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OIG Audit Uncovers $580M in Improper Medicare Payments for Psych Services

Analysis  |  By John Commins  
   May 05, 2023

Documentation errors and omissions for tele-mental health services accounted for $348 million.

More than half of the $1 billion in temporary pandemic-related psychotherapy services paid by Medicare in the first year of the public health emergency were incorrectly billed, federal auditors say.

The Department of Health and Human Services Office of the Inspector General examined the Centers for Medicare & Medicaid Services' mental health services records for both in-person and telehealth visits from March 2020 through February 2021 at the start of the public health emergency.

The audit covered approximately $1 billion in Part B payments for more than 13.5 million psychotherapy services during the period. The audit picked two random samples of psychotherapy services: one of 111 enrollee days for telehealth services, and the other of 105 enrollee days for in-person services.

For 128 of the sampled 216 enrollee days, providers did not properly document psychotherapy time or omitted other needed information. In 54 sampled enrollee days, providers' failed to sign their claims.

"Based on our sample results, we estimated that of the $1 billion that Medicare paid for psychotherapy services, providers received $580 million in improper payments for services that did not comply with Medicare requirements, consisting of $348 million for telehealth services and $232 million for non-telehealth services," OIG says. 

"The deficiencies we identified in our audit occurred because CMS's oversight was not adequate to prevent or detect payments for psychotherapy services, including telehealth services, that did not meet Medicare requirements and guidance," OIG says. "CMS's oversight was partially affected by the unprecedented challenges of the PHE because CMS's focus was to ensure that Medicare enrollees had access to health care."

"However, as CMS continues to reinstitute its program integrity measures and considers making other permanent changes to telehealth services, CMS should focus on implementing adequate oversight of providers to minimize the risk of paying for psychotherapy services, including those provided via telehealth, that do not meet Medicare requirements."

“CMS' oversight was partially affected by the unprecedented challenges of the PHE because CMS's focus was to ensure that Medicare enrollees had access to health care.”

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


KEY TAKEAWAYS

OIG examined the CMS' mental health services records for both in-person and telehealth visits from March 2020 through February 2021 at the start of the PHE.

The audit covered approximately $1 billion in Part B payments for more than 13.5 million psychotherapy services during the period.

Based on audit samples, OIG estimates that of the $1 billion that Medicare paid for psychotherapy services, providers received $580 million in improper payments.

Of the $580 million in improperly documented payments, $348 million were for telehealth services and $232 million were for non-telehealth services.


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