Pandemic Oversight Report on Telehealth Reveals Multiple Errors

Sarasota, FL (WorkersCompensation.com) – The Pandemic Response Accountability Committee (PRAC) is an independent oversight committee of the Council of the Inspectors General on Integrity and Efficiency (CIGIE). Earlier this month, the Healthcare Care Subgroup that is part of the PRAC released their findings on telehealth use the first year of the pandemic across 6 Federal programs: 

• Medicare
• Tricare
• Federal Employee Health Benefit Program
• Veterans Administration (VA)
• Office of Workers’ Compensation Programs
• Federal Bureau of Prisons and U.S. Marshals Service 

The December report reviewed 156 million telehealth services for approximately 37 million patients, a total up from only 3 million patients the previous year. Overall, the committee found that Medicare and Tricare had the greatest increases among the programs reviewed, with over 70 to 80 times the number of services from the previous year. DOL Workers’ Compensation Programs saw a 32 times increase, and Federal Employees Health Benefits program saw a 28 times increase. 

Medicare had the highest number of telehealth visits overall at 114.4 million, with a reimbursement total of $5.1 billion. The VA had 27.1 million visits, with reimbursement totaling $62 million. Federal Employees had a total of 8 million visits, paying out $646 million. Tricare had 5.9 million telehealth visits, and paid out $394 million. DOL had 58,000 telehealth visits and paid out $7.3 million in reimbursement. The DOJ Prisoner Health program had a total of 5,900 virtual visits with $444,800 in reimbursement. The total payout for all programs was $6 billion. 

For DOL, 11 percent of patients utilized telehealth. By comparison, the VA had the largest percentage of patients that utilized telehealth at 87 percent, followed by Tricare at 49 percent, Medicare at 43 percent, and Federal Employees at 40 percent. 

Office visits and behavioral health visits accounted for 93 percent of all telehealth services for DOL and 91 percent for Federal Employees, with physical, occupational, and speech therapy accounting for the remaining percentage. 

The committee found 5 trends in the telehealth claims they reviewed. 

Upcoding

Duplicate billing 

Billing for services not provided or not medically necessary

Billing for services no appropriate or not eligible for telehealth

Orders not meeting medical necessity 

The report cited an example of a DOL provider claim who inappropriately billed a 60-minute psychotherapy code on a consistent basis when they had treated the patient twice a week for 45-50 minutes. Another example given of inappropriate billing for DOL included a provider that billed for  acupuncture via telehealth. 

Another DOL example listed was a provider that the OIG identified as having an increase in durable medical equipment orders after the provider utilized telehealth. The analysts found that the provider’s claims accounted for three-quarters of all spending for DOL, and that the claims were all for the same type of equipment. 

One area of concern within the DOL claims included a provider that used untrained or unsupervised technicians while allegedly performing a virtual medical evaluation. 

Classification of services was also an issue as the DOL OIG found instances where telehealth services were incorrectly identified as in-person services. The concern raised was that providers may be billing with an incorrect place of service or modifier to indicate as such. 

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