HHS’ Office of Inspector General found CMS may have improperly paid more than $2.26 million for virtual check-in and e-visit services, according to an April audit report.

The audit aimed to uncover vulnerabilities with CMS’ tech-based services for Medicare enrollees. The audit window — which spanned Jan. 1, 2019, through Dec. 31, 2022 — examined Medicare payments totaling $12.48 million for virtual check-ins and $11.67 million for e-visits.

Virtual check-ins cannot be linked to an evaluation and management service within the previous seven days or an E/M service or procedure within the following 24 hours. CMS could have made $1,964,125 in improper payments for 173,287 virtual check-in services that occurred within that timeframe and had the same diagnosis code for an enrollee. Of these, 120,316 E/M services also included an unnecessary modifier.

CMS may have made $298,200 in improper payments for 10,237 e-visit services, as well. These services took place within one week of another e-visit with the same diagnosis code for that enrollee. If falling within the same week, the cumulative communication time should have been billed.

OIG suggested CMS install system edits for billing communication tech-based services, which could have saved Medicare up to $2.3 million during the audit period. The office also requested that, in the physician fee schedule, CMS bolsters healthcare common procedure coding system code descriptions for virtual check-ins. CMS was also advised to further inform providers of billing requirements for virtual check-in and e-visit services.

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