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Telehealth is Here to Stay: Audits to Come

Telehealth continues to expand, but payers are starting to audit for compliance.

By  Adam Abramowitz, Senior Manager, Sales and Marketing

January 2022

As telehealth services have grown exponentially since the start of the COVID pandemic, payers want to take a look under the hood to see if providers are administering these services compliantly. Consequently, multiple payers have already announced plans for upcoming telehealth audits in 2022. As a result, providers need to determine their level of compliance with approved telehealth services.

Throughout the pandemic the expansion of permitted telehealth services has played a prominent role in delivering patient care and has helped providers capture revenue for these remote services. Although everyone agrees that telehealth will be here to stay, payers continue to make tweaks regarding appropriate telehealth usage and accompanying reimbursement.

Two examples of piecemeal telehealth implementation highlight how reimbursement will vary based on which payer processes the claim. For instance, we have seen differing reimbursement rates among providers for Level 4 and Level 5 telehealth services. Additionally, while many payers have added telehealth reimbursement for telephonic-only interactions (this is due to many patients not having the technology available for remote video appointments), the documentation requirements and guidelines for these services can change from payer to payer, and often significantly.

As is typically the case in our confusing healthcare system, guidance for a given telehealth service may vary by payer. What may be permissible for one payer may not be approved by another. In addition, each payer may require different supporting documentation for the same telehealth service. This is a lot to keep track of for providers, coders and billers. Furthermore, although payers have updated contracts to allow for payment for new categories of telehealth services, adoption has not been universal.

CBIZ KA Consulting Services (CBIZ) has advised numerous clients during the pandemic regarding their telehealth services. We have found significant inconsistencies in how organizations have implemented, documented and billed their telehealth services, both within organizations, and in comparison to best practices. There are organizations that haven’t billed for telehealth services on a consistent basis, which has resulted in lost revenue, and there are other organizations where their documentation would expose them to recoupments given current telehealth guidelines for particular payers.

As the pandemic now moves to the third year, not only do providers need to ensure that they are capturing telehealth revenue, but they also must review their telehealth coding and billing to ensure that their current practices would withstand an audit. While many telehealth cases are “small-dollar” reimbursements, the consistent misapplication of telehealth guidelines could lead to significant recoupments, not to mention the resource-intensive process of responding to and negotiating with payers and audit entities.

CBIZ is here to help with your telehealth needs. We provide two main areas of telehealth support:

  • Revenue identification – we identify areas where providers are not capturing telehealth revenue
  • Coding and billing compliance review – a review to ensure that cases are being billed appropriately and that the documentation supports the billed level of service

For questions or additional information about CBIZ’s telehealth services, please contact our office at 800-957-6900 or email at [email protected].

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