The Office of Inspector General’s work plan for 2021 includes audits on Medicare Part B telehealth (TH) use. Phase one of these audits focuses on assessing, among other things, whether E/M services conducted via TH meet Medicare requirements. Phase two of these audits will center around reviewing Medicare Part B TH services related to distant and originating site locations, virtual check-in services, electronic visits, remote patient monitoring, use of TH technology, and annual wellness visits to determine whether Medicare requirements are met.
This is a good time for providers to extract reports of TH services from the billing system and review the documentation against Medicare’s guidelines. Remember that medical necessity is an over-arching requirement for medical services and must be clearly documented in the visit note. In addition, Medicare rules require that the documentation include:
- The visit was conducted via TH (audio or audio/video)
- That the beneficiary gave consent for this type of visit
- The location of the patient
- Anyone else involved in the visit, such as a family member
If your own review reveals that some of your TH visits do not meet Medicare criteria, you can send a corrected claim from your billing system or through the IVR and change the CPT code, or call your Medicare administrator and ask the best way to fix your claim.