In mid-April, CMS sent out a Medicare Learning Network (MLN) Connects Newsletter with a reminder to providers to bill correctly for telehealth services. In the short section in their newsletter, CMS cites a 2018 Office of Inspector General (OIG) report that found that there was a significant amount of telehealth claims that were improperly paid, and thus not billed correctly. As the OIG is currently conducting several audits on telehealth, it is possible that they may come to a similar conclusion again. The section also refers providers to several resources to ensure they are billing correctly, including the:

Telehealth Services MLN booklet:
https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/TelehealthSrvcsfctsht.pdf

Medicare Claims Processing Manual:
https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c12.pdf

Telehealth Payment Eligibility Analyzer
https://data.hrsa.gov/tools/medicare/telehealth

List of Covered Telehealth Services
https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes

For policies specific to the public health emergency (PHE), CCHP also recommends providers review the CMS resources listed in the Federal COVID-19 section in CCHP’s Policy Finder, as there are several telehealth flexibilities currently in place as a result of the PHE.

CCHP's Policy Finder:
https://www.cchpca.org/federal/?category=covid-19&topic=originating-site