OIG to Audit Provision of Behavioral Health Services Through Tele-Health Under Medicaid Managed Care

Sheppard Mullin Richter & Hampton LLP

Sheppard Mullin Richter & Hampton LLP

In its recently updated Work Plan, the Office of the Inspector General (“OIG”) at the Department of Health & Human Services (HHS) announced that it will conduct an audit focusing on how selected state Medicaid agencies and Medicaid managed care organizations (“MCOs”) leverage telehealth to provide behavioral healthcare.

The OIG’s Work Plan assesses relative risks in HHS programs and operations to identify those areas most in need of attention. As part of its telehealth review, OIG will review selected states’ monitoring and oversight of MCOs’ behavioral health services provided via telehealth. It will also identify states’ and MCOs’ practices in relation to how to maximize the benefits and minimize the risks of providing behavioral healthcare to Medicaid beneficiaries via telehealth.

OIG expects to issue the report in Fiscal Year 2020. Accordingly, Medicaid managed care plans that reimburse for telehealth services may expect to have those claims reviewed to confirm the patient was at an eligible originating site and that the statutory conditions for coverage were met, among other requirements.

It is unclear whether OIG’s decision to audit use of telehealth services for the provision of behavioral health care in the context of Medicaid managed care suggests that OIG will be scrutinizing use of telehealth more generally and in the context of other payers. We will continue to monitor the OIG’s activities in this regard and will post blog updates to keep our clients informed.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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