Functional electrical stimulation (FES) is an assistive technology shown to improve muscle condition when used appropriately and can also help patients with paralyzed or weak muscles to move. As such it has been explored as a form of exercise in the home environment. One parameter of this exploration which must be considered when interpreting the effectiveness of a device is patient compliance; that is, actual patient usage of a FES device in the home. In this short report, we discuss how the literature has historically reported compliance and propose, upon the premise of the literature, that compliance may be measured in three ways: anecdotally, externally, or procedurally. In emphasizing these methods, we stress that for clinicians or engineers to truly elucidate patient device usage, they must measure compliance by using a number of these measures.