Recently, the Office of Inspector General (“OIG”) for the Department of Health and Human Services published its Report on Medicare Telehealth Services During the First Year of the Pandemic: Program Integrity Risks (OEI-02-20-00720)

OIG’s report describes providers’ billing for telehealth services and identifies ways to safeguard Medicare from fraud, waste and abuse related to telehealth. OIG determined this information can help CMS, Congress and other stakeholders determine what safeguards may be needed as they consider permanent changes to telehealth policies in Medicare. 

OIG identified 1,714 providers whose billing for telehealth services during the first year of the pandemic poses a high risk to Medicare. These providers billed for telehealth services for about half a million beneficiaries. They received a total of $127.7 million in Medicare fee-for-service payments. OIG expressed concerns the providers they identified as having “concerning billing” may be billing for telehealth services not medically necessary or that were never provided.

In its recommendations to CMS, OIG recommended targeted oversight of telehealth services, including: 

  1. strengthening monitoring and targeted oversight of telehealth service,
  2. providing additional education to providers on appropriate billing for telehealth services,
  3. improving the transparency of “incident to” services when clinical staff primarily delivered the telehealth service,
  4. identifying telehealth companies that bill Medicare, and
  5. following up on the providers identified in this report. 

CMS concurred with the recommendation to follow up on the providers identified in this report, but CMS did not explicitly indicate whether it concurred with the other four recommendations.

OIG’s Sept. 7 Report and additional telehealth resources can be accessed at these links on OIG’s website:

Please contact Matthew Babcock at if you would like to engage Harris Beach to obtain more information on this topic or to comment.