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OIG Report Highlights Importance of Telehealth in Providing Behavioral Health Services, but Emphasizes Need for Additional Oversight

As we’ve previously covered, the COVID-19 pandemic has brought about a major increase in the prevalence of telehealth services, due in large part to regulatory flexibilities at the federal and state levels.  Beginning in March 2020, state Medicaid programs across the country loosened requirements for coverage of telehealth services provided to Medicaid beneficiaries, reducing barriers by allowing audio-only services and covering a broader scope of services delivered via telehealth.  The increase in telehealth has resulted in improved access to behavioral health services in particular, but according to an OIG report issued earlier this week, state Medicaid programs will need to increase their oversight of these services if the telehealth flexibilities become permanent.

“As the Nation confronts the psychological and emotional impact of COVID-19, the use of telehealth will be important in addressing behavioral health needs Medicaid enrollees,” the OIG report explains in discussing the reason for conducting the review of state evaluation and oversight for behavioral health in Medicaid.  While telehealth has long been an important tool used by states to improve access to behavioral health services for beneficiaries in rural and other underserved areas, the increase in telehealth utilization during the pandemic has highlighted its importance in increasing access to behavioral health services more broadly.  As states consider whether to make the telehealth flexibilities permanent, the report says, they will need additional data to determine which services best support Medicaid beneficiaries.

In conducting interviews with 37 Medicaid Directors from states that provide behavioral health services via telehealth through managed care organizations, the OIG found that most states have not evaluated the effects of telehealth in their state.  Further, some states were unable to identify which services were being provided via telehealth.  Those states that did evaluate the effects of telehealth found that telehealth increased access and reduced costs, although there are concerns about the quality of care provided and the potential for fraud, waste, and abuse.

To address these concerns, OIG has recommended that CMS take steps to ensure that states are able to identify those services being provided via telehealth.  OIG also recommended that CMS conduct evaluations, and support state evaluations, of the effects of telehealth on access, cost, and quality of behavioral health services.  Finally, OIG has recommended increased monitoring for fraud, waste, and abuse by CMS and the states.

The OIG acknowledges the importance of telehealth in improving access to behavioral health services, especially during a pandemic that has seen an increased need for such services.  As the federal and state governments take steps to make the telehealth changes of the past year and a half permanent, we can expect increased scrutiny of telehealth services.  Check back here for further updates on the evolving state of telehealth.

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Cassandra L. Paolillo is Of Counsel at Mintz whose practice involves advising health care clients on transactional and regulatory matters, including mergers and acquisitions, regulatory compliance, and general contracting. Cassie primarily works with providers and payors.