In an audit to determine if the Medicaid payments made to South Carolina healthcare facilities for telemedicine services were compliant with state and federal requirements, the Office of Inspector General (OIG) found 96 percent to be unallowable.
The audit covered $2.3 million in payments for telemedicine services for the period from July 1, 2014 through June 30, 2017. The audit used a “stratified random sampling” of 100 payments as the best representation for all Medicaid claims processed during the selected time period. Of those 100 payments, only three were found to be allowable. Of the rest, 95 were found to lack proper documentation regarding the starting and ending times and the location site for the medical service. The remaining two were disallowed because they were for in-office services, not telemedicine. The audit estimated that unallowable payments totaled at least $2.1 million ($1.5 million federal share) during the audit period.
The OIG is requesting the state of South Carolina to refund $1.5 million to the federal government. They are also recommending that healthcare providers receive formal training on the requirements for providing telemedicine services, and that telemedicine payments be periodically reviewed to ensure that the claims are complying with documentation requirements.
Compliance Perspective
Failing to ensure that Medicaid claims submitted for reimbursement were for telemedicine services and were properly documented to include all required information, (i.e., starting and ending times and the location site of the medical services) may result in a facility having to refund payments received, along with being deemed to have submitted false claims, in violation of state and federal regulations.
Discussion Points
- Review policies and procedures regarding the provision of telemedicine services.
- Train staff members about the documentation requirements for providing telemedicine services.
- Periodically audit to ensure that staff members are being trained regarding provision of telemedicine services and that claims being submitted meet state and federal compliance regulations.
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