U.S. Oversight Agencies Identify Program Integrity Risks Related to Increased Telehealth Usage During the Pandemic

With the substantial increase in telehealth usage, the six participating Offices of Inspectors General (OIGs) identified program integrity risks related to billing for telehealth services during the first year of the pandemic:

• Risks involving inappropriate billing for the highest, most expensive level of telehealth services. For example, the Department of Health and Human Services (HHS) OIG identified more than 300 Medicare providers who billed for telehealth services at the highest, most expensive level every time.
• Concerns related to providers billing twice for the same service, which may indicate that providers are intentionally submitting duplicate claims to increase their payments, and concerns about high-volume billing, which may indicate that providers are billing for services that are not provided or are not necessary.
• Risks related to billing for services that may not have been appropriate for telehealth or ineligible for payment as a telehealth service. For example, HHS-OIG identified providers who billed for both telehealth services and facility fees, which would indicate the provider and patient were in the same location at the time of the telehealth visit. 
• Risks related to ordering unnecessary durable medical equipment or laboratory tests associated with telehealth visits, which is consistent with recent investigations and settlements involving telemarketing schemes.
• Risks related to the limited availability of information about the impact of telehealth on quality of care. In particular, HHS-OIG noted the need to evaluate quality of care, especially as it relates to audio-only telehealth services. The Department of Justice OIG found that the lack of robust data or policies on telehealth services could present barriers to the programs’ ability to assess quality of care.
• Concerns about the lack of complete and reliable data to oversee billing for telehealth services and to protect against program integrity risks. For example, HHS-OIG found that Medicare does not collect data about some of the providers who render telehealth services to a Medicare beneficiary, which is critical to oversight of “incident to” billing.

The report explained that all of the selected programs have some type of program integrity safeguards in place. However, the OIGs recommended additional safeguards to strengthen oversight of telehealth services:

• Programs could conduct additional and ongoing monitoring of telehealth services. For example, HHS-OIG recommends that Medicare “closely monitor telehealth services on an ongoing basis to identify providers who pose a risk to the program and conduct targeted reviews of these providers.”
• Programs could develop additional billing controls to prevent inappropriate payments for telehealth services.
• Programs could conduct efforts to educate providers and individuals about telehealth services. For example, HHS-OIG recommends that CMS target specific providers with high levels of inappropriate billing for telehealth services and provide them with additional education about the Medicare guidelines that should be followed.
• Programs could collect additional data to support better oversight of telehealth services. For example, HHS-OIG recommends that Medicare collect specific data on audio-only telehealth services and data to indicate when services are provided “incident to” supervising practitioners.
• Programs could collect and review information about the impact of telehealth services on quality of care. 

A copy of the report is available here.