pharmacists.

Non-FQHC Outpatient Ambulatory Care Practices

Practice site specific considerations:

• Pharmacists embedded within an outpatient ambulatory medical clinic have a model that aligns particularly well with the traditional RPM billing structure, as these practices are typically equipped for medical billing and may have established referral and communication processes to support collaborative service models with physicians or qualified healthcare professionals.
• While reporting of CPT codes is common practice in these environments, RPM billing has complexities that require workflow modifications, such as cumulative tracking of time spent in care management and days of data transmission. Further, storage of RPM devices can put strain on clinic space and management of technical aspects of the program, such as device troubleshooting, can detract from time spent in care management.
• Another advantage of this practice setting with respect to RPM implementation is that ambulatory care practices are typically a multidisciplinary environment which can allow for offloading of administrative and technical support tasks to other team members, where appropriate. When the practice is part of a network of clinics implementing the service, opportunities to centralize resources can further promote scaling of the service.

Example program:

• The Ohio State University Wexner Medical Center Primary Care Clinics, Columbus, Ohio⁴

Contact:

• Jen Sabatino, PharmD, BCACP
  Clinical Pharmacist - Ambulatory Care
  OSU General Internal Medicine Clinics and OSU Physicians Virtual Care Center
  Jennifer.Sabatino@osumc.edu
  
  

Federally Qualified Health Centers (FQHCs)

Practice site specific considerations^5-8:

• Payment and reimbursement policies, particularly Medicaid parity for RPM services, are critical for sustainability, as FQHCs often face workforce shortages and financial constraints that can limit program expansion. FQHCs can experience inadequate reimbursement for RPM services, which undermines the financial sustainability of these programs and exacerbates workforce recruitment and retention challenges.
• Equity considerations are paramount, as FQHCs serve populations with high rates of socioeconomic disadvantage, limited English proficiency, and variable digital access. Addressing these disparities requires investment in patient training, provision of devices, and reliable broadband access. FQHCs have reported mixed results in overcoming these barriers, highlighting the need for long-term policy support and infrastructure investment to ensure that RPM can be scaled and sustained in safety-net settings.
• Patient engagement and sustained use of RPM can be hindered by low health and digital literacy, lack of awareness of RPM benefits, and inconsistent access to reliable internet or devices, particularly among patients living in areas affected significantly by social determinants of health. At the same time, this population has the potential to benefit most from a more accessible care model that overcomes common barriers to in-office management. Pharmacists can partner with care teams in FQHCs to provide education and resources to promote productive engagement in RPM services that facilitate efficient chronic disease management for this vulnerable population.

Example program:

• Neighborhood Family Practice Community Health Centers, Cleveland, Ohio

Contact:

• Katie Posendek, PharmD, BCACP, 340B ACE
  Director of Pharmacy
  Neighborhood Family Practice
  KPosendek@nfpmedcenter.org
  
  

Community Pharmacies

Practice site specific considerations:

• Being typically separated from the eligible billing provider both physically and with respect to EHR access adds several administrative challenges and logistical barriers to implementation for community pharmacists within traditional RPM billing structure. In order for time spent by the pharmacist to “count” toward RPM care management codes, a business agreement with the eligible billing provider is required. Further, putting a CPA in place significantly maximizes the impact community pharmacists can make in RPM practice models.
• While identifying and gaining access to the provider or practice may prove challenging, RPM as a service model sells itself well as it improves clinical outcomes and increases the value of care provided, revenue and wRVUs for the practice without increasing patient visit burden or staffing demand. Once that relationship and agreement are identified and established, the pharmacist must implement a process for documenting RPM activities and time spent in a format that can be shared with the billing provider for monthly submission of charges. Keeping referrals to the service top-of-mind for partnering providers can be more challenging without the face time often needed with the practice in order to build relationships, so identifying a target population or disease state that ties to a value-based metric or other priority for the practice can promote engagement.
• Alternatively, some community pharmacies in Ohio have developed RPM services outside of the traditional billing model, in example through partnership directly with the payer. This model often retains all of the logistical elements of a traditional RPM service but eliminates the need for a physician or qualified healthcare professional to submit charges, as reimbursement to the pharmacy occurs not through payment of CPT code-based billing, but through contracts with per-member-per-month or value-based terms.

Example program:

• Shrivers Pharmacy, Multiple locations, Southeast Ohio

Contact:

• Andrea Kowalski, PharmD
  Director of Clinical Services
  Shrivers Pharmacy
  Andrea.Kowalski@shriverspharmacy.com
  
  

Hospital Outpatient Department (HOD)

Practice site specific considerations:

• Pharmacist contracting practices in hospital-based clinics can interfere with provider reporting of care management billing codes based on pharmacist time, as the pharmacists may not be credentialed within the same department as the physician or qualified healthcare professional. Facility billing and pharmacist contracting practices can impact reimbursement and the model under which pharmacy services are financially supported.
• When traditional RPM billing is not supported, HOD pharmacists may propose RPM care models for services that align with cost-avoidance and quality improvement priorities for the organization. Many health systems participate in risk-based or value-based payment contracts. As such, a health system may support, for example, a pharmacist-led heart failure service aimed at reducing readmissions and ED utilization by utilizing clinic-provided weight scales that transmit to the EHR, allowing for earlier detection of clinical deterioration.

Example program:

• Multiple, in various stages of implementation

Contact:

• Please reach out to info@ohiopharmacist.org and OPA can put you in touch with a representative with experience in HOD implementation.

The Why

Evidence suggests that remote physiologic monitoring (RPM) can improve clinical outcomes for a variety of chronic conditions, including hypertension, heart failure, and diabetes. For example, a 2025 study of 5057 patients engaged in hypertension management by a pharmacist utilizing RPM demonstrated higher rates of BP control across racial subgroups when compared to usual care.⁹ Hassan et al. reported that 90% of participants in a remote hypertension management program maintained their target systolic blood pressure 42 months after enrollment, demonstrating long-term benefits of RPM for hypertension management.¹⁰ Similarly, systematic reviews demonstrate that telemonitoring and telehealth reduce heart failure rehospitalization and mortality.¹¹ For diabetes, Aggarwal et al. found that continuous glucose monitoring (CGM) improved HbA1c levels, reduced hospitalizations, and reduced instances of diabetic ketoacidosis.¹² These findings highlight the wide-ranging benefits of RPM in chronic disease management.

In addition to improving clinical outcomes, RPM has demonstrated the ability to lower healthcare costs. Tan et al. conducted a systematic review that found RPM interventions demonstrated a downward trend in the risks of hospital admission/readmission, length of stay, number of outpatient visits and non-hospitalization costs.¹³ Similarly, Lynch et al. found that telehealth can lead to cost savings through in-home monitoring for heart failure patients.¹⁴ In their study, nurse and pharmacist interventions utilizing home monitoring prevented 26 emergency room visits over five months.

Pharmacists are well-positioned to support RPM services due to their accessibility and expertise in management of chronic disease.  Pharmacists have demonstrated the ability to provide effective clinical interventions in patients with chronic conditions such as hypertension, diabetes, and heart failure when utilizing RPM.^14-16 Notably, in a meta-analysis of randomized controlled trials of interventions targeting barriers to hypertension control, Mills et al. found that pharmacist led-interventions resulted in the greatest blood pressure reductions, making them significantly more effective than multiple health care professionals, nurses, and physicians at delivering interventions.¹⁷

Pharmacists can leverage the RPM model of care to provide accessible, efficient, and effective chronic disease state management and lower healthcare costs.

References

*Calendar Year 2025 payment rate specific to 15202 Ohio MAC

Cited References:         

1. How to determine if your product is a medical device. FDA.gov. 9/29/2022. Accessed 12/18/25. https://www.fda.gov/medical-devices/classify-your-medical-device/how-determine-if-your-product-medical-device
2. KLAS Research Telehealth & Remote Patient Monitoring Ecosystem 2023
   Vendor-Reported Capabilities and Customer Adoption. 7/6/23. Accessed 12/15/23. https://klasresearch.com/report/telehealth-and-remote-patient-monitoring-ecosystem-2023-vendor-reported-capabilities-and-customer-adoption/3079
3. Powell BJ, McMillen JC, Proctor EK, Carpenter CR, Griffey RT, Bunger AC, Glass JE, York JL. A compilation of strategies for implementing clinical innovations in health and mental health. Med Care Res Rev. 2012 Apr;69(2):123-57. doi: 10.1177/1077558711430690. Epub 2011 Dec 26.
4. Sabatino JA, Lee NS, Barnes KD, Coffey CP, Jonas DE, Tayal NH. Implementation modifications and outcomes of a pharmacist-led primary care remote hypertension service. J Am Pharm Assoc (2003). 2025 Nov 1:102971. doi: 10.1016/j.japh.2025.102971. Epub ahead of print. PMID: 41183593.
5. Heredia NI, Fernandez ME, Garza ER, et al. Federally Qualified Health Center Patients' Experiences With Remote Patient Monitoring as Part of Telehealth Services for Self-Measured Blood Pressure Monitoring. BMC Health Services Research. 2025;25(1):104. doi:10.1186/s12913-025-12253-3.
6. Groom LL, Schoenthaler AM, Budhrani R, Mann DM, Brody AA. Patient Utilization of Remote Patient Monitoring in a Pilot Implementation at a Federally Qualified Health Center. Telemedicine Journal and E-Health : The Official Journal of the American Telemedicine Association. 2025;. doi:10.1177/15305627251362373.
7. Hailu R, Sousa J, Tang M, Mehrotra A, Uscher-Pines L. Challenges and Facilitators in Implementing Remote Patient Monitoring Programs in Primary Care. JGIM. 2024;39(13):2471-2477. doi:10.1007/s11606-023-08557-x.
8. Porteny T, Brophy SA, Burroughs E. Experiences of Telehealth Reimbursement Policies in Federally Qualified Health Centers. JAMA Netw Open. 2025 Feb 3;8(2):e2459554. doi: 10.1001/jamanetworkopen.2024.59554.
9. Price-Haywood EG, Olet S, Singh SD, Burton J. Digital Pharmacist-Physician Collaborative Care Management of Hypertension for Medicare Patients. J Gen Intern Med. 2025 Dec;40(16):3831-3839. doi: 10.1007/s11606-025-09823-w. Epub 2025 Sep 19.
10. Hassan S, Blood AJ, Zelle D, et al. The long-term blood pressure trends following a remote hypertension intervention: a secondary analysis of the digital care transformation - remotely delivered hypertension management program. Hypertension. 2025 Apr;82(4):733-742. doi: 10.1161/HYPERTENSIONAHA.124.24475.
11. Bashi N, Karunanithi M, Fatehi F, et al. Remote monitoring of patients with heart failure: an overview of systematic reviews. J Med Internet Res. 2017 Jan 20;19(1):e18. doi: 10.2196/jmir.6571.
12. Aggarwal A, Pathak S, Goyal R. Clinical and economic outcomes of continuous glucose monitoring system (CGMS) in patients with diabetes mellitus: A systematic literature review. Diabetes Res Clin Pract. 2022 Apr;186:109825. doi: 10.1016/j.diabres.2022.109825.
13. Tan SY, Sumner J, Wang Y, et al. A systematic review of the impacts of remote patient monitoring (RPM) interventions on safety, adherence, quality-of-life and cost-related outcomes. NPJ Digit Med. 2024 Jul 18;7(1):192. doi: 10.1038/s41746-024-01182-w.
14. Lynch KA, Ganz DA, Saliba D, et al. Improving heart failure care and guideline directed medical therapy through proactive remote patient monitoring-home telehealth and pharmacy integration. BMJ Open Quality 2022;11:e001901. doi:10.1136/ bmjoq-2022-001901.
15. Mnatzaganian C, Bounthavong M, Abalos W, et al. Evaluation of pharmacist-led management of type 2 diabetes using personal continuous glucose monitors across a large tertiary academic health system. J Am Pharm Assoc (2003). 2025 Apr 4:102397. doi: 10.1016/j.japh.2025.102397.
16. Margolis KL, Asche SE, Bergdall AR, et al. Effect of home blood pressure telemonitoring and pharmacist management on blood pressure control: a cluster randomized clinical trial. JAMA. 2013;310(1):46–56. doi:10.1001/jama.2013.6549.
17. Mills KT, O'Connell SS, Pan M, et al. Role of health care professionals in the success of blood pressure control interventions in patients with hypertension: a meta-analysis. Circ Cardiovasc Qual Outcomes. 2024 Aug;17(8):e010396. doi: 10.1161/CIRCOUTCOMES.123.010396.
    
    

Additional Resources:

• American Medical Association - Remote Patient Monitoring Playbook
• Bipartisan Policy Center - The Future of Remote Patient Monitoring
• National Association of Community Health Centers - Self-measured Blood Pressure Monitoring (SMBP) Implementation Toolkit
• National Association of Community Health Centers - Reimbursement Tips: Remote Physiologic Monitoring (RPM) & Remote Therapeutic Monitoring (RTM)
• US Department of Health and Human Services - Billing for remote patient monitoring
• Independent Pharmacy Cooperative - Digital Health for Independent Pharmacies