OIG greenlights telemedicine plan in latest advisory opinion

by: Julia Kyles, CPC Jun 1, 2018

The HHS Office of Inspector General (OIG) gave the go-ahead to a health center’s plan to provide telemedicine equipment to a county health clinic in Advisory Opinion 18-03. As always, the advisory opinion applies to the specific details of the request. However, a look at the details provides insight into what the agency does (and does not) like.

The federally qualified health center look-alike — essentially, a health center that operates like a federally qualified health center but does not receive funding from the Health Center Program — would provide the equipment, along with training, maintenance and technical assistance to the clinic free of charge.

Use of the telemedicine equipment would be limited to telemedicine encounters for HIV prevention. Specifically, “consultations regarding the prescription of medications for pre-exposure prophylaxis (‘PrEP’) and post-exposure prophylaxis (‘PEP’),” the OIG wrote in the advisory opinion published June 1.

According to the look-alike, the county clinic isn’t able to provide PrEP and PEP consultations to its patient populations.

The OIG found that the arrangement could potentially violate the Anti-Kickback statute, but said the two providers could proceed with the plan and gave four reasons:

The plan contains safeguards designed to prevent inappropriate patient steering.
The look-alike and the clinic will not recommend that patients use a specific pharmacy, which will prevent steering patients to the look-alike’s pharmacy. The requestors also noted that the clinic is an 80-mile drive from the health center, and the OIG observed that it was “unlikely that a patient would choose to use the [health center’s] pharmacy."
The plan is unlikely to inappropriately increase costs to federal health care programs. Furthermore, increasing access to HIV-prevention services “could reduce the prevalence of HIV and promote public health,” the OIG said.
Expanding on the topic of patient health, the OIG noted that the primary beneficiaries of the plan would be patients who received telemedicine services at the clinic. Access to the services is “especially important in PEP administration, where medication must be taken within 72 hours after exposure to HIV,” the OIG said.

Blog Tags: OIG

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