Telehealth Enforcement Actions

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“It behooves all healthcare compliance professionals to be aware of the fraud, waste and abuse risks associated with telehealth services. This mode of delivery holds great promise. For it to fulfill that promise, non-compliance needs to be rooted out and corrected.”

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Uncovering $9 Million in Unbilled Services   

maeve o'neill unbilled services

“My success in uncovering millions of dollars in unbilled services demonstrates how revenue protection is a tangible way Compliance delivers value to healthcare organizations. It also underscores how compliance professionals make an impact across the business through building relationships, shaping culture, preventing fines, and positioning Compliance as true partner.” – Maeve O’Neill

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Telehealth expansion: Interstate licensure compacts benefit patients 

YouCompli Woman reviewing interstate licensure compacts for telehealth

Telehealth services and models have expanded rapidly during the pandemic. Healthcare employee burnout, the Great Resignation, and other factors are expected to further accelerate telehealth growth.  

Telehealth expansion has led to significant growth in the use of interstate licensure compacts. As more healthcare professionals obtain licensure under compacts, compliance officers need to be aware of interstate licensure requirements – and their effects on patient care. 

Increasing use of interstate licensure compacts 

The National Council of State Boards of Nursing (NCSBN) recently published its annual report on interstate licensure. It noted 43 states and territories have enacted licensure compacts for nurses, physicians, physical therapists, emergency medical technicians, psychologists, speech therapists/audiologists, occupational therapists, and counselors. 

The Nurse Licensure Compact (NLC) is an interstate agreement allowing nurses to practice in multiple states with one multistate license issued from their home state. The compact enables nurses to provide nursing services to patients located in other NLC states via telehealth without obtaining additional licenses. The NCSBN says this approach allows for greater nurse mobility, public protection, and access to care.  

In addition, use of the Interstate Medical Licensure Compact (IMLC) grew by 47% in the past two years. The IMLC Commission noted “more than 8,000 licenses were issued through the compact from March 2020 to March 2021.” This is compared with nearly 4,000 licenses issued during the previous 12-month period.  

With more healthcare professionals practicing across state lines, patients have more choices. And healthcare compliance officers have processes and procedures to update.  

Interstate licensure compacts benefit patients 

For patients, one benefit of licensure compacts includes licensing boards being able to ensure that physicians maintain professional integrity and medical standards – regardless of where they practice. As more healthcare professionals obtain licensure under compacts, patients gain greater flexibility in making care decisions.  

For example, rural patients can participate in a telehealth visit with a specialist or provider at home. This saves patients the time and expense of driving long distances to see the same provider in a facility setting.   

Another positive is the increased use of remote monitoring devices, such as glucose monitors, blood pressure monitors, and heart monitors. Patients can receive state-of-the-art monitoring remotely, instead of as a hospital inpatient. In turn, healthcare costs decrease and patient compliance increases.  

A significant patient benefit with expanded telehealth is the inclusion of mental health services. Under the provisions of the Consolidated Appropriations Act of 2021, services for the diagnosis, evaluation, or treatment of mental health disorders may continue as telehealth services. Per the Centers for Medicaid & Medicare Services (CMS), the previous restrictions limiting telehealth mental health services to patients residing in rural areas no longer apply.  

Compliance considerations 

Compliance officers need to help their organizations keep up as healthcare delivery models change. Organizations will need to update everything from billing codes to human resources policies and procedures to information technology (IT) practices.  

For example, compliance officers should partner with Human Resources to make sure out-of-state licensed professionals have been educated in facility policies and procedures. They also need to ensure that professionals working under licensure compacts understand the nuances of the rules and laws in the state they are working. 

Compliance officers also need to work with the IT department to ensure that remote devices have been securely connected to the network. They also need to collaborate with the risk department on making sure proper medical professional liability insurance coverage has been obtained for these licensed professionals.  

Compliance officers should work with Revenue Cycle on two crucial issues:  

  • Ensuring that the organization stays abreast of the changes to the CMS list of services payable under the Medicare Physician Fee Schedule when furnished via telehealth. 
  • Staying current on telehealth visit coverages and coding modifiers to decrease denials of patient charges.  

As your team manages your response to continuing regulatory changes, having a system to keep up with the moving parts can help. YouCompli can support your regulatory change management process. It provides regulatory analysis to help you know what changes are coming and decide whether they affect your institution. It also provides requirements, tasks, and deadlines, in clear business English, making it easier for you to manage changes and verify that you’ve taken the proper steps. 

Denise Atwood, RN, JD, CPHRM 
District Medical Group (DMG), Inc., Chief Risk Officer and Denise Atwood, PLLC 

Disclaimer: The opinions expressed in this article or blog are the author’s and do not represent the opinions of DMG.  


Denise Atwood, RN, JD, CPHRM has over 30 years of healthcare experience in compliance, risk management, quality, and clinical areas. She is also a published author and educator on risk, compliance, medical-legal and ethics issues. She is currently the Chief Risk Officer and Associate General Counsel at a nonprofit, multispecialty provider group in Phoenix, Arizona and Vice President of the company’s self-insurance captive.  


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Decide: YouCompli helps your organization make easy regulatory decisions

Before YouCompli, Compliance Officer Scott Borsuk said he “probably spent six to eight hours a week reading regulations, then copying and pasting them” to share with colleagues. Read the Western Maryland Health System case study.

“It’s not enjoyable reading,” Borsuk noted.

But he had to read closely to be sure he properly analyzed the regulation to see if it applied to him.

Simplify decision-making

“We were not confident that we were catching everything, we had the documents but didn’t know if we missed anything. At the end of the day, we didn’t know if we were making the right changes or not.” – Scott Borsuk, Chief Compliance Officer

Borsuk knew he needed a better system and a stronger approach to managing regulatory change. That’s where YouCompli came in. With YouCompli, Borsuk can easily decide if a regulation applies to his hospital system and how to comply.

YouCompli makes it easy for you to decide which regulatory changes apply to your organization and which tasks need to be performed in order to comply.


In this clip Scott Borsuk explains what regulatory change management is, and how YouCompli assisted his hospital system in achieving desired results.

Watch more videos on this topic here and see how YouCompli can help your organization


Regulatory analysis to help you decide

  • For each requirement associated with a regulation, YouCompli creates a few relevance questions. Users may be asked, for instance, “Is your organization a Medicare provider?” These relevance questions are followed by tips generated by YouCompli to help make your decisions easier.
  • We can do this because our analysts read entire regulations, flag relevant changes, and translate technical legal documents into easy-to-understand business requirements.
  • If you decide the regulation is not relevant, YouCompli marks it “complete” and removes it from your active tasks.
  • All our analysis is checked by Horty Springer, the nation’s leading health care law firm.
YouCompli’s simple interface makes it easy to decide if a regulation is relevant to your organization.

Get expertise from colleagues

Sometimes the relevance questions stretch beyond your expertise as a Compliance leader. In those cases, use YouCompli to get the answer from colleague with the right expertise.

  • Use the workflow tool to assign a complex relevance question to a subject matter expert
  • YouCompli allows you to maintain a directory of subject matter experts who provide compliance leadership within their departments
  • The workflow tool also tracks responses and lets your colleague decline or answer the question right in the tool.

A complete audit trail for your relevance decisions

YouCompli tracks all of your relevance decisions over time, so you can see which regulations and changes applied to your organization and why (or why not!)

  • All responses to decision criteria, including usernames and date stamps, are recorded in YouCompli to become part of the official record and the compliance audit trail
  • The log also captures the reasons for rejecting the requirement or proceeding to the next phase of the workflow.
  • YouCompli clients can access the complete audit trail at any time to review previous decisions and the reason for making that decision.

Great decisions help you manage regulatory changes

Once you know about a regulatory change and you’ve used YouCompli’s decision criteria to decide that a regulation applies to you, you’re ready to respond. YouCompli helps you manage the tasks necessary for compliance. And it helps you verify that your organization has put forth best efforts to stay in compliance.

Interested in how a healthcare system used YouCompli to decide which regulatory changes apply? Check out this case study from the Western Maryland Health System.