OIG audits mental health care provider’s billing for telehealth

The OIG conducted an audit of claims for psychiatric services to ensure the Center for Comprehensive Mental Health in McAllen billed correctly for telemedicine services. 

Telemedicine is a health care service that is (a) delivered by a physician licensed in Texas, or a health care professional acting under the delegation and supervision of a physician licensed in Texas, acting within the scope of the physician’s or health care professional’s license, (b) provided to a patient at a different physical location than the physician or health care professional, and (c) provided using telecommunications or information technology. 

The COVID-19 pandemic increased the use of telemedicine to connect providers with their patients, and Texas adopted waivers and changes to ease technology restrictions, expanding the number of Medicaid services available through telemedicine. The center’s physician, who is licensed to provide medical services in Texas, provided behavioral health services in the same manner as those in a traditional in-person setting as required. However, the center did not always bill the appropriate current procedural terminology (CPT) codes based on time duration for telemedicine evaluation and management services with add-on psychotherapy services. 

The center’s incorrect billing resulted in an overpayment of $936 for telemedicine evaluation and management services with add-on psychotherapy services, which must be repaid to the state. Additionally, the center did not provide its patients with the required written or electronic privacy practice notifications prior to evaluation or treatment. 

OIG auditors recommended that the center implement processes to ensure that claims for services billed as time-based CPT codes are based on the actual length of services provided and that medical records include documentation to support the CPT codes billed. Additionally, the center should provide patients with written or electronic notification of its privacy practices prior to evaluation or treatment via telemedicine services. For the full audit, click here.