Lexology July 26, 2022
Telemedicine companies, beware: on July 20, 2022, the United States Department of Health and Human Services, Office of Inspector General (OIG) issued a new Special Fraud Alert targeting arrangements between practitioners and purported telemedicine companies, signaling a heightened focus by the government on fraud in the telemedicine industry.
While OIG drafted the alert broadly to apply to telehealth, telemedicine, and telemarketing services (collectively referred to in the Alert as Telemedicine Companies), the agency highlighted arrangements whereby practitioners order or prescribe a federally reimbursable item and/or service for patients they never examine or meaningfully assesses to determine whether such item is or service is medically necessary. OIG remarked that these arrangements commonly involve Telemedicine Companies paying practitioners on a per-click basis...