Insights on Telehealth Use and Program Integrity Risks Across Selected Health Care Programs During the Pandemic

The Pandemic Response Accountability Committee’s (PRAC) Health Care Subgroup developed this report to share insights about the expansion—and the emerging risks—of telehealth in selected programs across six federal agencies during the first year of the COVID-19 pandemic. The selected programs, which provided telehealth services to about 37 million people in 2020 (up from just three million in 2019), included the Veterans Health Administration, Medicare, TRICARE, Federal Employees Health Benefits Program, Office of Workers’ Compensation Programs, and Department of Justice prisoner healthcare services. While the programs’ expansion and variety of telehealth services clearly helped individuals access health care during the crisis, the study also identified several integrity risks associated with billing that were similar across the multiple programs. These included high-volume billing, duplicate claims, and inappropriate charges for the most expensive level of telehealth services. The study found that data necessary for the oversight of telehealth services, as well as for the protection against integrity risks, was limited, affecting the ability of specific programs to calculate the total cost of telehealth services, determine total number of telehealth services delivered, identify which providers rendered telehealth services to beneficiaries, and distinguish between telehealth and in-person services provided. While the programs have some safeguards in place to oversee telehealth services, program integrity can be strengthened by implementing additional and ongoing monitoring of telehealth services, developing more billing controls to prevent inappropriate payments, conducting efforts to educate providers and individuals about telehealth, collecting additional data to support oversight, as well as collecting and reviewing data about the impact of telehealth on quality of care—another area in which data was found to be lacking. The PRAC encourages agencies, policymakers, and stakeholders to rely on the insights of this report to inform future decisions on telehealth and to protect against fraud, waste, and abuse.