OIG to Audit Telehealth Services in 2023

CMS has a substantial influence on how telehealth services are delivered and paid. Specifically, CMS sets forth regulation for payment and coverage requirements.

The Office of Inspector General (OIG)’s 2023 Work Plan will provide significant oversight on telehealth services including the impact of PHE flexibilities. The OIG reviews will provide objective findings and recommendations that can further inform providers about telehealth. The oversight intent is to ensure that the potential benefits from telehealth are realized for beneficiaries.

We got you! Here are our top 5 takeaways:

  1. Due to the PHE, actions have been taken to allow practitioners to provide telehealth services.
  2. Telehealth may offer an alternative method for necessary care to be safely delivered to residents in appropriate situations. This flexibility has been extended through CY 2024 and is no longer tied to the end of the federal PHE.
  3. If a beneficiary denies the use of telehealth, services will not be performed via this delivery mode.
  4. Creating an environment for successful telehealth services can make a huge difference in the efficacy of treatment. More guidance can be found here.
  5. Document, document, and then document some more. Proper documentation of the validity of the use of telehealth is imperative. Review entities will be looking for documentation as proof that the “right” steps were taken when performing telehealth (and other) services. Document any interdisciplinary collaboration, beneficiary consent to the delivery mode, the clinical appropriateness of the delivery mode, and that other options for safely delivering services in the direct presence between the resident and staff have been exhausted.


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