Massachusetts
Office of the State Auditor (Massachusetts)
Published November 23, 2022

MassHealth Telehealth Review

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Overall Conclusion

MassHealth did not monitor telehealth practices to ensure compliance with its All Provider Bulletins for telehealth encounters, leading to at least $91,852,881 in potentially improper payments.

Source Document

Audit Scope

The audit covers MassHealth's payments for telehealth behavioral health services during January 1, 2020 through June 30, 2021. It examines whether MassHealth monitored telehealth practices to ensure compliance with All Provider Bulletins 281, 289, 291, 298, 303, and 314, including documentation requirements for telehealth encounters (e.g., patient identification, provider identity/credentials, medical history review, consent and privacy, distant and originating sites, and emergency planning). The audit used a random statistical sample of 47 telehealth behavioral health claims from a population of 1,306,414 claims totaling $96,464,816 for the audit period, with 90% confidence, to extrapolate results. It found at least $91,852,881 in overpayments and up to $96,464,816 total population paid for telehealth behavioral health services not properly documented. The audit also analyzed data reliability through prior OSA work on MMIS controls and referenced MassHealth policy changes, including All Provider Bulletins 281, 289, 291, 298, 303, 314, and 355. The period includes context around the COVID-19 emergency and related telehealth expansions.

Key Findings Summary

1

MassHealth made payments totaling at least $91,852,881 to its providers for telehealth behavioral health services that were not properly documented.

AI-Assisted

Generated by gpt-5-nano

AI Scope Summary

Assess MassHealth's monitoring and controls over telehealth behavioral health claims to ensure adherence to the telehealth encounter documentation requirements outlined in All Provider Bulletins 281, 289, 291, 298, 303, and 314 during the 2020-2021 audit period.

AI-Generated Insight

The audit highlights significant gaps in documentation and monitoring during the rapid expansion of telehealth for behavioral health services during the COVID-19 period. It underscores the need for robust internal controls, provider training, and timely policy updates to protect MassHealth’s integrity while preserving access to telehealth for members.