Key Takeaways From the GAO Report on Telehealth Utilization and Quality in Medicaid

Original article written by Jacqueline D. Marks and Jared Augenstein for Manatt Health.


The U.S. Government Accountability Office (GAO), as directed by a provision in the CARES Act, published a report that examined the use of telehealth among Medicaid beneficiaries before and during the COVID-19 pandemic across six states: Arizona, California, Maine, Mississippi, Missouri, Tennessee.1 The report explored the states’ experiences with telehealth during the pandemic, future plans for post-public health emergency (post-PHE) telehealth coverage, and efforts by states and the Centers for Medicare & Medicaid Services (CMS) to oversee program integrity risks and monitor telehealth quality. Below are their key findings and takeaways.


Finding 1: Telehealth policy flexibilities implemented during the pandemic enabled exponential growth of telehealth use, though there were significant differences across states in the level of telehealth utilization.


Finding 2: The expansion of telehealth coverage and payment policies improved access to care, and states are now applying lessons learned during the pandemic to the development of post-PHE policies.


Finding 3: CMS and states are starting to conduct fraud risk assessment activities related to telehealth.


Finding 4: There is currently no uniform approach to assessing quality of care delivered via telehealth, and CMS does not have plans to collect telehealth-specific quality data or report on the impact of telehealth on quality of care.


Based on these findings, GAO is making two recommendations to CMS:

  1. Collect and analyze information about the effect delivering services via telehealth has on the quality of care Medicaid beneficiaries receive.

  2. Determine any next steps based on the results of the report.

This GAO report shines a light on current gaps in federal and state telehealth quality-monitoring activities. In response to this report, the state should continue to develop infrastructure and processes to enable data collection and reporting related to quality of care delivered via telehealth. In addition, states should enhance data collection related to beneficiary demographics to enable more accurate analysis of the impact of telehealth on health equity and digital inclusion. Finally, states should review existing program integrity activities related to fraud, waste and abuse for all services (in-person and telehealth) and consider adapting existing procedures or adopting new ones that enable better oversight of Medicaid telehealth utilization and quality.


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