Dismal OIG Report on Telemedicine

April 20th, 2020 - Wyn Staheli, Director of Research
Categories:   Compliance   Documentation Guidelines  
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At a time when telemedicine rules have been greatly expanded, it’s important to realize that this will not last forever. On April 15, 2020, an OIG headline practically screamed that “96 Percent of South Carolina’s Medicaid Fee-for-Service Telemedicine Payments were Insufficiently Documented or Otherwise Unallowable.” Wow, that's a very low approval rate. As providers are expanding their telehealth offerings, now is the time to understand the potential pitfalls since disallowed amounts will be taken back.

The vast majority of those problematic claims was that “the providers documented neither the start and stop times nor the consulting site location of the medical service.” These are easy fixes. Not all CPT code guidelines specifically require that the documentation includes start and stop times; however, when it comes to federal rules for telehealth services, it is a requirement. Be sure you pay close attention to the times listed in the code description for the service being provided. If it says 15 minutes, then a minimum of 8 minutes must be documented in order to qualify to report the service.

Note: For a more comprehensive discussion on time reporting, see one of innoviHealth’s specialty-specific Reimbursement Guides in their online store.

The other stated problem was that the patient encounter was actually an in-office consultation, not a telemedicine service so it should have been reported differently. Not every service is allowed to be provided via telemedicine and payers may have differing lists. Be sure you know what is required by your payer.

Proper documentation of services is key. An auditor should easily be able to determine which services were provided and for how long. Another key requirement to note is summarized by a recent announcement by one payer stating that (emphasis added)  “... the use of audio and video must be documented in the patient’s chart note.” Also, be sure you know individual payer documentation requirements. For example, Medicare typically  requires that you document both the distant site (provider location) and the originating site (patient location). 

While rules are less stringent, now is an excellent opportunity to take the time to properly set up a telehealth program in your organization. To read the complete report, see the References listed below.

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