U.S. Department of Health and Human Services  
Office  of  Inspector  General  
 
Data Brief  
Sept ember  2022, OEI--02--20--00522  
 
Certain Medicare Beneficiaries,  Such as  Urban  and Hispanic  
Beneficiaries,  Were More  Likely  Than Others  To Use Telehealth 
During  the First Year of the  COVID-19 Pandemic  
Why  OIG Did This Review   
Key  Takeaways  
The COVID-19 pandemic created unprecedented  challenges for how  
o  Beneficiaries in urban areas  Medicare beneficiaries  access health care.   In response, the Department  
were more likely than  of Health and Human Services (HHS)  and the Centers for Medicare &  
those in rural areas  to use  Medicaid Services  (CMS)  took a number of actions to temporarily  
telehealth.   expand access to telehealth for Medicare beneficiaries.1   CMS allowed  
beneficiaries to use telehealth for  a wide range of services  and in 
o  Dually eligible, Hispanic, 
different  locations, including in urban areas  and from the beneficiarys  
younger, and female 
beneficiaries were also  home.  
more likely than others to 
In a  companion  report, OIG found  that  the use of telehealth increased  
use telehealth. 
dramatically during the first year of the pandemic.2   More than 
o  Almost one- fifth of 28  millionabout 2 in 5Medicare beneficiaries  used telehealth that  
beneficiaries used  certain 
first year.   In total, beneficiaries used  88 times more telehealth services  
audio -only telehealth 
during the first year  of the pandemic than they did in the prior year.   
services; the vast majority 
of these beneficiaries used 
This data brief  expands  on that  analysis and examines the 
them exclusively. 
characteristics of beneficiaries who used telehealth during the  first year 
o  Older beneficiaries were of the pandemic.  This information  sheds  light on  how the temporary  
more likely to use  certain  expansion of telehealth affected  different groups of  beneficiaries.   This  
audio -only  services, as 
information  will help CMS,  HHS,  Congress, and other stakeholders  
were dually eligible  and 
understand  who benefited from the expansion and make decisions  
Hispanic beneficiaries. 
about whether some of the temporary changes should become 
permanent.  It  can also inform efforts  aimed at  ensuring that  all 
beneficiaries  have  appropriate  access to telehealth.   
This data brief includes beneficiaries  in Medicare fee-for-service and Medicare Advantage.   This  data  
brief  is part of a  series  that examines the use of telehealth in Medicare and  identifies program integrity  
concerns related to telehealth during the pandemic.3  
How OIG Did This Review  
This analysis  focuses on  Medicare beneficiaries  who used telehealth services  during the first year  of the 
pandemic  from March 1,  2020,  to February 28, 2021.   We based this  analysis  on  Medicare fee-for-
service  claims data,  Medicare Advantage encounter data,  and data from  the Medicare Enrollment  
Database.   
 
  What OIG Found  
Beneficiaries in urban areas were more likely than those in rural areas to use telehealth  during the first 
year of the pandemic.   Beneficiaries  in Massachusetts, Delaware,  and California were more likely than 
beneficiaries  in  some  other  States  to use telehealth.   Dually  eligible  beneficiaries (i.e., those eligible for  
both Medicare and  Medicaid), Hispanic  beneficiaries,  younger  beneficiaries, and female beneficiaries  
were also  more likely than others  to use telehealth.   In addition, beneficiaries almost always used  
telehealth from home or other non-health-care settings.  Furthermore, almost  one-fifth of  beneficiaries  
used  certain  audio-only telehealth services, with  the  vast majority  of  these beneficiaries  using these  
audio-only  services  exclusively.4   Older  beneficiaries  were more likely to use  these audio-only services,  
as were dually eligible and Hispanic beneficiaries.    
What OIG  Recommends  
As CMS, HHS, Congress, and other stakeholders consider permanent changes  to  Medicare telehealth 
services,  it is important that  they  balance  concerns about  issues such as access, quality of  care,  cost,  
health equity, and program  integrity.  Doing so will  ensure  that the benefits of telehealth are realized  
while minimizing risk.   The data presented in this report  demonstrate  how the temporary expansions  
improved access to telehealth for Medicare beneficiaries  during the first year  of the pandemic,  
particularly for those  who are  medically underserved.   Understanding  who benefited from increased  
access and how  different groups used telehealth can inform policymakers  and stakeholders  as they  
make decisions about telehealth.   
Accordingly,  we recommend that  CMS: (1)  take appropriate steps to enable a successful transition from  
current pandemic-related flexibilities to well-considered long-term policies for the use of telehealth for  
beneficiaries in urban areas and from the beneficiarys home,  (2)  temporarily extend the use of audio-
only telehealth services  and evaluate their impact,  (3)  require a  modifier  to identify  all audio-only  
telehealth services provided in Medicare,  and (4)  use telehealth to advance health care equity.   CMS did 
not explicitly  indicate  whether it concurred  with our four recommendations.  
 
 
 
 
   
Primer on:    Medicare Telehealth Services During the Pandemic  
  Medicare  telehealth services  refer to services that are provided remotely using 
 
technology between a provider and a  beneficiary.5       
  The services that  can be provided via telehealth include office visits,  behavioral 
 
health services,  nursing home visits, and home visits, among others.   Most of 
these services  can also be provided in  person.    
 
  A group of services known as  virtual care services  is  always  provided remotely.6   
An example of these services is a  telephone call with a provider to discuss a 
  beneficiarys medical condition.  
  During the pandemic, CMS allowed beneficiaries to  use telehealth to  access  a wide 
  range of services in different locations, including in urban areas and from the 
beneficiarys home.   Prior to the pandemic, beneficiaries  were allowed to  use 
telehealth only  from medical facilities located in rural areas,  with  a few  exceptions.7   
 
  During  the pandemic, CMS increased the types  of  services that beneficiaries  could 
use via telehealth, from  118 to  264  service  types.8      
 
  During the pandemic, CMS expanded the use of  audio-only  for  certain types of 
telehealth services, such as office visits and behavioral health services.  Prior to the
  pandemic, only audio-video  was allowed for  the delivery  of  telehealth services, with
a few exceptions.9  
 
 
 
 
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Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Primer  | 3  
  RESULTS  
 
The COVID-19 pandemic  created disruptions in how  Medicare  beneficiaries accessed  
health care.   Because of  concerns  about the pandemic,  HHS and  CMS  took a  number  
of actions to provide broader  access to telehealth  for Medicare beneficiaries.   CMS  
allowed beneficiaries to  use telehealth for  a wide range of  services  and  in different  
locations, including in urban areas  and from the beneficiarys home.   Expanding 
access to telehealth services was  intended  to help  beneficiaries  maintain access to  
needed care while limiting community spread  of COVID-19, as  well as limiting the  
exposure to other patients and staff members.  
In a  companion report,  OIG found that  the use of telehealth increased dramatically  
during the first year  of the pandemic.10   More than  28 millionabout  2  in 5 
Medicare beneficiaries used telehealth  that first year.   In total,  beneficiaries used  
88  times more telehealth services during the first  year of the pandemic than they did  
in the prior year.  
This data brief  expands on that  analysis and  examines  the characteristics of  
beneficiaries who  used  telehealth during the first year  of the pandemic from March 
2020 through  February 2021.  It includes beneficiaries in Medicare fee-for-service and  
in Medicare Advantage.   In addition, this  analysis  looks at  billing by individual 
practitioners  but  not institutions, such as hospitals.  
Understanding the characteristics of beneficiaries  who used telehealth during the first  
year of the pandemic can shed light on how the temporary expansion of telehealth 
affected different groups of beneficiaries.   This information will help CMS,  HHS,  
Congress,  and other stakeholders  understand  who benefited from  the expansion and  
make decisions about  whether some of the  temporary  changes  should become 
permanent.   It can also  inform  efforts that are aimed at ensuring that all beneficiaries  
have appropriate access  to telehealth.    
Beneficiaries in urban areas were more likely than those in rural  
areas to use telehealth    
Beneficiaries in urban areas were more likely than beneficiaries in rural areas  to use 
telehealth during the first year of the pandemic.11   Beneficiaries in urban areas have 
not historically had access to telehealth.  Prior to the pandemic, telehealth services  
were limited to beneficiaries in rural areas,  with some exceptions.12  
In  total, 45  percent of beneficiaries in urban areas used telehealth during the  first year 
of the  pandemic.  They  accounted for  more than  24  million of the  54  million  
Medicare  beneficiaries living in urban areas.   In  contrast, just 33  percent of  
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Results  | 4   beneficiaries in rural areas used telehealth.   They accounted for  more than 3  million of  
the more than  11  million Medicare beneficiaries living in rural areas.   See  Exhibit  1.    
Exhibit 1: Medicare beneficiaries in urban areas were more likely than those 
in rural areas to use telehealth  during the first year of the  pandemic.  
 
45%  33% 
of beneficiaries  in   of beneficiaries  in  
urban areas used   rural areas used  
telehealth  telehealth 
                                            
    
Source:  OIG analysis of CMS data,  2022.  
Beneficiaries in rural areas may face unique barriers to accessing telehealth.  For  
instance, rural populations are less likely  than those in urban areas  to have access to  
broadband connectivity.13   Rural health care providers may also  face challenges  
providing  telehealth to their patients,  as  equipment and internet connectivity can be 
expensive.14  
Beneficiaries almost always used  telehealth from home,  regardless of whether  
they lived in urban or rural areas  
Almost all beneficiaries  who  used telehealth  during  93%   
the first year  of the pandemic  did so  from  home  or  
other non-health-care  settings.  Prior to the   of beneficiaries who used 
telehealth did so  from  home  or 
pandemic, most beneficiaries  were required  to use 
other  non-health-care settings.   
telehealth from  a health care setting,  such as a 
doctors  office or hospital, with some exceptions.15     
Beneficiaries in  Massachusetts,  Delaware, and California  were 
more  likely  than  beneficiaries  in  some  other States  to use  
telehealth  
The States  with  the highest percentages  of  Medicare beneficiaries  who  used  
telehealth during the first year of the pandemic  included  Massachusetts  (57  percent),  
Delaware  (57  percent),  and California (52  percent).   See Exhibit 2.  
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Results  | 5   This  varied  greatly from  some  other States.  The States with the lowest  percentages  of  
beneficiaries  who used telehealth included  North Dakota  (21 percent), Montana  
(25  percent), Wyoming (25 percent), and Nebraska (25 percent).   See Appendix A  for  
the percentage of beneficiaries  who used telehealth in each State.  
Exhibit 2: The percentage of beneficiaries who used telehealth  during the first 
year of the pandemic  varied by State.  
 
2 1% 
27% 
25%  NH44% 
VT41% 
MA57% 
26%  RI 47% 
CT 50% 
NJ 50% 
DE 57% 
MD50% 
DC46% 
45% 
 
Source:  OIG analysis of  CMS  data, 2022.  
Notably,  many beneficiaries in these four  States  live  in rural areas.   In Montana and  
Wyoming, roughly two-thirds of Medicare beneficiaries live in rural areas.  In North 
Dakota,  more than  half of  the  Medicare population lives in rural areas.   In Nebraska,  
more than 40  percent  of  all Medicare beneficiaries live in rural areas.  As mentioned  
above, beneficiaries in rural areas may face unique barriers to accessing telehealth. 
Dually  eligible, Hispanic,  younger, and  female  beneficiaries  were  
more likely than others  to use telehealth  
To better understand  which groups  of beneficiaries were more likely  than others  to  
use telehealth during the first year of the pandemic, we analyzed the use of telehealth 
among all beneficiaries enrolled in Medicare and  the use of telehealth among those 
 
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Results  | 6        
           
     
       
   
who used  any telehealth-eligible service, either in-person or via telehealth.   These 
measures show the extent to which each group of  beneficiaries used telehealth 
overall and the extent to  which each group used  telehealth regardless of  whether  
these beneficiaries  were more likely to use any service.   In this report, we use the term  
any service to refer to any telehealth-eligible service.  
For  each group of beneficiaries,  we found that the likelihood of each group to use 
telehealth was not impacted by the  likelihood  of using  any  service.   See Appendix B  
for detailed information about each group.  
Beneficiaries  dually eligible for Medicare and  Medicaid  were more likely  to use  
telehealth than Medicare-only  beneficiaries.   More than  half of all dually eligible  
beneficiaries  used  telehealth  during the first year of the pandemic.   Dually eligible  
beneficiaries are enrolled  in  Medicare due to age  or disability and in  Medicaid due to  
income.   They typically have lower incomes  and a  higher prevalence of many health 
conditions than Medicare-only beneficiaries.16  
In  total, 53  percent of dually eligible beneficiaries  used telehealth  during the  first year 
of the  pandemic, compared to 40  percent of  Medicare-only  beneficiaries.   See Exhibit  
3.  Notably, dually eligible beneficiaries  were more likely than Medicare-only 
beneficiaries  to use telehealth regardless of  race  and  ethnicity,  and  whether they lived 
in rural or urban areas. 
Exhibit 3: Dually eligible beneficiaries were more likely than Medicare-only  
beneficiaries to use telehealth during the first  year of the pandemic.  
 
53%  40% 
of dually eligible  of Medicare-only 
beneficiaries   beneficiaries  
used   used  
telehealth  telehealth 
                                          
 
Source:  OIG analysis of CMS data,  2022.  
    
Dually eligible beneficiaries  were  also  more  likely to use  any  service  (telehealth or  
in-person)  than  Medicare-only  beneficiaries;  however,  this did  not appear  to explain  
the  relatively high use of  telehealth  by dually eligible beneficiaries.   When accounting  
for their  increased  likelihood of using  any service, dually eligible  beneficiaries  were  
still more likely to use telehealth services  than  Medicare-only  beneficiaries.    
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Results  | 7   Hispanic beneficiaries were  more likely than  beneficiaries in other groups  to use  
telehealth.   Overall, 48  percent of Hispanic beneficiaries used telehealth  during the 
first year  of the pandemic,  which is  a higher  percentage  than beneficiaries in other  
racial  and ethnic groups.17   In  total,  45  percent of  Black beneficiaries  used telehealth,  
while  42  percent of  both Asian/Pacific Islander and White beneficiaries  did so.   See 
Exhibit  4.    
Exhibit 4: Hispanic beneficiaries were more likely than other groups to use 
telehealth during the first year of the pandemic.  
Hispanic  48%
Black  45%
Asian/Pacific Islander  42% 
White  42%
 
Source:  OIG analysis of  CMS  data, 2022.  
It is  important to note that  Hispanic beneficiaries  were  more  likely to use telehealth  
than others  regardless of  whether the  beneficiaries  lived  in rural  or urban  areas,  or  
whether  or not  they  were dually  eligible.     
Unlike  their use of telehealth during the first year of the pandemic,  Hispanic  
beneficiaries  were less likely to use any service  (telehealth or in-person)  than  White 
beneficiaries  and Black beneficiaries.   Yet, even when accounting  for  their  decreased  
likelihood of using  any  service, Hispanic beneficiaries  were  still more  likely to  use 
telehealth  than White  beneficiaries and  Black  beneficiaries.   This suggests  that  
Hispanic  beneficiariesa medically underserved populationparticularly  benefited  
from the expanded  access to  telehealth  during the first year of the pandemic.     
Beneficiaries under  age 65  were more likely than  beneficiaries in  other age  
groups  to use  telehealth.   Overall,  49  percent of  beneficiaries under the age of  
65  used  telehealth  during the first year of the pandemic.   These beneficiaries  were 
more  likely to use telehealth  than  beneficiaries in other age groups.   Beneficiaries  
under the age of  65  usually qualify for Medicare because of a disability  and are often 
dually eligible.    
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Results  | 8        
           
     
       
   
Beneficiaries between the ages of 65 and  74  were  less likely  to  use telehealth  than  
other age groups.   Specifically, 38  percent of beneficiaries between 65 and  74 used  
telehealth, while 47 percent of beneficiaries 75  and older  did so.   See Exhibit  5.    
Unlike their use of telehealth, beneficiaries under  65  were less likely than beneficiaries  
75 and older  to use any  service  (telehealth or in-person).   Yet,  even when accounting  
for their  decreased likelihood of  using  any service, beneficiaries under 65 were still 
more likely to use telehealth services  than  beneficiaries  75 and older.   This  suggests  
that beneficiaries  under 65  particularly  benefited from  the  expanded  access to  
telehealth during the first year of the pandemic.     
Exhibit 5: Medicare beneficiaries under age 65  were more  likely  than other  
age groups to  use telehealth  during the first year of the pandemic.  
Under 65  49%
65-74 38%
75-84 47%
Over 84  47%
 
Source: OIG analysis  of CMS data,  2022.  
 
Female beneficiaries were  more likely  than male beneficiaries  to use telehealth.   
In total,  46  percent of all female beneficiaries  compared to  39  percent of  male  
beneficiaries used telehealth  during the first year of the pandemic.   Female  
beneficiaries  were more likely to use telehealth than male beneficiaries  regardless of  
age, race  and  ethnicity,  whether they  were  in a rural or urban area,  or whether  or not  
they  were  dually eligible.     
Female beneficiaries were also  more likely to use  any  service  (telehealth or in-person)  
than male beneficiaries; however,  this did not appear to explain the relatively high use 
of telehealth by  female beneficiaries.   When accounting  for their  increased  likelihood  
of using  any service, female beneficiaries  were still more likely  than male beneficiaries  
to use telehealth services.    
 
 
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Results  | 9   Almost  1 in 5  beneficiaries used  certain  audio-only telehealth 
services;  the vast majority  of these beneficiaries  used  them  
exclusively  
Almost  1 in  5 Medicare beneficiaries  used  certain  telehealth services  that were 
available  audio-only  during the  first year of the  pandemic.   These  six  audio-only  
services  do not include video.  These services  
Exhibit 6: The  vast 
consist of  telephone calls with a provider  for  
various  durations  to discuss a beneficiarys   majority of  beneficiaries 
medical condition.18   A total of  12.7  million   who used certain audio-
Medicare beneficiaries, or 19 percent of all   only services did not use  
beneficiaries,  used  these  audio-only  services   any audio-video  
during the  first year of the  pandemic.   
telehealth services.  
It is important to note that an additional  
86  telehealth services  are available  either  as 
audio-only  or audio-video,  but  Medicare data do   93% 
not distinguish  between the two.19   Therefore, the  of beneficiaries  
total number of beneficiaries who used  any   who used certain  
audio-only services  during the first year of the  audio-only 
pandemic is higher than 12.7  million.    services did so  
exclusively 
The vast majority  of beneficiaries93 percent 
who used  the six  audio-only  telehealth  services                
    
did so exclusively.   These beneficiaries  did not use  
Source:  OIG analysis of CMS data,  2022.  
any  audio-video  telehealth services  during the 
first year  of the pandemic.20   The remaining  7 percent of beneficiaries used both 
audio-only and audio-video  telehealth services.   See Exhibit  6.   Using audio-only  
services exclusively  may  suggest that these beneficiaries  prefer  audio-only telehealth 
services,  or that they  may face barriers to using audio-video telehealth.   
Older beneficiaries were more likely to  use certain  audio-only 
services, as were dually eligible and Hispanic beneficiaries  
Older beneficiaries  were more likely to use the six  audio-only services  compared to  
younger beneficiaries  during the first year of the pandemic.  Specifically,  23 percent of  
beneficiaries  75  and older used audio-only services, while only  21 percent  of  
beneficiaries under 65 did the same.  This pattern is unlike that for all telehealth 
services and may indicate that older beneficiaries  prefer audio-only or  have greater  
difficulty accessing  audio-video  technology  than their younger  counterparts.   See 
Exhibit 7.  
In addition, dually eligible  beneficiaries  and Hispanic beneficiaries were more likely to  
use these audio-only services than other beneficiaries.  More than 20 percent of  
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Results  | 10   dually eligible  beneficiaries  and Hispanic beneficiaries  used  these audio-only services.   
Beneficiaries in these groups were also more likely to use all telehealth services.   
Furthermore, female  beneficiaries  were more likely to use these audio-only  services  
than male  beneficiaries, and those in urban areas  were more likely to  use these audio-
 
only  services  than those  in rural areas.   
  Exhibit  7: Certain beneficiaries were  more likely  to use these audio-only services  
than others during the first year of the  pandemic.  
 
Over 84  23% 
  75-84  23% 
65-74  16% 
 
Under 65  21% 
 
Hispanic  23% 
 
Black  21% 
 
White  19% 
  Asian/Pacific Islander  17% 
 
Dually eligible  24% 
 
Medicare-only  18% 
 
Female  21% 
 
Male  17% 
 
Urban  20% 
 
Rural  15% 
   
Source: OIG analysis of CMS data,  2022.  
Note: This analysis is based on  the six audio-only services.   
 
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Results  | 11   CONCLUSION AND RECOMMENDATIONS  
 
The COVID-19 pandemic created  unprecedented  challenges for how Medicare beneficiaries  
accessed health care.   In response, HHS and  CMS took a number of actions to temporarily  
expand access to telehealth for Medicare beneficiaries.   
In a  companion report,  OIG found that the  use of telehealth increased dramatically during the 
first year  of the pandemic.21   More than 28 millionabout  2 in 5Medicare beneficiaries used  
telehealth  that first year.   In total, beneficiaries used 88 times more telehealth services during  
the first year  of the pandemic than they did in the prior year.   
This data brief expands  on that analysis  and found  that,  during the first year of pandemic,  many  
Medicare beneficiaries relied on using telehealth from locations and in ways not previously  
allowed by Medicare, such as from urban areas, from home, and through audio-only.22   More 
specifically,  we found that  beneficiaries in urban areas were more likely than those in rural areas  
to use telehealth.  Dually  eligible  beneficiaries  and Hispanic beneficiaries  were also more likely  
than others to use telehealth.  In addition, beneficiaries almost always used  telehealth from  
home or other non-health-care settings.   Furthermore,  almost one-fifth of  beneficiaries  used  
certain audio-only  telehealth services, with  the vast majority  of these beneficiaries using  these 
audio-only  services  exclusively.     
As CMS, HHS, Congress, and other stakeholders consider permanent  changes to Medicare 
telehealth services,  it is important that they balance  concerns about  issues such as access, 
quality  of care,  cost,  health equity, and program integrity.   Doing so will  ensure the benefits of  
telehealth are realized  while minimizing risk.  The data presented in this report  demonstrate  how  
the temporary expansion  improved access  to telehealth for Medicare  beneficiaries, particularly  
for those  who are  medically underserved.   Understanding who benefited from increased access 
and how  different groups  used telehealth  can inform  policymakers and stakeholders  as they  
make  decisions about telehealth.    
We recommend  that CMS:   
Take appropriate steps to enable a successful transition from  
current pandemic-related flexibilities to well-considered  long-
term policies  for the use of telehealth for beneficiaries in urban 
areas and from the beneficiarys home  
Our findings demonstrate the important role that  telehealth played in Medicare 
beneficiaries access to  care when telehealth became more broadly available during the 
pandemic.  This  was especially true for beneficiaries in urban areas, as more than 
24  million beneficiaries in urban areas used telehealth services from March 2020 through 
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Conclusion and  Recommendations |  12   February 2021.  Furthermore, when given the option, more than 90 percent of all  
beneficiaries  (urban and  rural)  who used telehealth did so from home or  other non-
health-care settings.  Prior to the pandemic, many of these beneficiaries were not  
allowed to use telehealth in urban areas  or from home.  However, unless policymakers  
take action, millions of beneficiaries in urban areas, as well as millions of beneficiaries in  
both urban and rural areas receiving  care from home, will lose access to many telehealth 
services once the temporary expansions to telehealth end.23      
Congress has extended the temporary telehealth expansions for  5  months after the 
public health emergency ends.  If that deadline comes before long-term telehealth 
policies have been enacted, CMS  should seek additional authority from Congress to  
temporarily  continue access to telehealth services in urban areas  and from  the 
beneficiarys home.  This will ensure that beneficiaries enrolled in Medicare 
fee-for-service can continue to receive services  via telehealth, regardless of geographic  
location or ability to travel to a health care facility to receive care,  while policymakers  
deliberate and develop more permanent policies for telehealth.    
As CMS develops proposals for long-term policies on telehealth, it should carefully  
consider the impacts of telehealth flexibilities on beneficiary access to care, health equity,  
quality, costs, and program integrity.  CMS should take into account the analysis detailed 
in this  brief  and consider building on it to  further analyze access to care for medically  
underserved beneficiaries, including how maintaining the availability of telehealth could  
facilitate access to care for these beneficiaries.  CMS should  also use other OIG work,  
including the other report in this series about program integrity concerns related to  
telehealth,  additional analysis it conducts, and feedback and data from other  
stakeholders  as it develops policy proposals.24   
Temporarily extend the use of audio-only telehealth services  
and evaluate their impact   
CMS should temporarily  extend the use of audio-only for telehealth services once the 
temporary expansions to telehealth end, seeking statutory  authority,  if necessary.  CMS  
should then evaluate the impact of  audio-only services on beneficiary access,  equity,  
cost,  quality  of care,  and program integrity.25  
During the first  year of the pandemic,  more than 12 million beneficiaries used  certain 
audio-only telehealth services; the vast majority of these beneficiaries used audio-only  
telehealth services exclusively.  These beneficiaries may prefer audio-only or face barriers 
to  accessing audio-video telehealth  services, such  as a lack of appropriate technology or  
broadband  access.  Furthermore, certain beneficiaries such as older, Hispanic, and dually  
eligible beneficiaries were more likely to use these audio-only services than other  
beneficiaries  during the first year of the pandemic.    
Without further action,  Medicare beneficiaries  enrolled in Medicare fee-for-service will 
no longer be allowed to  use audio-only  services  (except in certain  circumstances)  once  
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Conclusion and  Recommendations |  13   the temporary expansions to telehealth end.26   In addition,  there are questions  about the 
impact of these services  on quality of  care,  among other issues.27    
CMS should use the information in this  brief,  information from its evaluations,  and  
feedback and data from other stakeholders  to  determine whether to permanently  
expand the use  of audio-only services and  what, if any, limitations should be placed on 
these services.  For example, CMS  could allow audio-only telehealth services  solely for  
providers  with whom  the  beneficiary has  an established relationship or  when the 
beneficiary has periodic in-person visits  with the provider.28   
Require a modifier to identify all audio-only telehealth services  
provided in Medicare  
CMS  is not able to identify all audio-only telehealth services.  Currently, it  can identify  
6  services, but it is not able to identify whether audio-only services  were provided for  
86  other telehealth services.  Not being able to identify these services when they are 
provided  as audio-only  makes it difficult to  assess the use of audio-only  as well as its  
impact on access, quality  of care,  equity,  and program integrity.   
Starting in 2022,  CMS requires  that providers use a modifier when billing  for audio-only  
telehealth  services under certain circumstances.29   CMS should build upon this and  
require providers  to  use this modifier to identify all  telehealth services provided  as 
audio-only.30   This is important in the event CMS  further  expands the use of  audio-only  
telehealth  on a more permanent basis.  CMS should  require that providers identify  all 
services that are provided  as audio-only so that it can evaluate and monitor  the use of  
audio-only services.   
Use  telehealth to advance health care equity  
Telehealth can be a valuable tool for increasing access to  care, especially  for certain 
beneficiaries.   We found  that dually eligible, Hispanic, younger, and  female beneficiaries  
were more likely than others to use telehealth during the first year of the pandemic.   
Furthermore,  certain beneficiaries, such as Hispanic beneficiaries,  were more likely to use 
telehealth than other groups even though they were less likely to use any service,  
suggesting they particularly benefited from the expansion of telehealth.   
CMS is  committed to advancing health equity and has developed a strategy to promote 
equity across its programs.31   Telehealth can help increase access to  care, especially for  
beneficiaries  who  are medically underserved or face barriers to accessing in-person care.   
CMS should take steps to promote the use of telehealth and use telehealth to address  
the goals  of  its health equity strategy, as appropriate.   For example, CMS  could  
incorporate telehealth as an action step to help close gaps in access among medically  
underserved populations.  
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Conclusion and  Recommendations |  14   In addition,  CMS should provide additional outreach and education to assist beneficiaries  
in accessing telehealth,  particularly  for beneficiaries with  limited access to  in-person care.   
For  example,  CMS could direct  its  Quality Innovation  Network-Quality Improvement  
Organizations to  provide resources that can  assist  in  accessing  telehealth as appropriate 
and include additional  information about  telehealth in the Medicare handbook (i.e.,  
Medicare  & You).  
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Conclusion and  Recommendations |  15    
AGENCY COMMENTS AND OIG RESPONSE  
 
 
CMS did not explicitly indicate whether it concurred with our four recommendations.    
In response to  our  first recommendation  to take appropriate steps to enable a  
successful transition from current pandemic-related flexibilities to well-considered  
long-term policies for the use of telehealth for beneficiaries in urban areas and from  
the beneficiarys home,  CMS noted that it has taken steps to implement telehealth 
policies consistent with changes in legislation, such as expanding the originating sites  
at which a beneficiary may be located for mental  health telehealth services.  CMS  
stated that it will continue to implement policies consistent with its authority, adding 
that further legislative change may be necessary to implement this recommendation.   
In response, OIG  recognizes that additional  legislative action  will  be necessary  for the 
transition from  current pandemic-related flexibilities,  and that the Presidents FY23  
Budget supports  extending telehealth coverage beyond  the public health emergency  
to study telehealths impact on utilization  of  services and  access to  care.   OIG will 
continue to monitor  the  implementation of  the Presidents FY23  Budget  proposal  and 
its outcomes.    
In response to  our second recommendation to temporarily extend the use of audio-
only telehealth services and evaluate their impact,  CMS noted that it established a  
policy to  allow mental health services to be provided  via  audio-only  telehealth in 
certain circumstances.   CMS stated that it will continue to implement policies  
consistent  with its authority and that further legislative change may be necessary to  
implement this recommendation.  In response, OIG recognizes that  additional 
legislation  will  be needed  to  temporarily  extend the use of  audio-only telehealth for  
most services.  OIG also  emphasizes that further  assessment of the impact  of audio-
only telehealth services on equitable access to  care is  critical given  OIGs findings  on 
the individuals  who  were most likely  to use audio-only telehealth during the first  year  
of the pandemic.  
In response to  our third recommendation to require a modifier to identify  all audio-
only telehealth services provided in Medicare,  CMS noted that, in the Calendar Year  
2023 Physician Fee Schedule proposed rule, it proposed requiring physicians and  
other health care practitioners to include a modifier on claims for telehealth services  
that were provided using audio-only technology.   CMS added that it will take  
feedback from the public comment period,  as well as OIGs recommendation, into  
consideration as it determines appropriate next steps.    
In response to  our fourth recommendation to use telehealth to advance health care 
equity,  CMS indicated that it continues to evaluate opportunities to advance health 
equity, drive innovation, and promote good fiscal  stewardship for the Medicare 
program based on the telehealth flexibilities implemented  during the public  health 
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Agency Comments and OIG Response  | 16   emergency,  and will continue to implement policies consistent  with its authority.  CMS  
added that it provided education to  assist individuals with Medicare in accessing 
telehealth and that it published a Coverage to  Care Telehealth Toolkit  that includes  
general information,  such as  information  about  the types of  care individuals can 
receive through telehealth.  CMS indicated that it  will continue to provide education 
to individuals with Medicare regarding their options for receiving services  via  
telehealth as appropriate.   OIG appreciates CMSs  efforts and encourages CMS to  
build upon these efforts  by,  for example,  providing additional outreach and education  
to assist beneficiaries in accessing telehealth.  
We ask that CMSin its Final Management  Decisionprovide details on any plans  
and progress toward implementing our recommendations.    
For the full text of CMSs  comments, see Appendix C.  
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Agency Comments and OIG Response  | 17   METHODOLOGY  
 
We based this data brief  on an analysis of  Medicare fee-for-service claims and  
Medicare Advantage encounters for telehealth services from  March 1, 2020,  to  
February 28, 2021.  These data are similar to the data used in other reports in the 
series  about Medicare beneficiaries use of telehealth during the first year of the 
pandemic.32  
We used the Medicare Part B  fee-for-service  claims from the National Claims History  
File and Medicare Advantage encounters from  Part C Encounter data.   When 
identifying telehealth services, we reviewed  services billed by individual practitioners;  
we did not review  services billed  by institutional entities, such as hospitals and nursing  
homes.   We also used enrollment data for  Medicare fee-for-service and Medicare 
Advantage from the Medicare Enrollment Database.    
We used these data to identify the characteristics of beneficiaries who used telehealth 
services in Medicare fee-for-service and Medicare Advantage during the first year of  
the pandemic.   
Beneficiaries  Who  Used  Telehealth  
To conduct this  analysis,  we first identified the services that  Medicare approved for  
telehealth during the pandemic.33   These services are described using Current  
Procedural Terminology  codes and Healthcare Common Procedure Coding System  
codes.  These codes  are included on the claim by  a provider for reimbursement  
purposes.   
As part of our  analysis, we included virtual care services as a type of telehealth service.   
These services are also  referred to as communication technology-based services.   
These services are always delivered remotely and include virtual check-ins, e-visits,  
remote monitoring, and telephone calls with a provider to discuss a beneficiarys  
medical condition.     
We identified the services that were delivered via  telehealth using  a modifier (i.e., 95,  
GT, GQ, or G0)  or a place of service code (i.e., 02) that indicates the service was  
delivered via telehealth.  We considered the services that did not have any  of these 
modifiers or codes to be delivered in  person.34  
To identify the audio-only services, we focused on the six telehealth services that  are  
available  exclusively  as audio-only.   These six audio-only services  do not include 
video.  They  consist  of  telephone calls with a provider for various durations  to discuss  
a beneficiarys medical  condition.   We did not include the other telehealth services  
that can be provided  as audio-only because Medicare data for these services do not  
distinguish between audio-only and  audio-video use.   
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Methodology  | 18   Analysis  of  Characteristics of  Beneficiaries  Who  Used  Telehealth  
We analyzed the use of telehealth among  beneficiaries with different characteristics.   
We first examined the use of telehealth among beneficiaries  who lived  in urban and  
rural areas.  We determined whether a beneficiary  lived in an urban or rural area by  
matching the beneficiarys ZIP  code from the Medicare Enrollment  Database with  a  
Census Bureau Core-Based Statistical Area (CBSA).  We considered  a beneficiary to  
live in an urban area if they resided in a Metropolitan Statistical Area and in a rural  
area if they resided in a  Micropolitan Statistical Area or  outside  a  CBSA.35    
We also looked at the use  of telehealth services among beneficiaries living in different  
States.  We determined a beneficiarys State of residence based on the beneficiarys  
address.  We also determined the extent to which beneficiaries used telehealth from  
home  and other non-health-care settings.36  
Next, we looked at the use of telehealth among beneficiaries  with certain 
demographic characteristics.  We based this analysis on information from the 
Medicare Enrollment Database.  We reviewed the following  characteristics:    
  Age (Under 65, 65-74, 75-84,  Over  84)  
  Sex (Male, Female) 
  Race and  Ethnicity (White, Black, Hispanic, Asian/Pacific  Islander) 
  Eligibility Status (Dually  Eligible, Medicare-Only) 
Note that the race  and  ethnicity information is based on data collected from the 
Social Security Administration and an algorithm developed by the Research Triangle 
Institute.37   This algorithm attempts to improve the  quality of the Social Security  
Administrations data by amending the race data for certain groups based on name 
and geography, as well as requests made by individuals for certain Government  
materials to be provided  in Spanish.  
For each group  described above,  we calculated the percentage  of beneficiaries who  
used telehealth among all enrolled beneficiaries and the percentage  of beneficiaries  
who used telehealth  among  those  who used any telehealth-eligible service, either  
in-person or via telehealth (i.e., any service)  during the first year of the pandemic.38   
For example,  we calculated the percentage  of  beneficiaries  who used telehealth 
among  all enrolled Medicare beneficiaries in each age group during the first year of  
the pandemic.  We then compared these percentages  to determine which age  groups  
were more likely to use telehealth during this time period.  For each age  group, we 
then  calculated the percentage  of beneficiaries  who used telehealth among  
beneficiaries who  used  any  service to determine the extent to which each group used  
telehealth,  regardless of  whether they were more likely to use any service.  
We conducted a similar  analysis of the use of  the six  audio-only services that are 
available exclusively  as audio-only.   For each  group, we calculated the percentage  of  
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Methodology  | 19   beneficiaries  who used these services  among  all enrolled  beneficiaries  during the first 
year of the pandemic.  We then compared  these percentages  to determine  which 
groups of beneficiaries were more likely to use these audio-only services during this  
time  period.  We also determined the extent to which beneficiaries used  these audio-
only telehealth services exclusively.39  
Limitations   
While this study includes demographic data about those using telehealth services, it is  
possible that other factors that were not included  in this study could have influenced  
an individuals use of telehealth, such as their diagnoses, health status, or income,  
among other factors.   Understanding how these factors  could have influenced the use 
of telehealth is important for future work.   
In addition, although the race and  ethnicity  information is currently the best available 
for the entire Medicare beneficiary population, comparisons to self-reported data  
(available in certain, limited circumstances) show that race  and  ethnicity  are still 
misclassified for some beneficiaries.  As such,  we did not report on beneficiaries  
identified as American  Indian/Alaska  Native since  this group is often misclassified.   
Furthermore,  although Hispanic is an ethnicity,  Medicares data combine race and 
ethnicity and limit beneficiaries to one category.40   
Standards  
We conducted this study in accordance with the Quality Standards for  Inspection and  
Evaluation  issued by the Council of the Inspectors General on Integrity and Efficiency.   
 
 
 
 
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Methodology  | 20   APPENDIX A  
Percentage of  Beneficiaries in  Each State  Who  Used  Telehealth During  the First  
Year  of  the Pandemic  
State   Percentage  
Massachusetts   57%  
Delaware   57%  
California    52%  
Connecticut    50%  
Maryland   50%  
New Jersey    50%  
Rhode Island   47%  
New York    47%  
Arizona    47%  
Florida    47%  
District of Columbia   46%  
New Mexico   46%  
Hawaii    45%  
Texas   45%  
Pennsylvania   44%  
New Hampshire   44%  
Ohio   44%  
Oregon    43%  
Michigan    43%  
Minnesota   42%  
Indiana   42%  
Virginia    42%  
Kentucky   41%  
Vermont    41%  
North Carolina    41%  
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Appendix A  | 21   APPENDIX A  (Cont.)  
State    Percentage  
Colorado   40%  
Illinois    39%  
Georgia   39%  
Alabama   38%  
Louisiana    38%  
Washington    38%  
Nevada   38%  
Maine   38%  
Mississippi   37%  
Oklahoma   37%  
South Carolina    36%  
Utah   36%  
Arkansas   36%  
Alaska   35%  
West Virginia   35%  
Wisconsin    34%  
Tennessee   30%  
Iowa   30%  
Idaho    30%  
Missouri   29%  
South Dakota   27%  
Kansas   26%  
Montana   25%  
Wyoming   25%  
Nebraska   25%  
North Dakota   21%  
Source:  OIG analysis of CMS data,  2022  
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Appendix A  | 22   APPENDIX  B 
 
Characteristics  of  Beneficiaries  Who  Used  Telehealth During  the First  Year  of  
the Pandemic   
Exhibit B1: Medicare beneficiaries in urban areas were more likely  than those in rural areas 
to use telehealth.  
Number  Percentage 
Beneficiaries  Beneficiaries who used  Beneficiaries who used 
Beneficiaries  who used any  telehealth among those  telehealth among those 
Area  enrolled  service*  enrolled  who used any service 
Urban  54,393,561  44,910,462  45%  55% 
Rural  11,337,760  9,217,144  33%  41% 
*This refers to the number of beneficiaries who used any telehealth-eligible service, either in-person or via telehealth. 
Source: DIG analysis of CMS data, 2022. 
 
Exhibit B2: Dually eligible beneficiaries were more likely than Medicare-only beneficiaries to  
use telehealth.  
Number  Percenrage 
Beneficiaries  Beneficiaries who used  Beneficiaries who used 
Beneficiaries  who used any  telehealth among those  telehealth among those 
Eligibility  enrolled  service*  enrolled  who used any service 
Dually Eligible  12,477,492  11,049,080  53%  60% 
Medicare-Only  53,605,379  43,079,920  40%  50% 
*This refers to the number of beneficiaries who used any telehealth-eligible service, either in-person or via telehealth. 
Source: DIG analysis of CMS data, 2022. 
 
 
 
 
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Appendix B  | 23  
 
   APPENDIX B (Cont.) 
 
 
Exhibit B3: Hispanic beneficiaries were more likely than other groups to use telehealth.  
Number  Percentage 
Beneficiaries  Beneficiaries who used  Beneficiaries who used 
Beneficiaries  who used any  telehealth among those  telehealth among those 
Race & Ethnicity  enrolled  service*  enrolled  who used any service 
Hispanic  5,744,927  4,472,408  48%  61% 
Black  7,010,304  5,632,552  45%  56% 
Asian/Pacific Islander  2,388,933  1,773,416  42%  56% 
White  48,663,596  40,538,574  42%  51% 
'This refers to the number of beneficiaries who used any telehealth-eligible service, either in-person or via telehealth. 
Note: Information for beneficiaries identified as American Indian/Alaska Native, Other, Unknown, or had missing race and ethnicity data are not included in 
the table because of limitations with the data. Furthermore, although Hispanic is an ethnicity, Medicare's data combine race and ethnicity and limit 
beneficiaries to one category. 
Source: OIG analysis of CMS data, 2022. 
 
Exhibit B4: Medicare beneficiaries under age 65 were more likely than beneficiaries in other  
age groups to use telehealth.  
Number  Percentage 
Beneficiaries  Beneficiaries who used  Beneficiaries who used 
Beneficiaries  who used any  telehealth among those  telehealth among those 
Age  enrolled  service*  enrolled  who used any service 
Under 65  8,747,663  6,935,246  49%  61% 
65-74  33,184,295  25,545,589  38%  49% 
75-84  17,032,153  15,206,898  47%  53% 
Over 84  7,198,694  6,442,203  47%  53% 
'This refers to the number of beneficiaries who used any telehealth-eligible service, either in-person or via telehealth. 
Source: OIG analysis of CMS data, 2022. 
 
   
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Appendix B  | 24  
 
  APPENDIX  B (Cont.)  
 
Exhibit B5: Female beneficiaries were more likely than male beneficiaries to use telehealth.  
Percentage 
Beneficiaries  Beneficiaries who used  Beneficiaries who used 
Beneficiaries  who used any  telehealth among those  telehealth among those 
Sex  enrolled  service*  enrolled  who used any service 
Female  35,849,569  30,514,701  46%  54% 
Male  30,313,225  23,615,231  39%  50% 
This refers to the number of beneficiaries who used any telehealth-eligible service, either in-person or via telehealth. 
Source: OIG analysis of CMS data, 2022. 
 
 
 
 
 
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Appendix B  | 25  
 
  DATE:  July 29, 2022 
TO:  Gregory E. Demske 
Acting Principal Deputy Inspector General 
Office of Inspector General 
FROM:  Chiquita Brooks-LaSure 
Administrator 
Centers for Medicare & Medicaid Services 
SUBJECT:  Office of Inspector General (OIG) Draft Data Brief: Certain Medicare 
Beneficiaries, Such as Urban and Hispanic Beneficiaries, Were More Likely Than 
Others To Use Telehealth During the First Year of the COVID-19 Pandemic 
(OEI-02-20-00522) 
The Centers for Medicare & Medicaid Services (CMS) appreciates the opportunity to review and 
comment on the Office of Inspector Generals (OIG) draft report.  
CMS is committed to advancing health equity and recognizes that telehealth may be a useful tool 
to address disparities. CMS is working to advance health equity by designing, implementing, and 
operationalizing policies and programs that support health for all the people served by our 
programs, eliminating avoidable differences in health outcomes experienced by people who are 
disadvantaged or underserved, and providing the care and support that our enrollees need to 
thrive. 
At the beginning of the public health emergency (PHE), CMS issued waivers to prevent gaps in 
access to care for patients affected by the COVID-19 PHE, including waivers for services 
furnished via telehealth. These changes to payment and coverage policies were intended to allow 
health care providers maximum flexibility to minimize the spread of COVID-19 among 
Medicare beneficiaries, health care personnel, and the community at large and increase capacity 
to address the needs of their patients.  
On March 17, 2020, CMS announced the expansion of telehealth services on a temporary and 
emergency basis pursuant to waiver authority added under section 1135(b)(8) of the Social 
Security Act by the Coronavirus Preparedness and Response Supplemental Appropriations Act, 
2020 (Pub. L. 116-123, March 6, 2020). Beginning on March 6, 2020, and for the duration of the 
COVID-19 PHE, Medicare pays for telehealth services, including office, hospital, and other 
visits furnished by physicians and other practitioners to patients located anywhere in the country, 
including in a patients place of residence. In the context of the COVID-19 PHE, CMS 
recognized that the use of telehealth could help address new challenges regarding potential 
exposure risks, for people with Medicare, health care providers, and the community at large. To 
facilitate the use of telecommunications technology as a safe substitute for in-person services, 
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries, Were More Likely Than Others To Use 
Telehealth During the First Year of the COVID-19 Pandemic 
OEI-02-20-00522                   Agency Comments B | 26 CMS, on a temporary interim final basis, added many services to the list of eligible Medicare 
telehealth services, eliminated frequency limitations and other requirements associated with 
particular services furnished via telehealth, and clarified several payment rules that apply to other 
services that are furnished using telecommunications technologies that can reduce exposure 
risks.1 
CMS has also taken steps to implement policies consistent with changes in legislation that take 
effect after the COVID-19 PHE ends. For example, Section 123 of the Consolidated 
Appropriations Act, 2021 removed the geographic restrictions and added the home of the 
beneficiary as a permissible originating site for telehealth services furnished for the purposes of 
diagnosis, evaluation, or treatment of a mental health disorder. Section 123 requires for these 
services that there must be an in-person, non-telehealth service with the physician or practitioner 
within six months prior to the initial telehealth service and requires the Secretary to establish a 
frequency for subsequent in-person visits. CMS implemented these statutory amendments via the 
Calendar Year 2022 Physician Fee Schedule Final Rule, specifying that an in-person, non-
telehealth visit must be furnished at least every 12 months for these services, that exceptions to 
the in-person visit requirement may be made based on beneficiary circumstances (with the 
reason documented in the patients medical record), while clarifying that more frequent visits are 
also allowed under our policy, as driven by clinical needs on a case-by-case basis.2 
In the Calendar Year 2022 Physician Fee Schedule Final Rule, CMS also established a 
permanent policy to permit the use of an audio-only interactive telecommunications system for 
mental health telehealth services furnished by practitioners who have the capability to furnish 
two-way, audio/video communications, but the beneficiary is not capable of, or does not consent 
to, the use of two-way, audio/video technology. CMS also specified that a designated modifier 
must be used on claims for these services furnished using audio-only communications, which 
would serve to verify that the practitioner had the capability to provide two-way, audio/video 
technology, but instead, used audio-only technology due to beneficiary choice or limitations. 
The Consolidated Appropriations Act, 2022 (Pub. L. 117-103) included several provisions that 
extend certain Medicare telehealth flexibilities adopted during the PHE for 151 days after the end 
of the COVID-19 PHE. These include allowing telehealth services to be furnished in any 
geographic area and in any originating site setting, including the beneficiarys home, allowing 
certain services to be furnished via audio-only telecommunications systems, and allowing 
physical therapists, occupational therapists, speech-language pathologists, and audiologists to 
furnish telehealth services.  
In the Calendar Year 2023 Physician Fee Schedule Proposed Rule, CMS provided notice of its 
intent to issue program instruction or other subregulatory guidance to effectuate the changes to 
telehealth enacted in the Consolidated Appropriations Act, 2022 to ensure a smooth transition 
1 The list of these eligible telehealth services is published on the CMS website at 
https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/index.html. 
2 Medicare Program; Calendar Year 2022 Payment Policies Under the Physician Fee Schedule and Other Changes to 
Part B Payment Policies; Final Rule (86 FR 64996) (11/19/2021). Accessed at: 
https://www.govinfo.gov/content/pkg/FR-2021-11-19/pdf/2021-23972.pdf  
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries, Were More Likely Than Others To Use 
Telehealth During the First Year of the COVID-19 Pandemic 
OEI-02-20-00522                   Agency Comments B | 27 after the end of the PHE.3 CMS also proposed to extend the time that certain services are 
temporarily available as telehealth services, which will allow more time for collection of data 
that could support their eventual inclusion as permanent additions to the Medicare telehealth 
services list. 
CMS continues to evaluate the inclusion of telehealth services that were temporarily added to the 
Medicare telehealth services during the COVID-19 PHE and evaluate opportunities to implement 
policies that advance health equity, drive innovation, and promote good fiscal stewardship for 
the Medicare program based on the telehealth flexibilities implemented during the PHE. 
The OIGs recommendations and CMS responses are below. 
OIG Recommendation  
The OIG recommends that CMS take appropriate steps to enable a successful transition from 
current pandemic-related flexibilities to well-considered, long-term policies for the use of 
telehealth for beneficiaries in urban areas and from the beneficiarys home.   
CMS Response  
Section 301 of the Consolidated Appropriations Act, 2022 temporarily expands the scope of 
telehealth originating sites to include any site in the United States where the beneficiary is 
located at the time of the telehealth service, including an individual's home, for 151 days after 
the end of the PHE for COVID-19. CMS has provided notice of its intent to issue program 
instruction or other subregulatory guidance to effectuate the changes to telehealth enacted in the 
Consolidated Appropriations Act, 2022 to ensure a smooth transition after the end of the PHE. 
The Presidents Fiscal Year (FY) 2023 Budget states that the Administration is committed to 
supporting a temporary extension of broader telehealth coverage under Medicare beyond the 
COVID-19 PHE declared by the Secretary to study its ability to promote proper use and access 
to care.4   
Additionally, as stated above, CMS has taken steps to implement policies consistent with 
changes in legislation that take effect after the COVID-19 PHE ends, such as expanding the 
originating sites at which a beneficiary may be located for mental health telehealth services. In 
implementing these statutory changes, CMS also established a policy to allow mental health 
services to be furnished via telehealth using audio-only telecommunications technology in 
certain circumstances. We will continue to implement policies consistent with our authority, 
however, further legislative change may be necessary to implement this recommendation.  
OIG Recommendation  
The OIG recommends that CMS temporarily extend the use of audio-only telehealth services and 
evaluate their impact.  
CMS Response 
Section 305 of the Consolidated Appropriations Act, 2022 extends the flexibilities related to 
furnishing certain telehealth services using audio-only telecommunications technology for 151 
3 Medicare Program; Calendar Year 2023 Payment Policies under the Physician Fee Schedule and Other Changes to 
Part B Payment Policies; Proposed Rule (87 FR 45860) (07/29/2022). Accessed at: 
https://www.govinfo.gov/content/pkg/FR-2022-07-29/pdf/2022-14562.pdf  
4 Department of Health and Human Services Fiscal Year 2023 Budget in Brief. Accessed at: 
https://www.hhs.gov/sites/default/files/fy-2023-budget-in-brief.pdf 
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries, Were More Likely Than Others To Use 
Telehealth During the First Year of the COVID-19 Pandemic 
OEI-02-20-00522                   Agency Comments B | 28 days after the end of the COVID-19 PHE. The Presidents Fiscal Year (FY) 2023 Budget states 
that the Administration is committed to supporting a temporary extension of broader telehealth 
coverage under Medicare beyond the COVID-19 PHE declared by the Secretary to study its 
ability to promote proper use and access to care.   
Additionally, as stated above, CMS has taken steps to implement policies consistent with 
changes in legislation that take effect after the COVID-19 PHE ends, such as expanding the 
originating sites at which a beneficiary may be located for mental health telehealth services. In 
implementing these statutory changes, CMS also established a policy to allow mental health 
services to be furnished via telehealth using audio-only telecommunications technology in 
certain circumstances. We will continue to implement policies consistent with our authority, 
however, further legislative change may be necessary to implement this recommendation. 
OIG Recommendation  
The OIG recommends that CMS require a modifier to identify all audio-only telehealth services 
provided in Medicare.  
CMS Response 
In the Calendar Year 2023 Physician Fee Schedule proposed rule we proposed that beginning 
January 1, 2023, a physician or other qualified health care practitioner billing for telehealth 
services furnished using audio-only communications technology shall append CPT modifier 93 
(Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive 
Audio-Only Telecommunications System) to Medicare telehealth claims for those services for 
which the use of audio-only technology is permitted under  410.78(a)(3), to identify them as 
having been furnished using audio-only technology. We will take the feedback received from the 
public comment period, as well as the OIGs recommendation, into consideration as we 
determine appropriate next steps.   
OIG Recommendation 
The OIG recommends that CMS use telehealth to advance health care equity. 
CMS Response 
CMS is committed to advancing health equity for people with Medicare through operations and 
policies in the Traditional Medicare, Medicare Advantage and Part D programs, ensuring that 
services are culturally and linguistically appropriate, care is high-value and person-centered, 
underserved communities have access to quality care, disparities are eliminated, and social needs 
are addressed.  
As stated above, we continue to evaluate opportunities to advance health equity, drive 
innovation, and promote good fiscal stewardship for the Medicare program based on the 
telehealth flexibilities implemented during the PHE and will continue to implement policies 
consistent with our authority. 
CMS has provided education to assist individuals with Medicare in accessing telehealth. For 
example, CMS has provided information about telehealth to individuals with Medicare in the 
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries, Were More Likely Than Others To Use 
Telehealth During the First Year of the COVID-19 Pandemic 
OEI-02-20-00522                   Agency Comments B | 29 Medicare & You Handbook, Medicare.gov, and through social media.5, 6 CMS has also published 
a Coverage to Care Telehealth Toolkit which includes general information about types of care 
individuals can receive through telehealth, how to prepare for an appointment, what to expect 
during a visit, and more.7 The Coverage to Care Telehealth Toolkit is available in eight 
languages. CMS will continue to provide education to individuals with Medicare regarding their 
options for receiving services via telehealth as appropriate.  
5 Medicare & You 2022. Accessed at: https://www.medicare.gov/media/10991  
6 Medicare.Gov. Accessed at: https://www.medicare.gov/coverage/telehealth 
7 Telehealth: What To Know For Your Family. Accessed at: https://www.cms.gov/About-CMS/Agency-
Information/OMH/equity-initiatives/c2c/consumer-resources 
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic Beneficiaries, Were More Likely Than Others To Use 
Telehealth During the First Year of the COVID-19 Pandemic 
OEI-02-20-00522                   Agency Comments B | 30  
ACKNOWLEDGMENTS AND CONTACT  
 
Acknowledgments  
Vincent Greiber served  as the team leader for this study.  Others in the Office of  
Evaluation and Inspections who  conducted the study include Aaron Plotke and John 
Gordon.  Office of  Evaluation and Inspections staff who  contributed to the  study  
include Miriam Anderson,  Robert Gibbons, and Michael Novello.  
This report was prepared under the direction of  Jodi Nudelman, Regional  Inspector  
General for  Evaluation and Inspections in the New York regional office, and Nancy  
Harrison and  Meridith Seife, Deputy Regional Inspectors  General.   
Contact  
To obtain additional information concerning this report, contact the Office of Public  
Affairs at  Public.Affairs@oig.hhs.gov.  OIG reports and other information can be found  
on the OIG website at  oig.hhs.gov.  
Office of  Inspector General  
U.S. Department of Health and Human Services  
330 Independence Avenue, SW  
Washington, DC 20201  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Data Brief: Certain Medicare  Beneficiaries, Such as Urban and Hispanic Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Acknowledgments and Contact  | 31   ENDNOTES  
 
 
1  HHS and CMS  were able to temporarily expand access to telehealth because of their waiver authority under section 1135  of  
the Social Security Act, subsequent legislation, and the Secretarys declaration of a public health emergency due to  
COVID-19.   The public health emergency was announced on January 31, 2020.   See HHS, Determination that a Public Health  
Emergency Exists, January 31, 2020, accessed at https://www.phe.gov/emergency/news/healthactions/phe/Pages/2019-
nCoV.aspx  on April  8, 2022.   See also Coronavirus Preparedness and Response Supplemental Appropriations  Act of 2020,  
accessed at  https://www.congress.gov/bill/116th-congress/house-bill/6074/text/rds  on November 23, 2021.   See also Families  
First Coronavirus Response Act, accessed at  https://www.congress.gov/bill/116th-congress/house-bill/6201/text  on April 15,  
2022.   See also CARES Act, accessed at  https://www.congress.gov/bill/116th-congress/house-bill/748/text  on November 23,  
2021.  
2  OIG,  Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First  Year of the COVID-19 Pandemic,  
OEI-02-20-00520, March 2022.   
 
3  OIG,  Telehealth Was  Critical for Providing Services to Medicare Beneficiaries During the First  Year of the COVID-19 Pandemic,  
OEI-02-20-00520, March 2022; OIG,  Most Medicare beneficiaries received telehealth services only from providers with whom they  
had an  established relationship,  OEI-02-20-00521,  October 2021;  OIG,  Medicare Telehealth Services During the First  Year of  the  
Pandemic: Program Integrity Risks, OEI-02-20-00720,  September  2022; Pandemic  Response Accountability Committee,  
Telehealth Services in Select Federal Health Care Programs, OEI-02-22-00150, forthcoming.  
4  These beneficiaries did not use any audio-video telehealth services during this time period.  They may have used in-person  
services.  
5  For the purposes  of this report, we refer to the services that  can be delivered either via telehealth or in-personas well as  
services that are always provided remotelyas telehealth services.    
6  These services are also referred to as communication technology-based services.  For the purposes of this report, we refer to  
them as virtual care services.  CMS does not include communication technology-based services in its formal definition of  
telehealth services.  
7  For example, prior to the  pandemic, beneficiaries  were allowed to  use virtual care services as well as telehealth  services to  
address  substance use  disorder or end-stage renal disease  from home  and in urban areas.   In addition, beginning in 2020,  
Medicare Advantage plans were able to allow their beneficiaries to use  telehealth services  from  home  and in urban areas.  
8  For the purposes of this study, we included the telehealth services approved for payment by Medicare as of  February 28,  
2021.    
9  Prior to the pandemic, beneficiaries could receive certain virtual care services, such as virtual check-ins, through audio-only.  
10  OIG,  Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First  Year of the COVID-19 Pandemic,  
OEI-02-20-00520, March 2022.  
 
11  Beneficiaries residing within a Metropolitan Statistical Area were classified as urban; all others were classified as rural.   See 
the methodology for more information.   
12  Prior to the pandemic, beneficiaries living in urban areas were allowed to use virtual care services as well as telehealth  
services to  address substance  use  disorder or end-stage renal disease.  In addition,  beginning in 2020,  Medicare Advantage  
plans were able to allow  their  beneficiaries to use telehealth  services in urban areas.  
 
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic  Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Endnotes | 32    
13  According to a 2019 report, the Federal Communications Commission estimated that 26  percent of  rural residents did  not  
have access to broadband internet service,  while 1.7 percent  of urban residents also did not have access in  2017.  Accessed at 
https://docs.fcc.gov/public/attachments/FCC-19-44A1.pdf  on December 17, 2020.  
14  OIG,  States Reported Multiple Challenges With Using Telehealth To Provide  Behavioral Health Services to Medicaid Enrollees,  
OEI-02-19-00400, September 2021.  
15  Prior to the pandemic, beneficiaries using telehealth services to address  substance use disorder or end-stage renal disease,  
as well as beneficiaries using virtual care services, were allowed to receive services  from home.   In addition, beginning in 2020,  
Medicare  Advantage plans were able to allow their beneficiaries to receive services  from home.  
16  For  more information about how beneficiaries become eligible for both Medicare and Medicaid, see Medicaid and CHIP  
Payment and Access Commission,  Eligibility: Dually Eligible Beneficiaries, accessed at  https://www.macpac.gov/subtopic/dually-
eligible-beneficiaries-eligibility/  on February 22, 2021.   For information about the health status of dually eligible beneficiaries,  
see CMS,  People Dually Eligible for Medicare and Medicaid, accessed at  https://www.cms.gov/Medicare-Medicaid-
Coordination/Medicare-and-Medicaid-Coordination/Medicare-Medicaid-Coordination-
Office/Downloads/MMCO_Factsheet.pdf  on December 17, 2020.   Also see CMS,  Medicare-Medicaid Coordination Office FY  2019  
Report to Congress, accessed at  https://www.cms.gov/files/document/mmco-report-congress.pdf  on December 17, 2020.  
17  This analysis uses the race and ethnicity information from Medicares enrollment database, which is based on data collected 
from the Social Security Administration and an algorithm.   Note that information for beneficiaries identified as American  
Indian/Alaska Native, Other, Unknown, or that had missing race and ethnicity  data are not included because of limitations with  
the data.  Furthermore, although Hispanic is an ethnicity, Medicares data combine race and ethnicity and limit beneficiaries to  
one category.  Although this information is currently the best available for the entire Medicare beneficiary population,  
comparisons to self-reported data (available in certain, limited circumstances) show that race and ethnicity is still misclassified 
for some beneficiaries.   In particular, Medicare beneficiaries with a race and ethnicity of American Indian/Alaska Native,  
Asian/Pacific Islander, or Hispanic are more likely to be misclassified.   For further discussion on these topics, see OIG,  
Inaccuracies in Medicares Race and Ethnicity Data Hinder the  Ability To Assess Health Disparities, OEI-02-21-00100,  June 2022.  
18  Three of these codes are telephone evaluation and management codes (99441, 99442,  99443) and the other three  are 
telephone assessment and management codes (98966, 98967,  98968).  
19  CMS does not distinguish between audio-only and audio-video for these 86 services.  In addition, Medicare Advantage plans  
can offer supplemental telehealth benefits that may include audio-only services that cannot be identified in the data.   
Furthermore, effective January 1, 2022, CMS will require providers to use a modifier to identify audio-only services for the 
treatment of certain mental health conditions.  See  Medicare Learning Network CY2022 Telehealth Update Medicare Physician  
Fee Schedule, accessed at  MM12549 -CY2022 Telehealth Update Medicare Physician Fee Schedule (cms.gov)  on February  1,  
2022.  See also 86 FR 64996 (November  19, 2021).    
20  These beneficiaries did not use any audio-video telehealth services during this time period.  They may have used in-person  
services.  
21  OIG,  Telehealth Was Critical for  Providing Services to Medicare Beneficiaries During the First  Year of the COVID-19 Pandemic,  
OEI-02-20-00520, March 2022.  
22  Prior to the pandemic, there were limited  circumstances in  which Medicare  beneficiaries could access telehealth services in  
urban areas,  from home, and through audio-only.   
23  On  November 19, 2021, CMS expanded access to telehealth  services to treat mental health conditions for beneficiaries in  
Medicare fee-for-service.   This expansion  allows beneficiaries  in urban areas and those seeking care from home to access  
telehealth services that treat mental health conditions.  See 86 FR 64996 (November 19, 2021).   In addition, the Consolidated 
Appropriations Act of 2022 extends most telehealth flexibilities for 151 days after the public health emergency expires.  See  
Consolidated Appropriations Act, 2022,  accessed at  https://www.congress.gov/bill/117th-congress/house-bill/2471  on 
March  22, 2022.  
 
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic  Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Endnotes | 33    
24  OIG,  Medicare Telehealth Services During the First  Year of the  Pandemic: Program Integrity Risks, OEI-02-20-00720,  September  
2022.  
25  This is similar to a recommendation made by the Medicare  Payment Advisory Commission.   See Medicare Payment Advisory  
Commission,  March 2021 Report to the Congress:  Medicare Payment Policy, accessed at  March 2021 Report to the Congress:  
Medicare Payment Policy    MedPAC  on September 15, 2021.   
26  CMS expanded access to audio-only telehealth services to  treat mental health conditions for beneficiaries in Medicare fee-
for-service after the public health emergency expires.  See 86 FR 64996 (November 19, 2021).  The Consolidated  
Appropriations Act of 2022 also extends the use of audio-only telehealth services for 151 days after the public health 
emergency expires.  See Consolidated Appropriations Act, 2022, accessed at  https://www.congress.gov/bill/117th-
congress/house-bill/2471  on March 22, 2022.  
27  See Medicare Payment Advisory Commission,  March 2021 Report to the Congress: Medicare  Payment Policy, accessed at  
March 2021 Report to the Congress: Medicare Payment Policy    MedPAC  on September 15, 2021.  
28  Along with its permanent expansion of audio-only telehealth services for  mental health conditions, CMS implemented a 
periodic in-person requirement through which a beneficiary is required to see a provider in person within 6 months prior to  
their initial audio-only visit and within 12 months for subsequent audio-only visits, with certain exceptions.  This in-person 
requirement applies to audio-video and audio-only telehealth services  for  mental health conditions.  The Consolidated 
Appropriations Act, 2022 delayed implementation of the required in-person visits until 152 days after the end of the  public  
health  emergency.  
29  Effective January 1, 2022, CMS requires  providers to use a modifier to identify audio-only services for the treatment of  
mental health conditions.  See Medicare Learning Network CY2022 Telehealth Update Medicare Physician Fee Schedule,  
accessed at  MM12549 -CY2022 Telehealth Update Medicare  Physician Fee Schedule (cms.gov)  on February 1, 2022.  See also  
86 FR 64996 (November 19, 2021).    
30  The Medicare Payment Advisory Commission, in its  March 2022 Report to the Congress: Medicare Payment Policy, also  
recommended CMS require that providers use a claims modifier to identify all audio-only telehealth services.  Report accessed  
at  MedPAC March 2022 Report to the Congress  on March 22, 2022.     
31  See CMS fact sheet accessed  at  https://www.cms.gov/files/document/health-equity-fact-sheet.pdf  on April 22, 2022.   
32  OIG,  Most Medicare beneficiaries received telehealth services only from providers with whom they had an established 
relationship, OEI-02-20-00521, October 2021; OIG,  Telehealth Was Critical for Providing Services to Medicare Beneficiaries 
During the First Year of the COVID-19 Pandemic, OEI-02-20-00520, March 2022; OIG,  Medicare Telehealth Services During the  
First Year of the Pandemic: Program Integrity Risks,  OEI-02-20-00720,  September  2022.  
 
33  The codes used in the analysis for this data brief include those on the list available on the CMS website as of February  28,  
2021, which can be found at https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-
Codes.   These codes also include the communication technology-based services  that were allowed during the first year of the  
pandemic.   See 85  F.R. 19230 (April 6, 2020) and 85 F.R.  84472 (December 20, 2020).  
34  All virtual care service codes  were considered as being provided via telehealth as they can  only be provided remotely.   
35  CBSAs are comprised of Metropolitan Statistical Areas, Micropolitan Statistical Areas, and non-CBSAs.  A Metropolitan  
Statistical Area is an urbanized area of 50,000 or more people.  A Micropolitan Statistical Area is an urbanized cluster of at least  
10,000 people but less than 50,000 people.   
36  For this analysis, we reviewed claims submitted by individual professionals and institutions.  If a beneficiarys claims did not  
include an originating site facility fee and the beneficiary had received at least one  telehealth service, we considered that  
beneficiary to have used telehealth from home or a non-health-care setting.    
37  Medicare data combines race and ethnicity and limits beneficiaries to one category.  
 
Data Brief: Certain Medicare Beneficiaries, Such as Urban and Hispanic  Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Endnotes | 34    
38  We determined enrollment based on beneficiaries enrolled in Medicare fee-for-service or  Medicare Advantage as of  
February 28, 2021.    
39  These beneficiaries  did not use any audio-video telehealth services  during this time period.  They may have used in-person  
services.   
40  For  further discussion on these topics, see OIG,  Inaccuracies  in Medicares Race  and Ethnicity Data Hinder the Ability To Assess 
Health Disparities, OEI-02-21-00100,  June 2022.   
Data Brief:  Certain Medicare Beneficiaries, Such as Urban and Hispanic  Beneficiaries,  Were More Likely Than Others  To  Use  
Telehealth During the First Year of the COVID-19 Pandemic  
OEI-02-20-00522   Endnotes | 35