Telehealth Services – Proactively Assess Your Risk

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

Billing Compliance

  • 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

Recent Insights

Newsletter Sign-Up