Issue Briefs

The number of unique FEHBP members who used telehealth services rose dramatically during the pandemic. Image: Tada Images/Shutterstock.com

Following is the section focusing on the FEHB program in a report from the Pandemic Response Accountability Committee on the growth in the use of telehealth care due to the pandemic.


During the first year of the pandemic, the number of unique FEHBP members who used telehealth services increased by 2,733 percent compared to the prior year.

From March 2020 through February 2021, a total of 2.2 million unique FEHBP members from one of our larger FEHBP carriers used a telehealth service. These 2.2 million members represented 40 percent of the 5.6 million members enrolled under this carrier, or about 4 in 10 members. This is a dramatic increase from the prior year, when just 1 percent—78,900 in total—of this same FEHBP carrier’s members used telehealth services.

Telehealth claims increased by 5,335 percent during the pandemic compared to the prior year.

In total, this same FEHBP carrier’s members filed over 8 million claims for telehealth services during the pandemic period of March 2020 through February 2021. This amounts to over 54 times more telehealth service claims than the 148,035 filed in the prior year. This FEHBP carrier also paid over $646 million for telehealth services during this same period, which is a 6,259 percent increase—over 63 times more—from the year prior, when only $10,164,062 was paid for telehealth claims.

FEHBP members most commonly used telehealth for office visits and behavioral health services.

For the FEHBP carrier we analyzed, these two service types together accounted for over 91 percent of all telehealth services during the first year of the pandemic. Office visits—routine appointments with primary care providers or specialists—accounted for 58 percent of all telehealth services. In addition, behavioral health services accounted for 33 percent of all services. Behavioral health services include individual therapy, group therapy, and substance use disorder treatment, among others. This carrier’s members also utilized telehealth for physical, occupational, and speech therapies as the third most utilized health care service, although this accounted for just four percent of overall telehealth services. The data from this carrier shows that the trend of members using telehealth for all of these services continued through the end of 2021.

Data analyses provide insight into billing schemes and identify providers whose billing poses a high risk to the FEHBP.

The OPM OIG’s analyses of FEHBP telehealth services claims data shed light on a number of schemes that providers may use to inappropriately maximize their FEHBP payments for telehealth services. We developed six measures that focus on different schemes to identify providers whose billing may indicate fraud, waste, and abuse.76 See Exhibit 8 for a list of these measures.

Using these measures, we identified over 560 providers whose telehealth billing poses a high risk to the FEHBP. While these providers represent a small proportion of the approximately 265,00077 providers who billed for a telehealth service between March 2019 and December 2021, their billing raises concern. For example, some providers billed office visit telehealth services at the highest, most complex level every time. In these cases, providers may be delivering higher levels of services than medically necessary or billing for levels of services that were not rendered—a scheme that is sometimes called “upcoding.” In other cases, providers billed for telehealth services for a high number of days in a year. Billing in this manner may indicate that the provider is billing for services that were not provided.

Little is known about the impact of telehealth on quality of care in the FEHBP.

Knowing which services and which populations telehealth works best for is critical to help stakeholders make decisions about the use of telehealth services in the future. OPM has specifically recommended expansion of telehealth services to combat the opioid epidemic, mental health provider shortages, and continuity-of-care issues during the COVID-19 pandemic. However, little is known about the effects of telehealth expansion in these areas on quality of care received, patient safety, or FEHBP member outcomes. OPM’s Healthcare and Insurance (HI) does conduct a Plan Performance Assessment annually, which examines quality of care through clinical quality measures. However, this assessment does not include any telehealth-specific measures. Given the drastic increase in the usage of telehealth services since the onset of COVID-19, we believe that OPM should evaluate whether the annual Plan Performance Assessment currently includes measures that would adequately identify quality of care concerns specific to the telehealth modality.

In addition to oversight by OPM itself, FEHBP carriers should also evaluate telehealth quality of care concerns. In response to our telehealth survey, one carrier indicated that it has a quality plan, which includes performing random audits, diagnosis trending, and utilization monitoring for claims coming in through its contracted telehealth company’s portal. However, as discussed above, 97 percent of telehealth services for this carrier were not obtained through this portal. Further, most carriers we surveyed indicated only that quality of care concerns will be reviewed when identified via member grievances. The OPM OIG is not aware of any large-scale reviews specifically examining telehealth’s effects on quality of care performed by carriers, though this question was not explicitly posed in our survey.

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