Telehealth has become an integral part of healthcare delivery, providing patients with convenient access to medical services without the need to visit a physical healthcare facility. The COVID-19 pandemic accelerated the adoption of telehealth, with Medicare beneficiaries utilizing virtual visits at a significantly higher rate than before.
As telehealth programs continue to thrive, healthcare organizations must be aware of the compliance risks associated with these virtual visits. The Office of Inspector General (OIG) has been proactive in addressing telehealth fraud and abuse, issuing alerts and toolkits to guide healthcare providers in maintaining integrity in their telehealth programs.
Brian Conner, a partner at Baker Tilly, and Kim Hodson, a senior manager specializing in telehealth compliance, emphasize the importance of evaluating and mitigating compliance risks in telehealth programs. With the OIG signaling increased audits and scrutiny, healthcare organizations must ensure their programs are resilient and compliant with regulations.
The surge in telehealth usage in 2020 prompted IT and billing leaders to quickly expand their telehealth programs to meet the growing demand. Many organizations leveraged waivers from the Centers for Medicare & Medicaid Services to facilitate virtual visits over a variety of platforms. This rapid expansion brought about challenges in ensuring compliance with regulations and safeguarding against potential fraud and abuse.
Conner and Hodson stress the need for healthcare organizations to conduct thorough assessments of their telehealth programs to identify potential compliance gaps. Implementing robust compliance measures, such as monitoring and auditing telehealth activities, can help organizations proactively address risks and ensure adherence to regulations.
Furthermore, Conner and Hodson recommend training staff on telehealth compliance protocols and staying informed about evolving regulations and guidance from regulatory bodies. By fostering a culture of compliance and accountability within the organization, healthcare providers can mitigate risks and safeguard the integrity of their telehealth programs.
In conclusion, as telehealth continues to play a significant role in healthcare delivery, healthcare organizations must prioritize compliance and risk management in their telehealth programs. By proactively addressing compliance challenges and staying abreast of regulatory developments, organizations can ensure the sustainability and effectiveness of their telehealth initiatives in an increasingly regulated environment.
As telehealth services continue to grow in popularity and complexity, healthcare organizations must prioritize telehealth billing compliance to avoid potential risks of fraud and abuse. The Office for Civil Rights (OCR) has emphasized the importance of ensuring compliance in telehealth billing, especially as the public health emergency (PHE) flexibilities come to an end.
Healthcare organizations should focus on identifying and mitigating telehealth compliance risks by developing a robust compliance program that includes oversight, policies and procedures, education and training, internal audits, and monitoring. It is crucial to assess the organization’s unique risks and vulnerabilities related to telehealth billing compliance on a regular basis.
Top areas of focus for telehealth billing compliance include internal auditing and monitoring, as well as policies and procedures. Internal auditing and monitoring are essential to ensure that documentation supports the services being billed for and complies with regulations. Policies and procedures should be regularly updated to reflect the evolving telehealth landscape and reduce the organization’s risk.
The stakes for noncompliance in telehealth billing are high and can result in fines, settlements, corporate integrity agreements, patient safety risks, and privacy violations. Organizations that do not address telehealth compliance risks may face enforcement actions from regulatory bodies.
Telehealth compliance is not limited to Medicare and Medicaid providers, as commercial health plans also have government oversight. As telehealth continues to be a permanent fixture in healthcare delivery, providers must prioritize compliance efforts to avoid potential risks and penalties. Compliance programs must evolve to address the increasing prevalence and complexity of virtual care encounters.
As the healthcare industry adapts to the post-pandemic landscape, maintaining telehealth billing compliance will be essential for organizations to navigate regulatory requirements and ensure the delivery of high-quality care to patients.
