Texas
Texas Health and Human Services Office of Inspector General Audit and Inspections Division
Published November 21, 2024

Summary of Results: Psychiatric and Behavioral Health Teleservices in Texas Medicaid and CHIP

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Overall Conclusion

While all five providers complied with some of the requirements tested, each had at least one finding of noncompliance.

Source Document

Audit Scope

Texas Medicaid and CHIP teleservices claims paid to five providers during the period: Providers A and B (June 1, 2020–May 31, 2021) for evaluation and management with add-on psychotherapy; Providers C and D (June 1, 2021–December 31, 2021) for evaluation and management, psychiatry, and psychotherapy; Provider E (September 1, 2020–August 31, 2022) for Texas Medicaid teleservices.

Key Findings Summary

1

Billing incorrect CPT or HCPCS codes.

2

Billed services delivered by providers not enrolled in Texas Medicaid.

3

Double billed for services.

View the Findings tab to see all 6 findings

AI-Assisted

Generated by gpt-5-nano

AI Scope Summary

This summary consolidates five provider audits of teleservices in Texas Medicaid and CHIP during the COVID-19 waiver period (2020–2022). It assessed billing accuracy, enrollment status, recordkeeping, privacy disclosures, and supervision, with all providers exhibiting at least one noncompliance finding and resulting overpayments and recommended corrective actions to reinforce internal controls for future audits.

AI-Generated Insight

The six high-level noncompliance themes across five Texas Medicaid telehealth audits reveal recurring weaknesses in billing practices, documentation, enrollment verification, privacy notification, and supervision. Systemic overpayments and potential misbilling were identified, underscoring the need for strengthened internal controls and ongoing monitoring.

Audit Objectives

1

To determine whether telemedicine services provided during the COVID-19 waiver period (a) were billed accurately and (b) followed applicable requirements.

2

To determine whether teleservices were billed accurately and in accordance with applicable requirements and related internal controls over teleservices were designed and operating effectively.

3

To determine whetherProvider E billed teleservices accurately and in accordance with applicable requirements and designed and implemented related internal controls over teleservices.

Audit Findings (6)

1

Billing incorrect CPT or HCPCS codes.

2

Billed services delivered by providers not enrolled in Texas Medicaid.

3

Double billed for services.

4

Billed for unallowable facility fees.

5

Did not always maintain complete records.

6

Two providers did not always notify patients about their privacy practices prior to the start of telemedicine evaluation or treatment.

Recommendations (2)

1

In addition to returning $936.02 to the state of Texas, [Provider A] should implement processes to ensure that (a) claims for services billed as time-based CPT codes are based on the actual length of services provided and (b) medical records include documentation to support the CPT codes billed.

2

[Provider A] should provide patients with written or electronic notification of its privacy practices prior to evaluation or treatment via telemedicine services.