The Office of Inspector General (OIG) within HHS https://oig.hhs.gov recently published the Data Brief titled Opportunities Exist to Strengthen Evaluation and Oversight of Telehealth for Behavioral Health in Medicaid.
OIG reviewed how states are increasingly relying on telehealth to provide behavioral health services to Medicaid enrollees. During the pandemic, states expanded the use of telehealth to address the behavioral health needs for Medicaid enrollees.
In order for OIG to review the issues related to telehealth and behavioral health services, a survey of State Medicaid Directors from 37 States provided behavioral health services via telehealth through managed care organizations plus interviews were conducted with relevant stakeholders.
The brief points out that CMS https://www.cms.gov and States play important roles in evaluating and overseeing Medicaid telehealth services. Evaluating the effects of telehealth on access, cost, and quality of behavioral health services is important in helping States make decisions on how best to use telehealth and to determine which populations benefit the most from these services.
Also, the information can help States decide which policies should be made permanent after the pandemic subsides, such as those regarding services and where enrollees can receive telehealth.
OIG Recommendations for CMS includes:
1) Endure that the three States that are unable to distinguish telehealth from in-person services implement indicators to identify which services are provided via telehealth
2) Conduct evaluations and support State efforts to evaluate the effects of telehealth on access, cost, and quality of behavioral health services
3) Conduct monitoring for fraud, waste, and abuse, and support State efforts to oversee telehealth for behavioral health services
According to the OIG Brief, CMS has concurred with the first recommendation but did not indicate whether they concurred with the other two recommendations. CMS reports that they will reach out to the three States to ensure that they are informed on ways to distinguish telehealth services from in-person services in the claims and encounter systems.
As for OIG’s second recommendation, CMS noted that they have provided the States with a toolkit and technical assistance but will consider the results from the study to determine how it can further support State and managed care organizations efforts to evaluate the effects of telehealth.
As for the third recommendation, CMS did respond that there is more work to be done to determine how to effectively conduct monitoring for fraud, waste, and abuse. The OIG Brief indicates that CMS should note the schemes that exist and conduct monitoring and oversight specific to telehealth for behavioral health services for potential fraud, waste, and abuse in Medicaid.
CMS notes that they are currently monitoring the impact of the pandemic on behavioral health services delivered via telehealth by managed organizations and has provided States with a Risk Assessment Template to assist State efforts to identify and address program risks.
Go to https://oig.hhs.gov/oei/reports/OEI-02-19-00401.pdf for the HHS OIG Data Brief published September 21, 2021.