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Is the GAO Holding CMS Accountable for Medicaid Telehealth Expansion?

By Terry A. Fletcher BS, CPC, CCC, CEMC, CCS, CCS-P, CMC, CMSCS, ACS-CA, SCP-CA, QMGC, QMCRC, QMPM
May 16, 2022

The GAO performs a study on telehealth.

The U.S. Government Accountability Office (GAO) provides Congress, the heads of executive agencies, and the public with timely, fact-based, nonpartisan information that can be used to improve government and save taxpayers billions of dollars.

For example, the GAO recently determined that from March 2020 to February 2021, a total of 32.5 million services were delivered via telehealth – versus 2.1 million services the prior year. But Medicaid hasn’t collected or assessed data on the quality of care that beneficiaries received via telehealth services.

Per the GAO, Medicaid officials from all six selected states – including Arizona, California, Maine, Mississippi, Missouri, and Tennessee – said expanding telehealth supported beneficiaries’ access to care, but also identified some limitations. Officials reported making or considering post-pandemic telehealth modifications.

What was interesting from this GAO study was that they reported that the Centers for Medicare & Medicaid Services (CMS) “does not collect, assess, or report information about any effect delivering services via telehealth has on the ‘quality of care’ Medicaid beneficiaries receive, and has no plans to do so.” Why is that? From someone who is a proponent of telehealth, as long as it shows that it’s more than a convenient way to deliver healthcare, but also a medically necessary and efficient way to take care of patients (and not just another waste of government spending), its use should be encouraged. This should have been a top priority for CMS.

The GAO further stated that collecting this data is important, given concerns GAO has raised about the quality of care provided via telehealth. It would also be consistent with how CMS has encouraged states to use data on quality of care to identify disparities in healthcare and target opportunities for improvement to advance health equity.

Why did the GAO perform this study?

The Coronavirus Aid, Relief, and Economic Security (CARES) Act includes a provision for the GAO to report on the federal response to the pandemic. In addition, the GAO was asked to examine the use of Medicaid flexibilities in response to COVID-19. This report describes selected states’ telehealth use before and during the pandemic, as well as their experiences with and plans for telehealth. It also evaluates, among other things, CMS’s telehealth oversight of quality of services.

You have to ask the question: “How can you expand telehealth in the Medicaid program if you don’t have all of the data to show it is safe, effective, and accessible – and the quality of care is comparable to an in-person patient visit?” You can’t.

So, the GAO is making two recommendations to CMS: to collect and analyze information about the effect delivering services via telehealth has on the quality of care Medicaid beneficiaries receive, and to determine any next steps based on the results of the analysis.

Does CMS have to follow their recommendations?

Agency Affected	Recommendation	Status
Centers for Medicare & Medicaid Services	The Administrator of CMS should collect and analyze the information needed to assess the effect delivering services via telehealth has on the quality of care Medicaid beneficiaries receive. (Recommendation 1)	Open When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Centers for Medicare & Medicaid Services	The Administrator of CMS should determine, based on the results of its initial assessment, whether further assessments of the effect delivering services via telehealth has on the quality of care Medicaid beneficiaries receive are warranted, for the purposes of developing guidance to assist states in making telehealth coverage and payment decisions. (Recommendation 2)	Open When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.