New Federal Reports on Telehealth: Urging Continuation and Identifying “High-Risk Providers”

In early September, the U.S. Department of Health and Human Services (HHS) Office of the Inspector General (OIG) released a report detailing that Medicare beneficiaries used 88 times more telehealth services during the pandemic’s first year than in the prior year.

The report recognized the importance of telehealth services, but also recognized the ongoing challenge in confirming these services are legitimate and provided in accordance with Medicare’s requirements. The OIG urged the Centers for Medicare and Medicaid Services (CMS) to conduct targeted oversight of the telehealth services.

To identify providers whose billing for telehealth services poses a high risk to Medicare, the OIG developed the following seven measures for CMS to scrutinize billing for: 

1. Both a telemedicine service and a facility fee for most visits;
2. Telehealth services at the highest, most expensive level every time;
3. Telehealth services for a high number of days in a year;
4. Both Medicare fee-for-service and a Medicare Advantage plan for the same service for a high proportion of services;
5. A high number of hours of telehealth services per visit;
6. Telehealth services for a high number of beneficiaries; and
7. A telehealth service and ordering medical equipment for a high proportion of beneficiaries.

A companion report also issued by the OIG analyzed the demographics of beneficiaries most likely to use telehealth and emphasized the important role telehealth played in Medicare beneficiaries’ access to care.

The companion report noted that unless policymakers take action, millions of beneficiaries will lose access to many telehealth services once the pandemic ends and the temporary exemptions to Medicare’s telehealth requirements terminate.