Telehealth Assessment and Surveillance for Behavioral Health Services


The Office of the Inspector General (“OIG”) of the United States Department of Health and Human Services recently published a report regarding the use of telehealth to provide behavioral health services to Medicaid registrants, calling for increased evaluation and monitoring in hopes of encouraging states to implement changes to improve the way their programs Medicaid use telehealth for behavioral health services, including mental health assessments, individual therapy, and medication management.

The report stems from a survey of Medicaid directors from 37 states and interviews with relevant stakeholders, providing insight into states’ telehealth surveillance efforts in January and February 2020, ahead of telehealth expansion. due to the COVID-19 pandemic. The report underscores the urgent need for increased telehealth surveillance, as most states apparently had not adequately assessed the impacts of telehealth in their state. For example, three states were unable to distinguish between services provided via telehealth and those in person, and only a few states had conducted meaningful telehealth evaluations in their state. Nonetheless, for those states that have done some type of telehealth assessment, they have generally found that telehealth increases access to care while reducing service costs.

The report also notes concerns about the quality of care provided and the high potential for fraud, waste and abuse. Indeed, the OIG found that many states do not conduct telehealth-specific surveillance or surveillance, with only 11 states performing telehealth-specific surveillance and surveillance. These concerns are all the more important as the The GM recently billed many health professionals are said to have been involved in telehealth fraud schemes, damaging the government by more than $ 1 billion.

The OIG then recommends the Centers for Medicare & Medicaid Services (“CMS”):

  1. Ensure that the three states unable to distinguish telehealth from in-person services implement indicators to differentiate these services;

  2. Conduct assessments and support state efforts to assess the impacts of telehealth on access, cost and quality of behavioral health services; and

  3. Monitor fraud, waste, and abuse, and support state efforts to oversee telehealth for behavioral health services.

CMS responded to the report by agreeing to the first recommendation and noting that it has supported the state’s telehealth efforts and is currently monitoring the impact of the COVID-19 public health emergency on behavioral health services. provided by telehealth.

This report highlights that wider use of telehealth is likely to result in increased government oversight, as evidenced by recent government actions focused on the telehealth space. Providers should therefore implement best practices to address the challenges associated with telehealth service delivery in order to effectively withstand the growing government oversight in this space.

Copyright © 2021, Sheppard Mullin Richter & Hampton LLP.Revue nationale de droit, volume XI, number 319


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