Telehealth billing errors lead to overpayment

The OIG conducted an audit that found a Houston-area mental health and intellectual and developmental disabilities provider incorrectly billed Medicaid for some teleservices, leading to overpayments.

Specifically, the audit found that the Harris Center for Mental Health and Intellectual and Developmental Disabilities billed for eight services totaling more than $3,056 without meeting minimum time requirements, seven services totaling more than $679 using incorrect procedure codes, and five services totaling $490 without documentation to support that providers saw the client.

The Harris Center audit covered the period from September 1, 2020, to August 31, 2022, and reviewed whether the provider met state and federal regulations, including rules for using telehealth services to connect with clients. The focus on telehealth services ensures providers met program standards as COVID-19 drove growth of the practice from 1.1 million encounters in 2019 to 7.2 million in 2021.

Auditors also found that although the video platform used for teleservices can report the time spent with patients, this information was not made available for 128 of 144 visits, totaling more than $13,892 billed to the state. Of the visits where time logs were provided, nine showed the state overpaid by more than $1,121 for time not spent with clients.

Additional concerns related to medical records were found in three of the 246 tested encounters, which did not include required individualized family service plans. Lacking this plan can impact the client's care, lead to unnecessary services and result in inappropriate billing. 

The OIG also reviewed records for 15 employees, including physical therapy assistants, occupational therapy assistants, community services specialists and qualified mental health professionals. Designated medical professionals must properly supervise these employees and the Center claims it met this requirement. However, seven employee records were missing evidence that supervisory activities always occurred.

Auditors provided the Harris Center’s management team with recommendations that, if implemented, will bring the provider into compliance regarding the issues uncovered during the audit. Specifically, Harris Center should:

  •  Return $3,736 to the State of Texas.
  • Implement processes to:
    a)    bill using the appropriate procedure code, 
    b)    use the actual length of services provided as the basis for claims for time-based procedure codes,
    c)    align its billing processes with Texas Medicaid requirements.
  • Utilize existing software capabilities to maintain records that support the duration of service provided.
  • Maintain complete medical records that meet applicable Texas Medicaid Provider Procedure Manual requirements.
  • Implement a process to have designated health care professionals conduct and document supervision of applicable staff.