Overview of the OIG Audit
Federal auditors have raised serious concerns about Medicare payment accuracy. The Department of Health and Human Services’ Office of Inspector General released an April 2026 audit finding that the Centers for Medicare and Medicaid Services may have made more than $2.26 million in improper payments. These payments covered virtual check-in and e-visit services delivered to Medicare enrollees.
The audit examined Medicare claims from January 1, 2019, through December 31, 2022. During that four-year window, CMS paid $12.48 million for virtual check-in services and $11.67 million for e-visits. Together, these payments totaled nearly $24.15 million — making audit-level scrutiny both warranted and timely.
The OIG designed this review specifically to expose vulnerabilities in CMS oversight of technology-based care. Furthermore, the findings highlight gaps in how providers understand and apply billing rules for remote services.
What Are Virtual Check-In Services?
Defining the Service Type
Virtual check-ins are brief, technology-based communication services. Physicians use them to assess whether a patient needs an in-person visit. Medicare covers these services under specific conditions, but strict billing rules apply.
Key Billing Restrictions
A virtual check-in must not connect to an evaluation and management (E/M) service within the previous seven days. Additionally, it must not precede an E/M service or procedure within the following 24 hours. When providers bill outside these boundaries, Medicare may pay for services it should not cover. These rules exist to prevent duplicative billing for what amounts to a single episode of care.
Improper Payments for Virtual Check-In Services
The $1.96 Million Concern
OIG found that CMS may have made $1,964,125 in improper payments for 173,287 virtual check-in services. Each of these services occurred within a restricted timeframe. Moreover, auditors noted the same diagnosis code appeared for the same enrollee — a strong indicator of overlapping care.
The Unnecessary Modifier Problem
Among those flagged claims, 120,316 E/M services also carried an unnecessary billing modifier. Modifiers signal special circumstances to Medicare billing systems. When providers apply them incorrectly, the system may approve payments it otherwise would reject. This pattern suggests a systemic gap in provider education and billing system controls alike.
Improper Payments for E-Visit Services
The $298,200 Finding
E-visits involve online digital evaluation through a patient portal or similar platform. CMS may have made $298,200 in improper payments for 10,237 e-visit services. Consequently, these services took place within one week of a prior e-visit for the same enrollee, sharing the same diagnosis code.
Cumulative Time Billing Rules
Medicare requires that providers bill cumulative communication time when multiple e-visits occur within the same week for the same condition. Instead, some providers billed each interaction separately. As a result, Medicare paid more than necessary for what should have counted as a single, aggregated service episode.
OIG Recommendations to CMS
Installing System-Level Edits
OIG recommended that CMS install automated system edits for billing communication technology-based services. These edits would serve as a safeguard, automatically flagging claims that fall outside accepted billing windows before payment processes. Proactively, this change alone could have saved Medicare up to $2.3 million during the four-year audit period.
Updating HCPCS Code Descriptions
OIG also advised CMS to strengthen Healthcare Common Procedure Coding System (HCPCS) code descriptions for virtual check-in services within the physician fee schedule. Clearer code language would reduce ambiguity for providers who bill these services. Specifically, more precise descriptions help prevent unintentional billing errors that accumulate into significant program losses.
Improving Provider Education
Finally, OIG urged CMS to better communicate billing requirements to providers. Many improper payments appear linked to provider confusion rather than intentional fraud. Therefore, targeted education campaigns, updated billing guides, and improved coding resources could significantly reduce future vulnerabilities in this growing service category.
What This Means for Medicare Providers
The OIG audit signals a clear shift in how federal regulators plan to treat virtual care billing. Telehealth and remote services expanded rapidly during and after the COVID-19 public health emergency. However, increased utilization has brought increased scrutiny alongside it.
Providers who bill for virtual check-ins and e-visits must review their current coding practices. They should confirm that claims align with the defined service windows and avoid modifier misuse. Billing teams also need to apply cumulative time rules accurately for same-week e-visit encounters.
Importantly, this audit covers a historical window — 2019 through 2022 — but its recommendations shape CMS policy going forward. Providers can expect tighter automated controls and more frequent audits as CMS acts on the OIG’s guidance. Staying ahead of these changes protects practices from recoupment risk and supports the integrity of the Medicare program.
