A new report from the Department of Health and Human Services Office of Inspector General (OIG) found that home health agencies (HHAs) rarely furnished services via telehealth early in the COVID-19 public health emergency. Just four claims in the OIG’s sample of 200 claims, which had service dates from March 1 through December 31, 2020, had home health services furnished by telehealth. None of the four claims fully complied with Medicare requirements for providing these services. OIG estimates that there are 127,999 claims in the sampling frame with telehealth services. None of the claims identified in the sample fully complied with Medicare requirements for home health services furnished via telehealth.

The errors occurred because the HHAs were unfamiliar with the Medicare requirements for such services which went into place in April 2020. More specifically, claims either did not include a provision in the plan of care allowing for the use of telehealth services or, if telehealth services were allowed, the plans of care did not tie the use of telehealth services to patient-specific needs identified in the comprehensive assessment.

In addition, one of the four claims, telehealth services substituted for a home visit ordered in the plan of care. The report includes two examples of how HHAs incorrectly included telehealth in plan of care statements. Beginning July 1, 2023, the Centers for Medicare & Medicaid Services required HHAs to report the use of telehealth services through two G-codes on home health claims— something LeadingAge repeatedly supported in addition to the Medicare Payment Advisory Commission recommending this requirement to CMS.