OIG Advocates For Increased Oversight Of Medicaid Telehealth Services In Behavioral Health | Goodwin


The exponential growth of telehealth – in part due to the COVID-19 pandemic – has highlighted both its value in increasing access to care and the potential for abuse. The Office of the Inspector General (OIG) of the US Department of Health and Human Services has issued a report in September 2021, which found that many state Medicaid programs did not sufficiently assess whether telehealth improves access to care, reduces costs, or improves the quality of care for Medicaid recipients receiving behavioral health services . Additionally, the OIG has found that many state Medicaid programs do not provide the proper oversight needed to reduce fraud, waste, and abuse. In fact, only two (2) states have measured the effectiveness of telehealth on access to behavioral health services for Medicaid recipients. In short, the OIG concludes that more action should be taken to maintain telehealth surveillance, particularly in the context of behavioral health.


When it comes to behavioral health services such as mental health assessments and therapy, generally, depending on the limits of insurance coverage, telehealth can be used and could be covered. The OIG report addresses this concept and states, “As the nation grapples with the psychological and emotional impact of COVID-19, the use of telehealth will be important in meeting the behavioral health needs of Medicaid registrants. However, providers must first understand where the value lies, how best to deliver these services and how to avoid fraud and abuse; and it starts with the monitoring and evaluation of telehealth services in the Medicaid program.

OIG Conclusions

The OIG report revealed the following:

  • A few states (3 of 37) could not identify which telehealth services are even available to Medicaid recipients. Failure to identify services provided to Medicaid recipients limits the state’s ability to analyze the effects of telehealth for Medicaid registrants, monitor and provide telehealth-specific surveillance, or detect and prevent fraud.
  • Only a few states have assessed the impact of telehealth use on behavioral health services for Medicaid recipients, despite states’ responsibility to ensure access to care and ensure quality of care. a accompaniement The report showed that states were describing the challenges and limitations of using telehealth to meet the behavioral needs of Medicaid registrants. As the reimbursement landscape continues to change and there is an increasing shift towards telehealth service offerings to Medicaid beneficiaries, the OIG said it is essential for all states to assess the impact of telehealth. .
  • Despite state concerns about telehealth abuse (p. The OIG report concluded that many states (26 of 37) do not adequately monitor or monitor telehealth services to detect fraud, waste and abuse significantly. Due to the virtual nature of telehealth services and the complex regulatory environment, states cannot monitor telehealth services to the same degree as in-person services. The report also found that the efforts program integrity of several states are insufficient to monitor telehealth.

OIG recommendations

Since the Centers for Medicare & Medicaid Services (CMS) play an equally important role in evaluating and overseeing state Medicaid programs, the OIG recommends that the CMS work with the three states that are unable to distinguish telehealth from in-person services to ensure implementation of indicators. to identify which services are provided through telehealth. The OIG suggests that CMS conduct assessments and support state efforts to assess the effects of telehealth on access, cost and quality of behavioral health services and conduct surveillance for fraud, waste and abuse. In addition, the OIG encourages CMS to specifically support state efforts to oversee and monitor telehealth for behavioral health services.

Notably, CMS agreed with at least one of the OIG’s recommendations; namely, CMS reported that “it is currently monitoring the impact of the COVID-19 pandemic on behavioral health services provided through telehealth by managed care organizations and has provided States with a template for assessing risks to help state efforts to identify and address program risks. ” Additionally, CMS said that “it will review the results of the OIG study to develop ways to support state efforts to oversee behavioral health services provided through telehealth by managed care organizations. “. It remains to be seen whether these CMS efforts will be sufficient to assist the States concerned.

Take away food

Telehealth providers should keep in mind that states can begin to take stronger, more comprehensive steps to assess and ultimately restrict access to Medicaid funds for telehealth services. Based on the OIG report, we anticipate that, given that states are responsible for determining how their Medicaid programs cover telehealth use, the OIG report may trigger more active and meaningful surveillance and monitoring of telehealth. use of telehealth with Medicaid recipients. States can also begin to further assess the impact of telehealth on access, quality and cost. And, we anticipate that state Medicaid programs will likely undertake a larger analysis as they determine which services will continue to be covered in a post-pandemic COVID-19 world.

Accordingly, providers should take into account the increased surveillance foreseen by CMS of behavioral health services provided through telehealth. Providers receiving reimbursement for health care from the state, for example, should undertake a risk assessment and corrective action to ensure that telehealth services provided to Medicaid beneficiaries comply with that state’s laws on health care. telehealth. This includes reviewing accreditation policies to ensure that every healthcare professional is licensed in the state in which the patient receives services and that the company is tracking compliance. Additionally, as a general practice, telehealth providers should verify that the correct medical codes from current procedural terminology are used when providing behavioral health telehealth services to people enrolled in Medicaid. Finally, telehealth providers should confirm that they are properly monitoring the effects of their telehealth program on Medicaid recipients in order to better understand the impact of telehealth on access, cost, and quality.

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