Time Tracking for RPM Billing: Documentation That Passes Audits

RPM codes 99457 and 99458 require documented time. Not estimated time. Not approximate time. Documented time.

Getting this wrong means denied claims or worse, audit exposure. Here's how to get it right.

What Medicare Requires

99457 (First 20 minutes)

Billable when:

• At least 20 minutes of clinical time in a calendar month
• Includes data review AND interactive communication
• Performed by clinical staff

99458 (Each additional 20 minutes)

Billable when:

• Additional 20-minute increments beyond first 20
• Same requirements as 99457
• Must have 99457 billed first

What Counts as Time

Includes:

• Reviewing CPAP compliance data
• Analyzing trends and patterns
• Phone or video calls with patient
• Secure messaging with patient
• Care coordination related to CPAP
• Documentation time

Does not include:

• Administrative tasks
• Scheduling
• Insurance verification
• Non-clinical activities

Time Tracking Methods

Manual Tracking

Paper log:

• Date, start time, end time
• Activity performed
• Patient identifier
• Staff signature

Pros: Simple, no technology needed

Cons: Easy to forget, hard to aggregate

Spreadsheet Tracking

Excel/Google Sheets:

• One row per activity
• Auto-calculate totals
• Sort by patient

Pros: Easy to total, searchable

Cons: Still manual entry, no integration

Integrated Tracking

In your compliance platform:

• Automatic time capture for data review
• Call timing logged automatically
• Rolls up to billing report

Pros: Most accurate, least effort

Cons: Requires compatible system

Documentation Standards

Minimum Required Elements

For each RPM encounter, document:

• Date of service
• Time spent (start and end or total minutes)
• Nature of activity
• Relevant findings or outcomes
• Staff credential

Sample Documentation

Data review entry:

Date: 2026-01-15

Time: 8 minutes

Activity: Reviewed 7-day compliance data for patient. Average usage 5.2 hours, AHI 2.3. No concerns identified. Patient on track for Medicare compliance.

Staff: J. Smith, RRT

Call entry:

Date: 2026-01-15

Time: 12 minutes

Activity: Coaching call with patient. Discussed mask fit issues. Patient reports air leak around nose. Advised adjustment to headgear, demonstrated via video. Will check data next week.

Staff: J. Smith, RRT

Monthly Billing Workflow

Week 1-3: Service Delivery

• Review data for all active patients
• Make outreach calls as needed
• Document all time as activities occur

Week 4: Billing Preparation

• Run report of all time logged
• Identify patients meeting 20-minute threshold
• Verify documentation complete

Month End: Claims Submission

• 99457 for patients with 20+ minutes
• 99458 for patients with 40+ minutes (one additional unit)
• Include or retain supporting documentation

Common Time Tracking Errors

Error 1: Estimating Time

Wrong: "I spent about 20 minutes on this patient"

Right: "I spent 8 minutes reviewing data (8:00-8:08) and 14 minutes on call (10:30-10:44)"

Error 2: Bundling Activities

Wrong: "Data review and calls: 45 minutes total"

Right: Separate entries for each distinct activity

Error 3: Missing Days

Wrong: Blank day when work was done

Right: Enter time the day it happens

Error 4: Non-Clinical Time

Wrong: Including hold time waiting for patient

Right: Only active clinical work

Staff Training Points

What to Track

• Every time you look at a patient's CPAP data
• Every call or message exchange
• Every clinical decision made
• Every care plan update

How to Track

• Log immediately (not end of week)
• Be specific (not "patient care")
• Note actual minutes (not rounded hours)

Why It Matters

• Revenue depends on accurate tracking
• Audits require documentation
• Inaccurate tracking = denied claims

Technology Solutions

Basic Requirements

• Easy time entry (few clicks)
• Patient association
• Date/time stamps
• Exportable reports

Advanced Features

• Auto-tracking for data review
• Call integration for automatic timing
• Threshold alerts (approaching 20 minutes)
• Billing integration

Audit Preparation

Maintain Records

Keep for 7 years:

• All time logs
• Supporting documentation
• Claims submitted
• Remittances received

Demonstrate Reasonableness

Time documented should be:

• Consistent with activity complexity
• Similar across comparable patients
• Reflective of actual work performed

Be Ready to Explain

If audited:

• What was done during the time
• How time was tracked
• Who performed the work
• What the outcomes were

Drift tracks RPM time automatically. Data review and calls logged without manual entry. [See RPM tools →](/support)