New audits to focus on telehealth services offered during pandemic
Home health agencies have scrambled to incorporate telehealth into their plans of care for patients during the Covid-19 public health emergency, and they’re about to get tested on those efforts. The Office of Inspector General (OIG) of the U.S. Department of Health and Human services will conduct audits to determine which types of services were furnished via telehealth during the pandemic, and whether agencies met Medicare regulations for teleheath. “The OIG audits report as overpayments any services that were improperly billed and makes recommendations to CMS accordingly,” said J’non Griffin, President of Home Heath Solutions, a Simione Coding Company. She said the OIG audits are part of an overall effort to address how CMS will expand the use of telehealth services beyond the public health emergency. Telehealth services were covered under a public health emergency waiver issued by the Centers for Medicare and Medicaid Services (CMS) in 2020, and finalized in the CY 2021 Home Health Final Rule. “But telehealth services are not yet billable,” Griffin said. “They are allowed under amended regulations when they are incorporated into the patient's overall plan of care to achieve specific goals, but they are not yet considered billable by CMS.” Proposed legislation to make virtual visits billable under some circumstances has not yet made it out of committee in U.S. Congress. Some specific telehealth ground rules were laid out for agencies in the Final Rule, and OIG audits are likely to examine documentation to make sure agencies are following those rules. As one example, a face-to-face encounter with the physician or other qualified provider may take place via telecommunications as long as documentation shows the encounter occurred with both audio and visual components. Simply noting that an “audio-visual” encounter occurred may not be enough, however. In some cases medical reviewers have required specific language denoting the visual aspect of the encounter, such as a reference to the patient’s appearance. “Without that documentation, agencies could be at risk for not having a valid face-to-face,” Griffin said. The plan of care must include any provision of remote patient monitoring or other services furnished via telehealth, and those services must be tied to patient-specific needs as identified in the comprehensive assessment. “CMS has been very specific in saying that virtual visits must not replace routine visits to the patient’s home,” Griffin said. “Telehealth visits may be part of the episode of care when those services are tied to patient-specific needs that are set out in the comprehensive assessment, and there must be specific documentation in the plan of care indicating how the use of the telehealth visit is expected to help achieve specific goals for that patient," she said. Griffin recommends that agencies make certain their telehealth policies are in order and take care to follow their own policies.