Telehealth Today

January 6, 2021

In 2020, telehealth services took healthcare by storm largely due to the COVID pandemic. Prior to 2020, telehealth was available; however, it has not been largely used across the continuum. CMS, on a temporary and emergency basis, broadened access to Medicare telehealth services. This allowed beneficiaries to receive a wider range of services from their providers without having to travel to a healthcare facility. Providers started providing telehealth services for office, hospital, and other visits furnished via telehealth/telemedicine across the country and including in patient’s places of residence after March 6, 2020.

Deviation, unfamiliarity, or unawareness of official guidelines sets the atmosphere for poor outcomes both legally and financially. The rapidly evolving and ever-changing policies and guidelines have created much confusion and errors to occur when coding and billing telehealth or telemedicine visits. On September 30, 2020, the Department of Justice (DOJ) reported on charges of more than $4.5 billion in allegedly telemedicine false and fraudulent claims submitted by more than 86 criminal defendants in 19 judicial districts pertaining to telehealth and telemedicine visits. Some of the finding include unnecessary DME orders, genetic and diagnostic testing, pain medications for patient not established to the clinic or providers as well as insufficient documentation to support telehealth or telemedicine services. CMS Center for Program Integrity has also announced taking a record-breaking number of administrative actions related to telemedicine and telehealth fraud. Auditors are targeting practices to uncover medical necessity and other telemedicine violations; they’re leveraging hefty fines and Medicare is even revoking billing privileges. Is your organization at risk for punitive damages?

Key areas of risk include, but not limited to:

  • Documentation not including the start/stop times or total time of the medical appointment
  • Incorrect reporting of the virtual visit site/location of the medical service
  • Lack of or use of the telehealth modifiers with differing payer requirements
  • Unbundled services
  • Telephone visits billed more than once in a seven-day period
  • The patient record not authenticated by the provider
  • Insufficient documentation supporting the services billed

All of these key risk areas and more could be denied or be flagged for compliance on an audit.

Telehealth and telemedicine services that you have provided and continue to provide are at risk from scrutiny across all payers. Actions you take now can help your practice mitigate the risk of fraudulent charges, expensive fines, the potential payback of thousands of dollars, and more.

You can increase your compliance and decrease your financial and legal exposure by hiring Excite Health Partners LLC to initiate compliance reviews.

Call Excite Health Partners to help evaluate your reporting for telehealth and telemedicine compliant reporting and optimal reimbursement.

Rose Klemkosky, RHIA, CPCO, CMPA, RHIT, CCS, CPC, CCS-P, Coding Auditor & Educator


The Department of Justice 

Centers for Medicare & Medicaid Services