The OIG workplans plans to conduct a series of telehealth audits for Medicare Part B services

April 13, 2021

The scope of the audits

Phase one will focus on making an early assessment of whether services like evaluation and management, opioid use order, end-stage renal disease and psychotherapy meet Medicare requirements.

Phase two will include additional audits of 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 being met.

 

What can be done to prepare?

  • Understand the requirements for documentation
    • Review resources and regulatory requirements for the services performed via Telehealth
  • The rules for each service and distinguishing when it is appropriate to use telehealth and when it may not be a good idea
  • Make sure the regulation requirements are met when conducting telehealth and the technology used is an acceptable means to carry out the service
  • Internal audits
    • This is a good way to identify issues prior to being told you have an issue, and you can take corrective action to fix possible errors.

When documenting telehealth make sure you include the following;

  • A statement that the service was provided by using telemedicine, the specific mode of communication with the patient. Audio-Visual, Audio-only, etc.
  • The location of the patient
  • The location of the provider
  • Patient informed consent
  • The names of all persons participating in the telemedicine service and their role in the encounter
  • Document the encounter as you would in person, included normal documentation practices from chief complaints, HPI, any collected exam components and how they were collected, as well as clear documentation to support the diagnosis selected and treatment plan going forward.
  • Time

 

Please see the following resources to review telehealth requirements;

https://www.youtube.com/watch?v=Bsp5tIFnYHk – Medicare released an informative video on these services.

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/TelehealthSrvcsfctsht.pdf - The telehealth services booklet from Medicare

https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes -list of service codes included in telehealth

https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf - FAQs for all things Covid-19 as well as a section of questions asked about telehealth.

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