Illinois Generally Complied With Requirements For Claiming Medicaid Reimbursement for Telehealth Payments During COVID-19, A-05-21-00035
- Issuer
- Office of Inspector General
- Document type
- Report
- Date
- 2020-03-01
Summary
An audit report, No. A-05-21-00035, issued in December 2022 by the Department of Health and Human Services Office of Inspector General on Illinois Medicaid telehealth payments during COVID-19. The audit covered 584,492 Medicaid fee-for-service telehealth payments totaling $21,052,452 ($13,980,157 Federal share) claimed for March 1, 2020, through March 1, 2021. The report finds that 583,960 payments complied with requirements and 532 did not, including 249 payments where one provider was paid both originating and distant site fees and 146 duplicate payments. It calculates unallowable payments of approximately $16,154 ($9,832 Federal share) and recommends a refund, periodic reviews and a list of acceptable telehealth procedure codes. The Illinois Department of Healthcare and Family Services letter of December 13, 2022 concurs with the three recommendations.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
Department of Health and Human Services
OFFICE OF
INSPECTOR GENERAL
ILLINOIS GENERALLY COMPLIED WITH
REQUIREMENTS FOR CLAIMING
MEDICAID REIMBURSEMENT FOR
TELEHEALTH PAYMENTS DURING
COVID-19
Inquiries about this report may be addressed to the Office of Public Affairs at
Public.Affairs@oig.hhs.gov.
Amy J. Frontz
Deputy Inspector General
for Audit Services
December 2022
A-05-21-00035
Office of Inspector General
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THIS REPORT IS AVAILABLE TO THE PUBLIC
at https://oig.hhs.gov
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OFFICE OF AUDIT SERVICES FINDINGS AND OPINIONS
The designation of financial or management practices as
questionable, a recommendation for the disallowance of costs
incurred or claimed, and any other conclusions and
recommendations in this report represent the findings and
opinions of OAS. Authorized officials of the HHS operating
divisions will make final determination on these matters.
Report in Brief U.S. DEPARTMENT OF HEALTH & HUMAN SERVICES
Date: December 2022
OFFICE OF INSPECTOR GENERAL
Report No. A-05-21-00035
Why OIG Did This Audit Illinois Generally Complied With Requirements for
Medicaid telehealth refers to the Claiming Medicaid Reimbursement for Telehealth
services provided via a
telecommunication system. A Payments During COVID-19
Medicaid patient at an originating
site uses audio and video equipment What OIG Found
to communicate with a health Illinois generally made telehealth payments that were in accordance with
professional at a distant site. Federal and State requirements. Of the 584,492 Medicaid fee-for-service
Medicaid programs saw a significant telehealth payments in our population, 583,960 payments were in
increase in telehealth services due to compliance with the requirements, but the remaining 532 payments were not
the COVID-19 public health in compliance with applicable requirements. For 249 payments, the same
emergency. provider was paid both the originating site and distant site fee. There were
146 payments made as duplicate payments for the same services provided to
Our objective was to determine the same recipient on the same day. Also, 22 of the payments were
whether Illinois complied with inaccurately billed as both originating and distant site fees. Finally, providers
Federal and State requirements when incorrectly used the telehealth modifier with 35 different procedure codes
claiming Medicaid reimbursement for that are for in-person services. A total of 115 telehealth payments were
telehealth payments during COVID- identified with these codes that could not be performed via
19. telecommunication systems. This noncompliance occurred because the State
agency did not adequately monitor compliance. The State agency also did
not establish a list of acceptable telehealth procedure codes. Based on our
How OIG Did This Audit testing, we calculate the unallowable payments totaled approximately
We reviewed 584,492 Medicaid fee- $16,154 ($9,832 Federal share) during our audit period.
for-service telehealth payments,
totaling $21,052,452 ($13,980,157 What OIG Recommends and Illinois Comments
Federal share), that Illinois claimed We recommend that Illinois refund up to $9,832 to the Federal Government
on their March 1, 2020, through and enhance the monitoring of provider compliance by conducting periodic
March 1, 2021, Federal financial reviews of telehealth payments for compliance with requirements. Also, we
participation Reports. We analyzed recommend that Illinois establish a list of acceptable telehealth procedure
the payments looking for trends in codes.
the services provided and categorized
any unusual or duplicative billing Illinois agreed with our findings and provided information on actions that it
issues. We researched procedure planned to take to address our recommendations. The actions Illinois
codes and the types of services that described include: (1) reimbursing the Federal Government $9,832,
can be performed via (2) continuing to develop a quality assurance program to review samples of
telecommunication systems. We also claims, and (3) implementing edits to prohibit inappropriate procedure codes
contacted providers and reviewed from being billable.
medical records for 230 payments.
The full report can be found at https://oig.hhs.gov/oas/reports/region5/52100035.asp.
TABLE OF CONTENTS
INTRODUCTION............................................................................................................................. 1
Why We Did This Audit...................................................................................................... 1
Objective ........................................................................................................................... 1
Background ....................................................................................................................... 1
Administration of the Medicaid Program and Telehealth ..................................... 1
Telehealth Services in Illinois Prior to COVID-19.................................................... 2
Telehealth Services in Illinois During COVID-19..................................................... 2
Telehealth Reimbursement in Illinois .................................................................... 2
How We Conducted This Audit.......................................................................................... 3
FINDINGS ...................................................................................................................................... 3
Federal and State Requirements ....................................................................................... 4
The State Agency Made Telehealth Payments Not in Compliance
With Requirements ..................................................................................................... 5
The State Agency Made 249 Payments That Did Not Comply
With Telehealth Location Requirements ............................................................ 5
Providers Were Paid for 146 Services Two Times.................................................. 5
Providers Incorrectly Billed 22 Claims as Both an Originating and
Distant Site Service ............................................................................................. 5
Providers Incorrectly Added the Telehealth Modifier ........................................... 6
The State Agency Could Improve Controls and Monitoring Over Telehealth Billing.......... 6
RECOMMENDATIONS.................................................................................................................... 6
STATE AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL RESPONSE ............................ 7
APPENDICES
A: Audit Scope and Methodology...................................................................................... 8
B: Federal Requirements ................................................................................................ 10
C: State Agency Comments ............................................................................................. 11
INTRODUCTION
WHY WE DID THIS AUDIT
Medicaid telehealth refers to the services provided via a telecommunication system. A
Medicaid patient at an originating site uses audio and video equipment to communicate with a
health professional at a distant site. 1 Medicaid views telehealth services as a way to provide
medical services between places of lesser and greater medical capability or expertise, or both,
for the purpose of evaluation and treatment.
Under the President’s national emergency declaration and the Secretary’s public health
emergency declaration, the Centers for Medicare & Medicaid Services (CMS) has temporarily
waived certain requirements and encouraged States to exercise broad flexibilities for the
provision of telehealth services to minimize the impact of COVID-19 on health care facilities,
decrease community spread of COVID-19, and increase access to medical care. By expanding
access to telehealth, people who are self-isolating are allowed to continue medical services
from their homes, freeing space in hospitals and other health facilities for COVID-19 patients
who require in-person care. Expanding access to telehealth also allows people to continue to
receive regular services, such as wellness checks, therapy appointments, and more, while social
distancing orders are in place.
Because of the speed with which telehealth has expanded during the COVID-19 pandemic, we
maintain the opportunity exists for inefficiencies and potential abuse of the telehealth system.
Rapid expansion of telehealth may pose challenges for providers and State agencies, including
State oversight of these services.
OBJECTIVE
Our objective was to determine whether the Illinois Department of Healthcare and Family
Services (State agency) complied with Federal and State requirements when claiming Medicaid
reimbursement for telehealth payments during COVID-19.
BACKGROUND
Administration of the Medicaid Program and Telehealth
The Medicaid program provides medical assistance to low-income individuals and individuals
with disabilities. The Federal and State Governments jointly fund and administer the Medicaid
program. At the Federal level, CMS administers the program. Each State administers its
Medicaid program in accordance with a CMS-approved State plan. Although the State has
considerable flexibility in designing and operating its Medicaid program, it must comply with
1
See the “Federal And State Requirements” section for definitions of “originating site” and “distant site.”
Illinois Generally Complied With Requirements for Claiming Medicaid Reimbursement for Telehealth Payments
During COVID-19 (A-05-21-00035) 1
applicable Federal requirements. In Illinois, the State agency administers the Medicaid
program.
For purposes of Medicaid, telehealth seeks to improve a patient’s health by permitting two-
way, real-time interactive communication between a patient at an originating site and a
provider at a distant site. States may claim Federal financial participation (FFP) for amounts
expended as medical assistance under the State plan. 2
Telehealth Services in Illinois Prior to COVID-19
Telemedicine is the use of a telecommunication system to provide medical services for the
purpose of evaluation and treatment when the patient is at one medical provider location and
the rendering provider is at another location. The interactive telecommunication system must,
at a minimum, have the capability of allowing the consulting distant site provider to examine
the patient sufficiently to allow proper diagnosis of the involved body system. The
telecommunication system must also be capable of transmitting clearly audible heart tones and
lung sounds, as well as clear video images of the patient and any diagnostic tools, such as
radiographs. Telehealth is defined as the services provided via a telecommunication system. 3
Telehealth Services in Illinois During COVID-19
The Executive Order signed by the Illinois Governor on March 19, 2020, expands telehealth
services in response to COVID-19. The relaxed telehealth requirements were outlined in the
Illinois Register. 4 The expanded guidance allows the distant site provider to be any enrolled
provider operating within its scope of practice with the appropriate license or certification.
Telehealth services are delivered to a patient that is located at an originating site. Any site that
allows for the patient to use a communication or technology system may be an originating site,
including a patient’s place of residence located within or temporarily outside Illinois. However,
for a provider to be eligible for the originating site fee, it must be a certified eligible facility or
provider organization that acts as the location of the patient at the time a telehealth service is
rendered.
Telehealth Reimbursement in Illinois
To be eligible for reimbursement, the telehealth service must be delivered using an “interactive
telecommunication system” or “telecommunication system,” or other type of communication
system where information exchanged between the provider and the patient during the service
would be sufficient to meet the requirements of the same service when rendered via face-to-
2
Social Security Act §1903(a).
3
In this report, we use the terms telemedicine and telehealth interchangeably.
4
Illinois Register (volume 44, issue 14, dated April 3, 2020).
Illinois Generally Complied With Requirements for Claiming Medicaid Reimbursement for Telehealth Payments
During COVID-19 (A-05-21-00035) 2
face interaction. Reimbursement for telehealth services will be made at the same rate paid for
face-to-face services. The distant site provider and originating site provider eligible for a facility
fee must maintain adequate documentation of the telehealth services provided.
The Medicaid statute does not recognize telehealth as a distinct service, and States have
significant flexibility to establish telehealth payment methodologies and requirements. In
Illinois, to bill for telehealth, providers must be licensed to practice medicine in Illinois or the
State where the participant is located.
The amount paid to the health professional delivering the medical service is the current fee
schedule amount for the service provided. Distant site providers submit claims for telehealth
services using the appropriate code for the professional service along with the telehealth
modifier “GT.” The originating site provider is eligible to receive only a facility fee for telehealth
services, billed using Healthcare Common Procedure Coding System (HCPCS) code Q3014.
Documentation in the medical records must be maintained at both the distant and originating
sites to substantiate the service provided.
HOW WE CONDUCTED THIS AUDIT
Our audit covered 584,492 Medicaid fee-for-service telehealth payments, totaling $21,052,452
($13,980,157 Federal share), that the State agency included on its FFP Reports with dates of
March 1, 2020, through March 1, 2021 (audit period). We analyzed the payments looking for
trends in the number of services per person, per day, and by provider. We categorized any
unusual or duplicative billing issues that we noted. We made a list of all procedure codes paid
as telehealth and researched their descriptions to determine whether those services could be
performed via a telecommunication system. We identified 1,502 payments that appeared to
be duplicative billing (matching procedure codes, provider, recipient, date of service). We
performed additional testing on the matching payments with different modifiers, to determine
whether the modifier indicated separate services. We contacted 5 providers and obtained
supporting documentation for 230 of these payments. All 230 selected payments appeared to
be for distinguishable services.
We conducted this performance audit in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.
Appendix A contains the details of our audit scope and methodology. Appendix B contains the
Federal requirements.
FINDINGS
The State agency generally made telehealth payments that were in accordance with Federal
and State requirements. However, the State could establish a list of acceptable telehealth
Illinois Generally Complied With Requirements for Claiming Medicaid Reimbursement for Telehealth Payments
During COVID-19 (A-05-21-00035) 3
procedure codes and enhance the monitoring of provider compliance by conducting periodic
reviews of telehealth payments. Of the 584,492 Medicaid fee-for-service telehealth payments
in our audit period, 583,960 payments were allowable, but the remaining 532 payments were
not in compliance with applicable requirements. For 249 payments, the same provider was
paid both the originating site fee and distant site fee. There were 146 payments made as
duplicate payments for the same services provided to the same recipient on the same day.
Also, 22 payments were inaccurately billed as both originating and distant site fees. Finally,
providers incorrectly used the telehealth modifier with 35 different procedure codes that are
for in-person services. A total of 115 telehealth payments were identified with these codes that
could not be performed via telecommunication systems. This noncompliance occurred because
the State agency did not give adequately monitor compliance. The State agency also did not
establish a list of acceptable telehealth procedure codes. Based on our testing, we calculate
the unallowable payments totaled approximately $16,154 ($9,832 Federal share) during our
audit period.
FEDERAL AND STATE REQUIREMENTS
Per Federal requirements, FFP is generally available for expenditures under the State plan. 5
Claims for Federal Medicaid reimbursement must be supported by adequate documentation to
ensure that all applicable Federal requirements have been met. 6 Additionally, costs must be
adequately documented to be allowable under Federal awards. 7
Per Illinois requirements, 8 telehealth services are performed via a telecommunication system to
provide medical services for the purpose of evaluation and treatment when the patient is at
one medical provider location and the rendering provider is at another location. The originating
site is the site where the participant receiving the service is located. Originating site providers
may receive reimbursement for a facility fee for each telehealth service encounter. To receive
reimbursement for the facility fee, originating site providers must bill HCPCS code Q3014
(originating site fee). Conversely, the distant site is the site where the provider rendering the
telehealth service is located. Providers rendering telehealth and telepsychiatry services at the
distant site shall be reimbursed the State agency’s rate for the Current Procedural Terminology
(CPT) code for the service rendered. The appropriate CPT code must be billed with modifier GT
(via interactive audio/video telecommunication systems).
5
42 CFR § 440.2(b).
6
CMS State Medicaid Manual § 2497.1.
7
45 CFR § 75.403(g).
8
89 Illinois Administrative Code 140.403(a).
Illinois Generally Complied With Requirements for Claiming Medicaid Reimbursement for Telehealth Payments
During COVID-19 (A-05-21-00035) 4
THE STATE AGENCY MADE TELEHEALTH PAYMENTS
NOT IN COMPLIANCE WITH REQUIREMENTS
Of the 584,492 Medicaid fee-for-service telehealth payments totaling $21,052,452
($13,980,157 Federal share) in our audit period, the State agency made 583,960 payments
totaling $21,036,298 ($13,970,325 Federal share) in compliance with Federal and State
requirements. However, the remaining 532 payments were not made in accordance with
Federal and State requirements.
The State Agency Made 249 Payments That Did Not Comply With
Telehealth Location Requirements
Of the 584,492 Medicaid fee-for-service telehealth payments reviewed, 249 payments totaling
$11,311 ($6,994 Federal share) did not appear to comply with telehealth location
requirements. For these payments, the State agency paid the same provider for both an
originating site fee and the corresponding distant site service for the same recipient. Payments
made for an originating site fee and distant site service on the same day, for the same recipient,
should have different provider numbers to distinguish the different locations. We are unable to
determine which, if any, of the payments are correct without confirmation from the recipient
and medical records from all providers involved.
State officials agreed 139 payments appeared to be billing errors. The other 110 payments
were for Medicare crossover claims billed by a community mental health center. The State
believed the claims were originally reported correctly, but after they crossed through the
Medicare system to the Medicaid system, the distant site provider was paid for both the distant
and originating site fees. The State could not provide any documentation to support their
position.
Providers Were Paid for 146 Services Two Times
From the population of payments, an additional 146 services were paid two times. These
duplicate payments show matching provider, beneficiary, procedure code, and date of service.
Most of the procedure codes billed were for an “initial 30-minute” individual visit or group
intervention. The duplicate services were not always paid the same amount as the first time it
was processed. Since we do not know which payment amount is correct, we determined all
292 payments to be in error and included the $4,361 ($2,522 Federal share) in the
overpayment section of this report. State officials agreed the providers billed twice in error.
Providers Incorrectly Billed 22 Claims as Both an Originating and Distant Site Service
Another 22 payments totaling $482 ($316 Federal share) were for claims inaccurately coded as
both an originating site and distant site. The providers used the HCPCS code for originating site
fee but listed the claims as “distant site” and included the GT modifier to indicate distant site.
Illinois Generally Complied With Requirements for Claiming Medicaid Reimbursement for Telehealth Payments
During COVID-19 (A-05-21-00035) 5
The providers were paid the originating site fees. State officials could not confirm the nature of
these claims and attributed the issue to provider billing errors.
Providers Incorrectly Added the Telehealth Modifier
When we sorted the population of payments by procedure code, we found 189 unique
procedure codes labeled with the GT modifier to indicate a telehealth service was provided. Of
the 189 codes, 35 are for services that cannot feasibly be performed via a telecommunication
system. Some of these procedure codes indicate injections, vaccines, or ultrasounds as the
service performed. Providers submitted and the State agency processed 115 payments with
these 35 procedure codes and the incorrect telehealth modifier. The distant site providers are
reimbursed the same rate for services performed as telehealth, so an overpayment did not
occur. Miscoding the 115 payments caused the number of telehealth services performed in
Illinois to be overinflated. State officials mentioned they did not have any list of acceptable
telehealth procedure codes.
THE STATE AGENCY COULD IMPROVE CONTROLS AND MONITORING OVER
TELEHEALTH BILLING
The COVID-19 pandemic and the rapid expansion of telehealth may have posed challenges for
the State agency and its providers. While the State generally complied with the broadened
telehealth billing requirements, it did not adequately monitor provider compliance by
performing periodic reviews of the claims. In addition, the State agency did not establish a list
of acceptable telehealth procedure codes. This resulted in payments for services that could not
be provided in a telehealth setting, as well as other telehealth billing errors.
RECOMMENDATIONS
We recommend that the State agency:
• refund up to $9,832 to the Federal Government,
• enhance the monitoring of provider compliance by conducting periodic reviews of
telehealth payments for compliance with requirements, and
• establish a list of acceptable telehealth procedure codes.
Illinois Generally Complied With Requirements for Claiming Medicaid Reimbursement for Telehealth Payments
During COVID-19 (A-05-21-00035) 6
STATE AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL RESPONSE
In written comments on our draft report, Illinois concurred with our recommendations and
described the actions that it has taken or plans to take to address them. The actions Illinois
described include: (1) reimbursing the Federal Government $9,832, (2) continuing to develop a
quality assurance program to review samples of claims, and (3) implementing edits to prohibit
inappropriate procedure codes from being billable. Illinois’ comments are included in their
entirety as Appendix C.
We recognize the corrective actions Illinois has implemented or plans to implement to address
our recommendations. These corrective actions should provide improved compliance with
telehealth billing requirements.
Illinois Generally Complied With Requirements for Claiming Medicaid Reimbursement for Telehealth Payments
During COVID-19 (A-05-21-00035) 7
APPENDIX A: AUDIT SCOPE AND METHODOLOGY
SCOPE
Our audit covered 584,492 Medicaid fee-for-service telehealth payments, totaling $21,052,452
($13,980,157 Federal share), that providers billed and were reimbursed for on the FFP Reports
from March 1, 2020, through March 31, 2021.
We performed our audit fieldwork at the State agency office in Springfield, Illinois, from
August 2021 through November 2022. We did not assess the State agency’s overall internal
control structure. Rather, we limited our audit of internal controls to those applicable to our
audit objective.
METHODOLOGY
To accomplish our objective, we:
• reviewed applicable Federal laws, regulations, and guidance;
• reviewed State laws, regulations, and guidance, including the Illinois Register and Illinois
Administrative Code;
• interviewed State officials and providers to gain an understanding of telehealth in
Illinois;
• analyzed all 584,492 Medicaid fee-for-service payments to discover unusual or
duplicative billing;
• researched the 189 procedure codes paid as telehealth services;
• identified 1,502 payments that appeared to be duplicative billing (same provider,
recipient, procedure code, date of service);
• selected 230 of the 1,502 payments for further testing to ensure modifiers indicated
separate services;
• contacted 5 providers to request supporting documentation for the 230 payments and
reviewed the medical records to ensure they were separate services; and
• discussed our findings with State officials.
We conducted this performance audit in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
Illinois Generally Complied With Requirements for Claiming Medicaid Reimbursement for Telehealth Payments
During COVID-19 (A-05-21-00035) 8
based on our audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.
Illinois Generally Complied With Requirements for Claiming Medicaid Reimbursement for Telehealth Payments
During COVID-19 (A-05-21-00035) 9
APPENDIX B: FEDERAL REQUIREMENTS
FEDERAL REQUIREMENTS
Section 1903(a) of the Act states:
From the sums appropriated therefor, the Secretary (except as otherwise
provided in this section) shall pay to each State which has a plan approved under
this title, for each quarter, beginning with the quarter commencing January 1,
1966—(1) an amount equal to the Federal medical assistance percentage (as
defined in section 1905(b), subject to subsections (g) and (j) of this section and
subsection 1923(f)) of the total amount expended during such quarter as
medical assistance under the State plan.
42 CFR § 440.2(b) states: “Definitions of services for FFP purposes. Except as limited in part
441, FFP is available in expenditures under the State plan for medical or remedial care and
services as defined in this subpart.”
45 CFR § 75.403 states: “Except where otherwise authorized by statute, costs must meet the
following general criteria in order to be allowable under Federal awards . . . (g) Be adequately
documented.”
CMS’s State Medicaid Manual § 2497.1 states: “Federal financial participation (FFP) is available
only for allowable actual expenditures made on behalf of eligible recipients for covered services
rendered by certified providers. Expenditures are allowable only to the extent that, when a
claim is filed, you have adequate supporting documentation in readily reviewable form to
assure that all applicable Federal requirements have been met.”
Illinois Generally Complied With Requirements for Claiming Medicaid Reimbursement for Telehealth Payments
During COVID-19 (A-05-21-00035) 10
APPENDIX C: STATE AGENCY COMMENTS
A HFS
t~ ~t Illinois Deportment of JB Pritzker, Governor
4lol' Healthca re and Family Services Theresa Eagleson, Director
·201 South Grand Avenue East Telephone: (217) 782-1200
Springfield, Illinois 62763-0002 TTY: (800) 526-5812
December 13, 2022
Department of Health and Human Services
Office of Audit Services, Region V
Attn: Sheri L. Fulcher, Regional Inspector General for Audit Services
223 North Michigan Avenue, Suite 1360
Chicago, IL 6060 I
Re: Draft Audit Report A-05-21 -00035
Dear Ms. Fulcher:
Thank you for providing the opportunity to comment on your draft audit report entitled "Illinois Generally
Complied with Requirements for Claiming Medicaid Reimbursement for Telehealth Payments During COVID-
19".
The Department concurs with the three recommendations noted in the draft audit report. Regarding
recommendations one, the Department agrees to reimburse the Federal Government $9,832.
Regarding recommendation two, and in response to a previous telehealth audit, the Department is in the
process of developing a quality assurance program to review a focused sample of telehealth claims to
determine the accuracy of the claim submissions. We met with our Office oflnspector General last week
regarding sample size and selection criteria.
Regarding finding three, the Department is reviewing the procedures codes that were billed to the
Department during the Public Health Emergency, for their appropriateness. The Department will
implement editing to prohibit inappropriate procedure codes from being billable.
We appreciate the work completed by your audit team and the open lines of communication with HFS staff
throughout this audit. If you have any questions or comments about our response to the audit, please contact
Amy Lyons, External Audit Liaison, and (217) 558-4347 or through email at amy.lyons@illinois. gQy.
Sincerely,
~r
Director
E•mall: bts.webmaster@illinois.gov Internet: http://www.hfs.illinois.gov/
Illinois Generally Complied With Requirements for Claiming Medicaid Reimbursement for Telehealth Payments
During COVID-19 (A-05-21-00035) 11
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