Medicare Improperly Paid Providers for Some Psychotherapy Services, Including Those Provided via Telehealth, During the First Year of the COVID-19 Public Health Emergency

Submitting OIG:

Department of Health & Human Services OIG

Date Issued:

Tuesday, May 2, 2023

Agency Reviewed / Investigated:

Department of Health & Human Services

Submitting OIG-Specific Report Number:

A-09-21-03021

Component, if applicable:

Centers for Medicare & Medicaid Services

Centers for Medicare and Medicaid Services

Location(s):

United States

Type of Report:

Audit

Special Projects:

Pandemic

Questioned Costs:

$35,560

Funds for Better Use:

$579,631,950

Number of Recommendations:

Report updated under NDAA 5274:

View Document:

Attachment	Size
92103021.pdf	1.44 MB

Recommendation Number	Recommendation Status	Significant Recommendation
23-A-09-068.01	Open	No
We recommend that the Centers for Medicare & Medicaid Services work with the MACs to recover $35,560 in improper payments made to providers for the 128 sampled enrollee days that did not meet Medicare requirements.
23-A-09-068.03	Open	No
Now that CMS has reinstituted most program integrity measures, we also recommend that CMS take the following steps, which if in effect during the audit period could have saved Medicare an estimated $579,667,510 during that period: Conduct medical reviews of psychotherapy services, including services provided via telehealth, to verify that the services are documented and billed in accordance with Medicare requirements.
23-A-09-068.04	Open	No
Now that CMS has reinstituted most program integrity measures, we also recommend that CMS take the following steps, which if in effect during the audit period could have saved Medicare an estimated $579,667,510 during that period: Implement system edits for psychotherapy services, including services provided via telehealth, to prevent payments for services that were billed incorrectly.
23-A-09-068.05	Open	No
Now that CMS has reinstituted most program integrity measures, we also recommend that CMS take the following steps, which if in effect during the audit period could have saved Medicare an estimated $579,667,510 during that period: Strengthen educational efforts to make providers aware of educational materials on how to meet Medicare requirements and guidance for psychotherapy services, including services provided via telehealth.
23-A-09-068.06	Open	No
Now that CMS has reinstituted most program integrity measures, we also recommend that CMS work with the MACs to take the following steps, which if in effect during the audit period could have saved Medicare an estimated $579,667,510 during that period: Review MAC jurisdictions' LCD requirements for psychotherapy services to identify which provisions effectively promote program integrity, and consider additional steps that CMS could undertake to ensure appropriate coverage and payment for psychotherapy services across all jurisdictions.

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

23-A-09-068.01

Open

We recommend that the Centers for Medicare & Medicaid Services work with the MACs to recover $35,560 in improper payments made to providers for the 128 sampled enrollee days that did not meet Medicare requirements.

23-A-09-068.03

Open

Now that CMS has reinstituted most program integrity measures, we also recommend that CMS take the following steps, which if in effect during the audit period could have saved Medicare an estimated $579,667,510 during that period: Conduct medical reviews of psychotherapy services, including services provided via telehealth, to verify that the services are documented and billed in accordance with Medicare requirements.

23-A-09-068.04

Open