HHS OIG Develops Toolkit to Analyze Telehealth Claims to Assess Program Integrity Risks

Posted In Telehealth

On April 20, 2023, the United States Department of Health and Human Services Office of the Inspector General (HHS OIG) released a new toolkit designed to help analyze telehealth claims to assess federal healthcare program integrity risks. The toolkit is OIG’s latest action in its continued focus on telehealth services that OIG considers to be high risk. The toolkit is based on methodologies highlighted in OIG’s September 2022 data brief, which identified billing practices by Medicare providers that OIG was concerned posed a high risk to program integrity based on a review of Medicare fee-for-service claims data and Medicare Advantage data from March 1, 2020, through February 28, 2021 (OIG Data Brief). The September 2022 OIG Data Brief is discussed in detail in this prior On The Subject article.

OIG intends for the toolkit to be used by public and private parties, including Medicare Advantage plan sponsors, private health plans, State Medicaid Fraud Control Units, and other federal healthcare agencies to analyze program integrity risks and identify providers whose billing may pose a high risk and warrant further scrutiny.

Read more here. 

James A. Cannatti III
James A. Cannatti III* practices at the intersection of today's most pertinent health care issues, including digital health, health IT policy, and fraud and abuse, including Anti-Kickback Statute/Stark Law matters. With more than 10 years of experience in the US Department of Health & Human Services’ (HHS) Office of Inspector General (OIG), most recently as Senior Counselor for Health Information Technology, James is well-attuned to the regulatory issues impacting the rapidly evolving digital health landscape. Read James A. Cannatti III's full bio.  *Not admitted to practice in the District of Columbia; admitted only in Ohio. Supervised by principals of the Firm who are members of the District of Columbia Bar.


Amanda Enyeart
  Amanda Enyeart maintains a general health industry and regulatory practice, focusing on fraud and abuse, information technology and digital health matters. Amanda advises health care industry clients in all aspects of software licenses and other agreements for the acquisition electronic health record (EHR) systems and other mission critical health IT.  Amanda’s health care IT transactional experience also includes advising clients with respect to software development, maintenance, service and outsourced hosting arrangements, including cloud-computing transactions. Read Amanda Enyeart's full bio.


Marshall E. Jackson, Jr.
Marshall E. Jackson, Jr. focuses his practice on transactional and regulatory counseling for clients in the health care industry, as well as advises clients on the legal, regulatory and compliance aspects of digital health. Marshall provides counseling and advice to hospitals and health systems, private equity firms and their portfolio companies, post/sub-acute providers, physician practices, and other public and private health care companies in a variety of complex transactions and health regulatory compliance matters. Read Marshall Jackson's full bio.


Lisa Mazur
Lisa Mazur advises health care providers and technology companies on a variety of legal, regulatory and compliance matters with a particular focus on digital health topics, including telehealth, telemedicine, mobile health and consumer wellness. Lisa advises a variety of health care providers and technology companies involved in “digital health,” including assisting clients in developing and implementing telemedicine programs by advising on issues related to professional licensure, scope of practice, informed consent, prescribing and reimbursement. Lisa helps clients identify and understand the relevant legal issues, and develop and implement practical, forward-thinking solutions and strategies that meet the complex and still-evolving digital health regulatory landscape.  Read Lisa Mazur's full bio.


Dexter Golinghorst
Dexter Golinghorst focuses his practice on health law matters, providing regulatory and operational advice to traditional healthcare providers, industry innovators and other healthcare and life sciences clients. Learn more about Dexter's practice: https://www.mwe.com/people/dexter-golinghorst/

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