Medicare Compliance & Reimbursement

Question: Like many Medicare practices, we’ve taken advantage of the telehealth expansion during the pandemic to help patients. However, we noticed that the OIG added Medicare telehealth services to its Work Plan active list. Is there anything we can do to protect ourselves from a claims review?

Ohio Subscriber

Answer: Yes, there are several things you can do to ensure your claims are airtight.

Work plan details: The HHS Office of Inspector General (OIG) added telehealth services to its Work Plan action list for two reasons.

First, the Centers for Medicare & Medicaid Services (CMS) is considering making some of the telehealth flexibilities permanent. Several industry organizations and Congress have reached out to CMS and the Department of Health and Human Services (HHS) asking them to not only extend many of the COVID-19-inspired telehealth benefits, but to make them permanent in future policymaking (see story, p.4).

OIG’s other motive for looking into Part B and Medicare Advantage (Part C) telehealth claims relates to the uptick in usage. “The second review will identify program integrity risks with Medicare telehealth services to ensure their appropriate use and reimbursement during the COVID-19 pandemic,” notes OIG in the work plan update.

Read more on the active Work Plan item at /www.oig.hhs.gov/reports-and-publications/workplan/summary/wp-summary-0000491.asp.

Reminder: Thorough documentation is essential to ensuring that your telehealth claims meet the necessary requirements — and to steer clear of OIG’s radar. “We expect the same level of documentation that would ordinarily be provided if the services furnished via telehealth were conducted in person,” CMS says in its COVID-19 frequently-asked-questions set on fee-for-service (FFS) billing.

Before you submit, you may want to check the Medicare covered services list and make sure the codes used are on it. Review the COVID-19-updated list at www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

Next: Once you’ve confirmed that you’re good-to-go, review the face-to-face (F2F) documentation requirements of the codes used — and crosscheck them with your notes from the telehealth visit. Your documentation will likely need to include: reason for the visit; history; review of systems (ROS); and notes about the service and the medical decision-making.

Plus, you’ll need to add why your practice utilized telehealth, the location of both the provider and the patient, the technological components you used, and the identities of all parties involved, including all clinical participants, beneficiary, and/or additional family members of the beneficiary.

Best practice: Don’t forget to clock your time, too, experts advise. “You should always record your time in case you need to use it to level the care,” advises Donelle Holle, RN, president of Peds Coding Inc., and a healthcare, coding, and reimbursement consultant in Fort Wayne, Indiana.

Tip: It’s a good idea to revisit the guidelines of your Medicare Administrative Contractor (MAC) before you submit your claims to see if there are any local requirements.

Resource: CMS continues to update its original COVID-19 FAQs on FFS billing with supplemental data. Take a look at the FAQ supplement, which includes revisions from July 15, at www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf?_cldee=anVkeUBqdWR5d2lsaGlkZS5jb20=&recipientid=contact-4d01407ec995e011ac48005056834d9b-217e32a7828a46239f5458c85b12912e&esid=a37922dd-737a-ea1-1-80e5-000d3a0f728a.