The Department of Health and Human Services Office of Inspector General (OIG) says CMS needs to pay close attention to telehealth reporting in home health, as its first review of claims in 2020 showed non-compliance in each case where telehealth was used, particularly around telehealth inclusion in the plan of care.
The review of 200 claims between March and December 2020 found four claims involving telehealth, and none of the four met Medicare requirements, according to the OIG.
Particularly, two of the cases didn’t include a provision in the plan of care allowing for the use of telehealth services. The other two claims didn’t tie the use of telehealth services to patient-specific needs identified in the comprehensive assessment, as required. One of the claims also used telehealth services to substitute an in-person home visit, which is not allowed.
The OIG notes that the agencies were unfamiliar with Medicare requirements in this early period of the COVID-19 PHE, and that CMS has new requirements that telehealth use is logged on the claim. The OIG recommended that CMS monitor telehealth reporting “to determine whether further updates to regulations or guidance are necessary.”
Among the 194 claims that did not include telehealth services, 60 records had plans of care that included language allowing telehealth services, but only two met Medicare requirements.
The rest didn’t tie the telehealth use to the patient-specific needs identified in the comprehensive assessment.
For example, one stated: May use telehealth and telecommunications to provide services as necessary and appropriate according to the patient’s condition.
Sixteen plans of care erroneously suggested that telehealth could be used to substitute an in-home visit.