In a recent review of telehealth services, the Office of Inspector General (OIG) found approximately one-third (31/100) of the claims reviewed did not meet Medicare telehealth requirements. Of the 31 cases, the majority were noncompliant because the patients received care in a location not considered “rural.” Institutions/facilities that provide telehealth services should be on notice. These findings combined with the increase in telehealth services provided – $61,302 in 2001 to $17,601,996 in 2015 – make telehealth a prime target area for the Centers for Medicare & Medicaid Services (CMS).
Telehealth remains a gray area for many institutions/providers making proactive auditing of the services essential. Institutions and providers engaged in providing telehealth services should consider two types of assessment/audits:
- Billing Compliance
- Privacy and Security
- What processes are in place to ensure
- Site is a certified rural originating site
- Practitioner at the distant site is licensed in that state to provide covered telehealth services
- Care is provided through an interactive audio and video telecommunications system that permits real-time communication
- Services provided are covered services
Privacy and Security Assessment
- What policies and procedures are in place to ensure the patient’s privacy is maintained?
- What safeguards have been implemented to ensure the method/s utilized are secure?
For more information on Telehealth Services, access CMS’ educational document at https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/TelehealthSrvcsfctsht.pdf.