OIG Report Assesses Medicaid Telehealth Programs for Behavioral Health

A federal review has found that no state Medicaid programs are analyzing how telehealth affects the quality of behavioral health services even though many are offering virtual care coverage during the pandemic – and three states don’t even know which services are offered via telehealth and which are offered in-person.

Those results are found in a data brief issued by the Health and Human Services Department’s Office of the Inspector General (OIG). The review of Medicaid programs in 37 states uncovered concerns that states aren’t evaluating whether telehealth can improve access, reduce costs and boost quality of care, and many aren’t providing the oversight needed to reduce fraud, waste and abuse.

The states were not identified in the report.

According to that report, only two states have evaluated the effects of telehealth specifically on access to behavioral health services for Medicaid enrollees, and only one state has evaluated the effects of those services on cost – finding that one managed care plan saved $8,600 in emergency room costs and another saved $484,000 in transportation costs through telehealth. No state, meanwhile, has evaluated the effects of telehealth on quality of behavioral health services, including continuity of care and patient safety.

The report also noted that, while they haven’t evaluated the effects, 17 state did note that telehealth increases access to care, and “a few” reported that it increases access by potentially reducing barriers to care, such as location, transportation and the stigma of needing care. Six states have suggested that the impact of telehealth on cost is “largely uncertain,” and 10 states have noted concerns about the quality of services delivered via telehealth.

Also, 23 states report that fraud, waste and abuse are concerns with respect to telehealth, in some cases uncovering schemes that involve providers inappropriately billing for delivering both telehealth and in-person services, billing for services not rendered and billing for services delivered from outside the country. Yet only 11 states are monitoring for fraud, waste and abuse specific to telehealth.

“Given the importance of telehealth in Medicaid during the pandemic, States need to identify the services provided via telehealth so that they can better understand the effects of telehealth on access, cost, and quality of behavioral health services for Medicaid enrollees,” the OIG report states. “It is increasingly important that States evaluate the effects of telehealth to inform their decisions about how they will use telehealth in the future. Further, States also need to monitor and provide oversight of telehealth, as expanding the use of telehealth may present additional risk for fraud, waste, and abuse.”

The report is important as both states and the federal government look to improve access to mental and behavioral health services in the wake of a nationwide increase in depression, stress, anxiety and substance abuse. Those services can be delivered via connected health tools and platforms, either alone or in a hybrid program that integrates virtual and in-person care, but providers first have to understand where the value lies, how best to deliver these services and how to avoid fraud and abuse.

The OIG has recommended that the Centers for Medicare & Medicaid Services ensure that the three states identified in the report distinguish what services are offered via telehealth and what’s offered in person, and that CMS conduct evaluations and support states’ efforts to determine the value of telehealth on access, cost and quality of behavioral health services.

The agency is also recommending that CMS monitor state Medicaid programs for fraud, waste and abuse in the telemental health services and support state efforts to improve oversight of those programs.

According to the report, CMS officials have agreed with OIG investigators that three states are lax in their management of telehealth services, but it hasn’t explicitly said whether it will support the OIG’s recommendations to evaluate those telehealth services or monitor them for illegal activities.

“CMS noted that it is currently monitoring the impact of the COVID-19 pandemic on behavioral health services delivered via telehealth by managed care organizations and has provided States with a Risk Assessment Template to assist State efforts in identifying and addressing program risks,” the OIG report noted. “CMS stated it will consider the results from OIG’s study to develop ways to support State efforts to oversee behavioral health services delivered via telehealth by managed care organizations.”

“In its response, CMS noted that there is more work to be done to determine how to effectively conduct monitoring for fraud, waste, and abuse, and support State efforts to oversee behavioral health services delivered via telehealth by managed care organizations,” the report continues. “OIG agrees, and we stress to CMS the importance of its role and the need to be active in evaluating and overseeing the use of telehealth.”

“OIG’s findings show that, prior to the pandemic, there were opportunities for States to do more to evaluate and oversee the use of telehealth for behavioral health services,” the report concludes. “Given the growth of, and increased dependence on, telehealth during the pandemic, these opportunities have become even more critical to address, warranting additional steps by CMS to support and supplement State efforts to evaluate and oversee telehealth. Building on its current efforts in these ways will help CMS to ensure that telehealth meets the behavioral health needs of Medicaid enrollees while protecting the integrity of the Medicaid program.”