In previous Med Law Blog posts, we have featured examples of increased enforcement in the telehealth area, including the recent creation of the National Rapid Response Strike Force, announced by the Department of Justice on September 30, 2020, and OIG Takedowns in the DME and telehealth arenas.

Now, the OIG work plan includes at least 7 audits targeted at telehealth, identified in the attached PDF.

Commentators are expecting increased activity with respect to:

  1. Improper coding for telehealth services,
  2. Improper or inappropriate use of telehealth technology, especially when combined with state telehealth laws defining the parameters of the delivery of telehealth services,
  3. Evaluation of the appropriate state or billing requirements for the establishment of medically appropriate doctor patient relationships,
  4. Increasing cybersecurity activity with respect to HIPAA and data privacy laws, and
  5. Audit of appropriate uses of COVID-19 relief funds from multiple programs, i.e. provider relief and paycheck protection, which incidentally was also mentioned in the April 21, 2021 post “Medical Practices Face Liability for COVID Accelerated and Advance Payments and PPP Loans” at the following link: