The Office of Inspector General of the United States Department of Health and Human Services (“OIG”) recently announced that the Centers for Medicare and Medicaid Services (“CMS”) intends to institute a two-phase audit of Medicare Part B Telehealth Services. Telehealth has played an important role during the COVID-19 public health emergency (PHE), and CMS is exploring how telehealth services can be expanded beyond the PHE to provide care for Medicare beneficiaries. In the OIG’s recently updated Work Plan, the OIG announced that CMS would initially be auditing whether services such as evaluation and management, opioid use order, end-stage renal disease, and psychotherapy would meet Medicare requirements. Phase two will include additional audits of Medicare Part B telehealth services related to distant and originating site locations, virtual check-in services, electronic visits, remote patient monitoring, use of telehealth technology, and annual wellness visits to determine whether Medicare requirements are met. Here is the link to the OIG Work Plan:

Our healthcare attorneys are available to answer your specific questions about Telehealth during the COVID-19 PHE. Please reach out to your Lashly & Baer attorney with any questions. Prepared by attorneys Stuart J. Vogelsmeier, Richard W. Hill, and Scott A. Pummell.