Bradley attorney Jason Mehta was quoted in Report on Medicare Compliance on his suggestions for a compliant telemedicine program. The growth in telehealth services during the COVID-19 crisis has drawn the attention of the Department of Justice (DOJ), leading experts to anticipate increased enforcement in this space.
To have a compliant telemedicine program, make sure telemedicine orders are not identical. If 98% of patients are receiving the same order, there may be a reason to question it, Mehta said. “It’s important to be thoughtful and strategic,” he noted.
It's also important to use approved equipment. Mehta said that “generally, interactive telecommunications systems do not include telephone, fax, or email.”
Finally, organizations should only provide covered telemedicine services. CMS has increased the number, “but that is a dynamic list,” Mehta said. “If I’m the compliance officer, the first of every month I am making sure whatever services my organization is offering are covered.”
The original article, "CMS: Many Telehealth Codes are Here to Stay, but First Visit Will be in Person Post-PHE," appeared in Report on Medicare Compliance on November 23, 2020.