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Most Medicare Telehealth Claims Fail Documentation Audit

By John Commins  
   April 13, 2018

Medicare paid a total of $17.6 million in telehealth payments in 2015, compared with $61,302 in 2001, but a review found significant shortcomings in the documentation for the consultations.

More than half of the $13.8 million in Medicare telehealth payments examined by federal auditors fell short of reporting requirements.

Medicare telehealth payments include a fee paid to the clinician performing the service at a distant site, and an originating-site fee paid to the hospital or clinic where the patient receives the service.

However, the Department of Health and Human Services' Office of the Inspector General focused its audit on the more than 191,000 Medicare distant-site telehealth claims totaling $13.8 million and filed between 2014 and 1015 that did not have those required corresponding originating-site claims.

The auditors then reviewed a sampling of 100 of those incomplete telehealth claims and found that 31 did not meet reporting requirements.


  • 24 claims were unallowable because the beneficiaries received services at non-rural originating sites;
  • 7 claims were billed by ineligible institutional providers;
  • 3 claims were for services provided to beneficiaries at unauthorized originating sites;
  • 2 claims were for services provided by an unallowable means of communication;
  • 1 claim was for a non-covered service;
  • 1 claim was for services provided by a physician located outside the United States.

"We estimated that Medicare could have saved approximately $3.7 million during our audit period if practitioners had provided telehealth services in accordance with Medicare requirements," the auditors said.

OIG blamed CMS for the deficiencies, and said the agency failed to ensure that:

  • There was oversight to disallow payments for errors where telehealth claim edits could not be implemented;
  • All contractor claim edits were in place;
  • Clinicians were aware of Medicare telehealth requirements.

OIG recommended that CMS:

  • Conduct periodic post-payment reviews to disallow payments for errors for which telehealth claim edits cannot be implemented;
  • Work with Medicare contractors to implement all telehealth claim edits listed in the Medicare Claims Processing Manual;
  • Offer training sessions to clinicians on Medicare telehealth requirements.

CMS agreed with the recommendations.     

John Commins is a content specialist and online news editor for HealthLeaders, a Simplify Compliance brand.

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