HS-OIG will work with the other OIG members in and leadership of the Pandemic Response Accountability Committee (PRAC) to produce a report describing the types of telehealth services that are available, including those that were expanded during the pandemic, and key program integrity risks associated with the use of telehealth across six selected Federal health care programs.
Audit of Home Health Services Provided as Telehealth During the COVID-19 Public Health Emergency
We will evaluate home health services provided by agencies during the COVID-19 public health emergency to determine which types of skilled services were furnished via telehealth, and whether those services were administered and billed in accordance with Medicare requirements. We will report as overpayments any services that were improperly billed. We will make appropriate recommendations to CMS based on the results of our review.
Audits of Medicare Part B Telehealth Services During the COVID-19 Public Health Emergency
Phase one audits will focus on making an early assessment of whether services such as evaluation and management, opioid use disorder, end-stage renal disease, and psychotherapy (Work Plan number W-00-21-35801) meet Medicare requirements. Phase two audits will include additional audits of Medicare Part B telehealth services related to distant and originating site locations, virtual check-in services, electronic visits, remote patient monitoring, use of telehealth technology, and annual wellness visits to determine whether Medicare requirements are met.
Home Health Agencies’ Challenges and Strategies in Responding to the COVID-19 Pandemic
This nationwide study will provide insights into the strategies HHAs have used to address the challenges presented by COVID-19, including how well their emergency preparedness plans served them during the COVID-19 pandemic.
Medicare Telehealth Services During the COVID-19 Pandemic: Program Integrity Risks
This review will be based on Medicare Parts B and C data and will identify program integrity risks associated with Medicare telehealth services during the pandemic. We will analyze providers’ billing patterns for telehealth services. We will also describe key characteristics of providers that may pose a program integrity risk to the Medicare program.
Medicaid—Telehealth Expansion During COVID-19 Emergency
Our objective is to determine whether State agencies and providers complied with Federal and State requirements for telehealth services under the national emergency declaration, and whether the States gave providers adequate guidance on telehealth requirements.
Use of Medicare Telehealth Services During the COVID-19 Pandemic
Findings: Beneficiaries used 88 times more telehealth services during the first year of the pandemic than they used in the prior year. Beneficiaries’ use of telehealth peaked in April 2020 and remained high through early 2021. Overall, beneficiaries used telehealth to receive 12 percent of their services during the first year of the pandemic. Beneficiaries most commonly used telehealth for office visits, which accounted for just under half of all telehealth services used during the first year of the pandemic. However, beneficiaries’ use of telehealth for behavioral health services stands out. Beneficiaries used telehealth for a larger share of their behavioral health services compared to their use of telehealth for other services. Specifically, beneficiaries used telehealth for 43 percent of behavioral health services, whereas they used telehealth for 13 percent of office visits.
Data Snapshot: Review of Beneficiaries Relationships With Providers for Telehealth Services
Findings: Most beneficiaries received telehealth services from providers with whom they had an established relationship. Notably, 84 percent of beneficiaries received telehealth services only from providers with whom they had an established relationship. Those enrolled in traditional Medicare were more likely to receive services from providers with whom they had an established relationship, compared to beneficiaries in Medicare Advantage. This pattern persisted among virtually all of the most common telehealth services. Beneficiaries tended to see their providers in person about 4 months prior to their first telehealth service, on average.
Use of Telehealth to Provide Behavioral Health Services in Medicaid Managed Care (Part 1)
Findings: While most States can identify which services are provided via telehealth, a few reported being unable to, limiting their ability to evaluate and oversee telehealth. In addition, only a few States have evaluated the effects of telehealth in their State; these States found increased access and reduced costs. Based on their own experiences, other States believe that telehealth increases access, has uncertain impacts on costs, and raises concerns about quality. Further, despite concerns about fraud, waste, and abuse, many States do not conduct monitoring and oversight specific to telehealth.
Use of Telehealth to Provide Behavioral Health Services in Medicaid Managed Care (Part 2)
Findings: Most States reported multiple challenges with using telehealth, including a lack of training for providers and enrollees, limited internet connectivity for providers and enrollees, difficulties with providers’ protecting the privacy and security of enrollees’ personal information, and the cost of telehealth infrastructure and interoperability issues for providers. Some States also reported other challenges, including a lack of licensing reciprocity and difficulties with providers obtaining informed consent from enrollees. These challenges limit States’ ability to use telehealth to meet the behavioral health needs of Medicaid enrollees.