Telehealth Services, Telehealth coverage

OIG Recognizes Telehealth Services Importance But Urges Caution


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The recent increase in telehealth has improved access to behavioral health services in ways that were previously unimagined by the average provider or provider group. Still, according to a Medicaid-related report published by the U.S. Office of the Inspector General (OIG) in September 2021, state Medicaid programs will need to increase their oversight of these services if the telehealth flexibilities become permanent. The OIG interviewed Medicaid directors from 37 states that provide telehealth behavioral services to understand how they evaluate telehealth use in their jurisdictions. The report offers these takeaways to deal with increasing demand as the U.S. population struggles with COVID:

1.  Most states have faced numerous challenges in their use of telehealth. Some of the challenges include a lack of knowledge about various professional training options for providers and enrollees; bandwidth limitations on the availability and reliability of internet connections for providers and enrollees, difficulty with providers knowing how to protect the privacy and security of enrollees’ personal information; the cost of telehealth infrastructure; and interoperability issues for providers. Most of these concerns can easily be addressed with tailored provider training and consultation.

2.  Fraud seems rampant. Twenty-three of the 37 states identified fraud as their primary concern, but only 11 states monitored telehealth fraud and wasted related to telehealth.

3.  Three states could not distinguish which services were provided to Medicaid beneficiaries via telehealth compared to in-person care.

4.  Only two states had evaluated telehealth’s effectiveness for improving the quality of and access to behavioral health services. The OIG said measuring quality and access “is particularly important in helping states make decisions about how best to use telehealth and about which populations benefit most from these services.”

5.  Only one state evaluated telehealth’s effect on cost. It found that pre-pandemic telehealth usage resulted in $8,600 in savings for emergency room care avoidance in one managed care plan and $484,000 in reduced transportation costs for another plan.

The OIG pointed out that even though Medicaid is a joint program run by the federal government and state governments, states are responsible for monitoring telehealth fraud. The OIG report stated that “fraud monitoring is essential to ensuring the fiscal integrity of the Medicaid program and to protecting Medicaid enrollees.” Given that the increase in telehealth services now involves increased access to behavioral health services, Medicaid programs will need to increase their oversight of these services if these flexibilities become permanent. As federal and state governments continue taking the proper steps in making telehealth measures permanent, we can expect to see increased scrutiny of telehealth services and telehealth coverage.

OIG Recommendations

The OIG offered these specific recommendations:

  1. CMS takes steps to ensure that states are able to identify those services being provided via telehealth versus in-person.
  2. CMS conducts evaluations and supports state evaluations of the effects of telehealth on access, cost, and quality of behavioral health services.
  3. Increased monitoring for fraud, waste, and abuse by CMS as well as the state Medicaid officials.

Ongoing Telehealth Services Scrutiny Moving Forward

The OIG acknowledged the critical role played by telehealth in providing access to behavioral health services, especially with the increased need for such services in response to the COVID-19 pandemic.  As federal and state governments decide which changes to roll back or keep, the U.S. healthcare community can expect increased governmental oversight of telehealth services.

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