Medicare Generally Paid for Evaluation and Management Services Provided via Telehealth During the First 9 Months of the COVID-19 Public Health Emergency That Met Medicare Requirements

Why OIG Did This Audit

In response to the COVID-19 public health emergency (PHE), CMS temporarily expanded access to health services provided via telehealth. From March 2020 through November 2020 (audit period), Medicare Part B paid approximately $10.3 billion for Evaluation and Management (E/M) services, including telehealth services, provided to Medicare enrollees nationwide. The telehealth expansion increased the risk of inappropriate payments in the Medicare program due to the extent and speed of the changes. Therefore, CMS's oversight of the telehealth expansion becomes increasingly important to ensure that enrollees receive the appropriate quality of care both during and after the PHE, while protecting the Medicare program from fraud, waste, and abuse.

Our objective was to determine whether physicians and other practitioners that provided E/M services via telehealth complied with Medicare requirements.

How OIG Did This Audit

Our audit covered $1.4 billion in Medicare Part B payments for more than 19 million E/M claim line services that were billed with place of service codes or modifiers indicating telehealth was used to provide the service our audit period. We selected a stratified random sample containing three strata of E/M services provided via telehealth during the audit period. One stratum included 30 E/M services billed as telehealth services provided to new patients and the other two strata each included 40 E/M services billed as telehealth services provided to established patients.

What OIG Found

Physicians and other practitioners that provided E/M services via telehealth generally complied with Medicare requirements. For 105 of the 110 sampled E/M services provided via telehealth, providers complied with Medicare requirements. However, for the remaining five sampled E/M services, providers did not comply with Medicare requirements. Medicare paid $446 for the five sampled E/M services for which providers did not document or insufficiently documented the services. We also identified potential documentation issues in the medical records used to support the sampled E/M services that we discuss in the Other Matters section of this report.

This report does not have recommendations because providers generally met Medicare requirements when billing for E/M services provided via telehealth and unallowable payments we identified resulted primarily from clerical errors or the inability to access records.

CMS elected not to provide comments on our draft report.