U.S. Department of Health and Human Services 
Office of Inspector General 
Data  Brief 
March 2022, OEI-02-20-00520 
 
Telehealth Was Critical for Providing Services to Medicare 
Beneficiaries 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  Over 28 million Medicare  Medicare beneficiaries accessed health care.  In response, the 
beneficiaries used  Department of Health and Human Services (HHS) and the Centers for 
telehealth during the first  Medicare & Medicaid Services (CMS) took a number of actions to 
year of the pandemic.  This  temporarily expand access to telehealth for Medicare beneficiaries.1 
was more than 2 in 5  CMS allowed beneficiaries to use telehealth for a wide range of 
Medicare beneficiaries.  
services; it also allowed beneficiaries to use telehealth in different 
o  Beneficiaries used 88 times  locations, including in urban areas and from the beneficiarys home.   
more telehealth services 
Understanding the use of telehealth during the first year of the 
during the first year of the 
pandemic can shed light on how the temporary expansion of 
pandemic than they used in 
telehealth affected where and how beneficiaries accessed their health 
the prior year. 
care.  This information can help CMS, Congress, and other stakeholders 
o  Beneficiaries use of 
make decisions about how telehealth can be best used to meet the 
telehealth peaked at the 
needs of beneficiaries in the future.  
beginning of the pandemic 
and remained high through 
This data brief provides insight into the use of telehealth in both 
early 2021. 
Medicare fee-for-service and Medicare Advantage during the first year 
o  Beneficiaries most  of the COVID-19 pandemic.  It is a companion to a report that 
commonly used telehealth  examines the characteristics of beneficiaries who used telehealth 
for office visits during the  during the pandemic.2  Another report in this series identifies program 
first year of the pandemic.  integrity concerns related to telehealth during the pandemic.3 
How OIG Did This Review 
We based this analysis on Medicare fee-for-service claims data and Medicare Advantage encounter 
data from March 1, 2020, to February 28, 2021, and from the prior year, March 1, 2019, to February 
29, 2020.  We used these data to determine the total number of services used via telehealth and in-
person, as well as the types of services used.  We also compared the number of services used via 
telehealth and in-person during the first year of the pandemic to those used in the prior year.  
What OIG Found 
Over 28 million Medicare beneficiaries used telehealth during the first year of the pandemic.  This was 
more than 2 in 5 Medicare beneficiaries.  In total, beneficiaries used 88 times more telehealth services 
during the first year of the pandemic than they used in the prior year.  Beneficiaries use of telehealth 
peaked in April 2020 and remained high through early 2021.  Overall, beneficiaries used telehealth to 
receive 12 percent of their services during the first year of the pandemic.  Beneficiaries most commonly 
used telehealth for office visits, which accounted for just under half of all telehealth services used during 
  the first year of the pandemic.  However, beneficiaries use of telehealth for behavioral health services 
stands out.  Beneficiaries used telehealth for a larger share of their behavioral health services compared 
to their use of telehealth for other services.  Specifically, beneficiaries used telehealth for 43 percent of 
behavioral health services, whereas they used telehealth for 13 percent of office visits.  
What OIG Concludes 
Telehealth was critical for providing services to Medicare beneficiaries during the first year of the 
pandemic.  Beneficiaries use of telehealth during the pandemic also demonstrates the long-term 
potential of telehealth to increase access to health care for beneficiaries.  Further, it shows that 
beneficiaries particularly benefited from the ability to use telehealth for certain services, such as 
behavioral health services.  These findings are important for CMS, Congress, and other stakeholders to 
take into account as they consider making changes to telehealth in Medicare.  For example, CMS could 
use these findings to inform changes to the services that are allowed via telehealth on a permanent basis.  
 
 
 
 
 
 
 
 
 
 
   
 
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.  
    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.4  
    During the pandemic, CMS increased the types of services that beneficiaries 
could use via telehealth, from 118 to 264 services.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 telehealth services known as virtual care services are always 
provided remotely.6  An example of these services includes a telephone call 
 
with a provider to discuss a beneficiarys medical condition.  
  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.7 
 
4567 
 
 
 
 
 
 
 
 
 
 
 
 
 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  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; it also allowed 
beneficiaries to use telehealth in different locations, including in urban areas and 
from the beneficiarys home.   
This data brief examines the use of telehealth services from March 2020 through 
February 2021.  It also looks at the growth of telehealth services, the extent to which 
beneficiaries also used in-person services, and the types of telehealth services most 
commonly used.  It includes beneficiaries in Medicare fee-for-service and in Medicare 
Advantage. 
Understanding the use of telehealth during this time can shed light on how the 
temporary expansion of telehealth affected where and how beneficiaries accessed 
their health care.  This information can help CMS, Congress, and other stakeholders 
make decisions about how telehealth can be best used to meet the needs of 
beneficiaries in the future.     
Over 28 million Medicare beneficiaries used telehealth during 
the first year of the pandemic 
More than 28 million Medicare beneficiaries used a telehealth service during the first 
year of the pandemicfrom March 2020 
through February 2021.  These beneficiaries 
More than 2 in 5 Medicare 
represented 43 percent of the 66 million 
beneficiaries used telehealth 
beneficiaries enrolled in Medicare, or about 
during the first year of the pandemic 
2 in 5 Medicare beneficiaries.   
 
This is a dramatic increase from the prior year, 
when less than 1 percent of Medicare 
 
beneficiariesapproximately 341,000 in 
totalused telehealth.  
During the first year of the pandemic, more than half of beneficiaries (55 percent) who 
used telehealth used only 1 to 2 services, while the remainder used 3 or more 
telehealth services.  Further, almost all beneficiaries who used telehealth during the 
first year of the pandemic also used in-person services.   
In addition, 84 percent of beneficiaries who used telehealth during the pandemic 
received telehealth services only from providers with whom they had an established 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Results | 4   
relationship.8  These beneficiaries received an in-person service from a provider an 
average of 4 months prior to their first telehealth service. 
Overall, beneficiaries enrolled in Medicare Advantage were more likely to use 
telehealth than those in Medicare fee-for-service.  In total, 49 percent of beneficiaries 
enrolled in Medicare Advantage used telehealth, compared to 38 percent of those 
enrolled in Medicare fee-for-service.  Prior to the pandemic, Medicare Advantage had 
greater flexibility to provide telehealth services to beneficiaries.9  
Beneficiaries used 88 times more telehealth services during the 
first year of the pandemic than they used in the prior year 
Medicare beneficiaries used 114.4 million telehealth services from March 2020 
through February 2021.  This amounts to 88 times more telehealth services compared 
to the year prior to the pandemic, 
when beneficiaries used 1.3  Medicare paid over $5.1 billion for 
million telehealth services.   telehealth services for beneficiaries enrolled 
in Medicare fee-for-service during the first 
Over half of these telehealth  year of the pandemic. 
services (60.1 million in total) were   
used by beneficiaries enrolled in Medicare fee-for-service.  In total, Medicare paid 
over $5.1 billion for these services, 76 times more than what it paid for telehealth in 
the prior year.10 
CMSs temporary policy changes enabled the monumental growth in the use of 
telehealth in multiple ways.  CMS allowed beneficiaries to use telehealth services from 
home and from any geographic location, including urban areas, beginning in March 
2020.11  In addition, CMS temporarily expanded the types of services that could be 
provided via telehealth.  Specifically, CMS allowed for 264 services to be provided via 
telehealth during the pandemic, compared to 118 services prior to the pandemic.   
Beneficiaries use of telehealth peaked at the beginning of the 
pandemic and remained high through early 2021 
Telehealth use peaked in the early months of the pandemic.  At the height of 
telehealth use in April 2020, beneficiaries used 17.6 million telehealth services, 
followed by 13.6 million telehealth services in May 2020.  In these early months, some 
States and localities had issued stay-at-home orders and some health care providers 
suspended in-person care because of increasing COVID-19 infection rates.
From June through November 2020, the number of telehealth services steadily 
decreased to 7.8 million services in November.  In December 2020, telehealth services 
increased slightly, before declining again in February 2021.  Despite the decline, the 
number of telehealth services in February 2021 was almost twice as high as in 
March 2020.  See Exhibit 1. 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Results | 5   
 
Even though telehealth use increased dramatically, beneficiaries 
still received most of their care in-person 
Even though the use of telehealth increased substantially during the pandemic, 
telehealth accounted for 12 percent of all services used by beneficiaries during the 
first year of the pandemic.12   
However, not all months were the same.  At the peak of telehealth use in April 2020, 
telehealth accounted for 29 percent of all services.  In most other months, 
beneficiaries used telehealth for 9 to 11 percent of all services.  See Exhibit 2.
 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Results | 6   
 
Despite the significant increase in telehealth, beneficiaries used  
fewer services overall during the first year of the pandemic than 
they did in the prior year 
Despite a large increase in the use of telehealth, beneficiaries used fewer services 
overall during the first year of the 
pandemic than they did in the prior year.  
Beneficiaries use of telehealth only 
partially filled the gap left by a decrease 
in in-person services during the 
pandemic.   
In total, beneficiaries used 20 percent 
fewer services, amounting to 990 million 
services during the pandemic, down from 
1.2 billion services the year prior.  See 
Exhibit 3.  The decrease in services is 
likely because of some health care 
providers temporarily suspending in-
person care, beneficiaries forgoing care 
because of concerns about community 
spread of COVID-19, and the strain on 
providers to offer needed services related 
to COVID-19, among other factors.13
 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Results | 7   
Beneficiaries most commonly used telehealth for office visits 
during the first year of the pandemic 
From March 2020 through February 2021, beneficiaries most commonly used 
telehealth for office visits, virtual care services, behavioral health services, nursing 
home visits, and preventive services.  Beneficiaries also used telehealth for a wide 
variety of other services.  See Appendices A and B for more information about these 
services and the extent to which beneficiaries used telehealth for these services.  
During the first year of the pandemic, beneficiaries most often used 
54.5 million 
telehealth for office visits.  These are routine appointments with a 
Office visits 
primary care provider or specialist.  In total, beneficiaries received 
54.5 million office visits via telehealth.  These office visits accounted 
for just under half (48 percent) of all telehealth services used during 
  the first year of the pandemic.  This percentage was similar for 
beneficiaries in Medicare fee-for-service and Medicare Advantage. 
Next, beneficiaries most commonly used telehealth for virtual care 
34 million 
services, totaling 34 million of these services during the first year of 
Virtual care 
the pandemic.  These services, unlike most Medicare telehealth 
services 
services, can only be provided remotely.  The most common type of 
virtual care service is a telephone call with a provider to discuss a 
beneficiarys medical condition, referred to as a telephone evaluation 
and management service.  Beneficiaries used over 28 million of these 
services, accounting for a quarter of all telehealth services used 
 
during the first year of the pandemic.   
 
 
Other common virtual care services include discussions with a 
  provider of up to 10 minutes, known as virtual check-ins.14  Virtual 
  care services also include online interactions via a patient portal, 
  known as e-visits, and remote monitoring of a beneficiarys weight 
  or other vital statistics.  Beneficiaries in Medicare Advantage used 
  more virtual care services than beneficiaries in Medicare fee-for-
service, with these services accounting for 35 percent of all 
 
telehealth services in Medicare Advantage, compared to 25 percent 
 
in Medicare fee-for-service.  
Beneficiaries also commonly used telehealth for behavioral health 
14.1 million 
services, totaling 14.1 million services.  Behavioral health services 
Behavioral 
include individual therapy, group therapy, and substance use 
health 
disorder treatment, among others.  Beneficiaries in Medicare fee-for-
services 
service used more behavioral health services than those in Medicare 
Advantage, with these services accounting for 16 percent of all 
telehealth services in Medicare fee-for-service, compared to 
  9 percent in Medicare Advantage.
 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Results | 8   
Nursing home visits were the next most common telehealth service, 
3.3 million 
with beneficiaries using 3.3 million services during the first year of 
Nursing 
the pandemic.  Nursing home visits include initial and subsequent 
home visits 
visits from a provider with a beneficiary located in a nursing home 
that are conducted via telehealth.  These visits include discussions 
between a provider and beneficiary regarding a beneficiarys medical 
  condition, and nursing home discharge management services, 
  among others.  Nursing home visits were slightly more common 
among beneficiaries in Medicare fee-for-service (4 percent of 
 
services) than those in Medicare Advantage (2 percent of services).    
Beneficiaries also commonly used telehealth for preventive services, 
2.4 million 
totaling 2.4 million of these services during the first year of the 
Preventive 
pandemic.  Preventive services include annual wellness visits, 
services 
diabetes management training, medical nutrition therapy, and 
tobacco use counseling.  There was no difference in the use of these 
telehealth services between beneficiaries in Medicare fee-for-service 
and Medicare Advantage. 
 
Beneficiaries use of telehealth for behavioral health services 
stands out 
While beneficiaries used telehealth for a number of different services, beneficiaries 
use of telehealth for behavioral health services stands out.  Beneficiaries used 
telehealth for a larger share of their behavioral health services compared to their use 
of telehealth for other services.  Specifically, beneficiaries used telehealth for 
43 percent of all behavioral health services they received during the first year of the 
pandemic.  In contrast, they used telehealth for only 13 percent of all office visits they 
received during the first year of the pandemic.  See Exhibit 4 and Appendix C.    
Understanding which services beneficiaries use telehealth for, compared to their use 
of these services in-person, helps inform questions about how beneficiaries access 
their health care.  In particular, beneficiaries use of telehealth for behavioral health 
services relative to their use of these services in-person shows that beneficiaries 
benefited from the ability to use telehealth for these services.  This is further 
supported by literature prior to the pandemic that suggests the use of telehealth for 
behavioral health may improve access, especially for beneficiaries facing barriers to 
care.15 
 
 
 
 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Results | 9   
Exhibit 4: Beneficiaries used telehealth for a larger share of their behavioral 
health services compared to other services.           
  
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Results | 10   
CONCLUSION
 
 
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.   
Beneficiaries use of telehealth increased dramatically during the first year of the 
pandemic.  Over 28 millionmore than 2 in 5Medicare beneficiaries used 
telehealth services during the first year of the pandemic, from March 2020 through 
February 2021.  In total, beneficiaries used 88 times more telehealth services during 
the first year of the pandemic than they did in the prior year.  Beneficiaries use of 
telehealth was particularly high in April 2020, when it accounted for 29 percent of all 
services.  It then decreased to around 10 percent of services per monthstill almost 
twice the level it was in March 2020.   
In addition, beneficiaries most commonly used telehealth for office visits, but their use 
of telehealth for behavioral health services stands out.  Beneficiaries used telehealth 
for a larger share of their behavioral health services compared to their use of 
telehealth for other services. 
Telehealth was critical for providing services to Medicare beneficiaries during the first 
year of the pandemic.  Beneficiaries use of telehealth during the pandemic also 
demonstrates the long-term potential of telehealth to increase access to health care 
for beneficiaries.  Further, it shows that beneficiaries particularly benefited from the 
ability to use telehealth for certain services, such as behavioral health services.  These 
findings are important for CMS, Congress, and other stakeholders to take into 
account as they consider making changes to telehealth in Medicare.16  For example, 
CMS could use these findings to inform changes to the services that are allowed via 
telehealth on a permanent basis.   
These changes to telehealth need to balance concerns about access, quality of care, 
equity, and program integrity so that the benefits of telehealth are realized, and 
Medicare can best meet the needs of its beneficiaries.  OIG has additional evaluations 
and audits underway examining telehealth in Medicare to help further inform 
program policies and oversight.17
 
 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Conclusion | 11   
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.18 
We used the Medicare fee-for-service claims from the National Claims History File 
and Medicare Advantage encounters from Part C Encounter data.  We also used 
enrollment data for Medicare fee-for-service and Medicare Advantage from the 
Medicare Enrollment Database.   
Beneficiaries Use of Telehealth Services 
To conduct this analysis, we first identified the services that Medicare approved for 
telehealth during the pandemic.19  These services are described using Current 
Procedural Terminology (CPT) codes and Healthcare Common Procedure Coding 
System (HCPCS) 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 provided 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 provided 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 these modifiers 
or codes to be delivered in-person.20 
Using these data, we determined the number of beneficiaries who used telehealth 
services during the first year of the pandemic, from March 2020 through February 
2021.  We included beneficiaries who had at least one Medicare fee-for-service claim 
or Medicare Advantage encounter for a telehealth service during the first year of the 
pandemic. 
Next, we calculated the percentage of beneficiaries enrolled in Medicare fee-for-
service or Medicare Advantage who used telehealth.  We determined the number of 
beneficiaries enrolled in each program based on Medicare enrollment data.21  
 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Methodology | 12   
We also calculated the number of services each beneficiary used during the first year 
of the pandemic. 
Use of Telehealth and In-Person Services 
Using both Medicare fee-for-service claims data and Medicare Advantage encounters, 
we determined the extent to which the use of telehealth services changed during the 
first year of the pandemic.  We calculated the number of telehealth services 
beneficiaries used in each month, as well as the total number of telehealth services 
used.   
We also calculated the total amount paid by Medicare for telehealth services during 
the first year of the pandemic and compared that amount to the total Medicare 
payments for telehealth services in the prior year.22  Payment amounts are for 
beneficiaries in Medicare fee-for-service only; payment amounts are unavailable in the 
Medicare Advantage encounters. 
We also calculated the number of in-person services used during the first year of the 
pandemic and compared this to the number of telehealth services provided.  We then 
compared the total number of services used during the first year of the pandemic to 
the total number of services used in the prior year.   
Most Common Telehealth Services 
We grouped each service into a category based on CMSs service classification system 
and CPT codes.23  To determine the most common services that beneficiaries used via 
telehealth, we calculated the number of telehealth services in each category.  We also 
calculated the proportion of the services in each category that were provided via 
telehealth and in-person.  
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Methodology | 13   
APPENDIX A 
 
Examples of Medicare services that can be provided via telehealth 
 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Appendix A | 14   
APPENDIX B 
 
Beneficiaries most commonly used telehealth for office visits, virtual care 
services, and behavioral health services during the first year of the pandemic 
 
 
 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Appendix B | 15   
APPENDIX C 
 
Beneficiaries used telehealth to receive a larger share of their behavioral health 
services compared to their use of telehealth for other services during the first 
year of the pandemic       
 
 
 
 
 
 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic  
OEI-02-20-00520  Appendix C | 16  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 John Gordon and 
Aaron Plotke.  Office of Evaluation and Inspections staff who provided support include 
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: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Acknowledgments and Contact | 17   
ENDNOTES
 
 
1 HHS and CMS were able to expand the use of telehealth as a result of the declaration of a Public Health Emergency (PHE) and 
subsequent legislation, among other actions.  The PHE was announced on January 31, 2020 and was retroactively effective to 
January 27, 2020.  The Coronavirus Preparedness and Response Supplemental Appropriations Act of 2020 and the CARES Act 
allowed CMS to waive telehealth-related restrictions with a PHE declaration in place.  See Coronavirus Preparedness and 
Response Supplemental Appropriations Act of 2020, accessed at Text - H.R.6074 - 116th Congress (2019-2020): Coronavirus 
Preparedness and Response Supplemental Appropriations Act, 2020 | Congress.gov | Library of Congress on November 23, 
2021.  See also, CARES Act, accessed at Text - H.R.748 - 116th Congress (2019-2020): CARES Act | Congress.gov | Library of 
Congress on November 23, 2021. 
2 OIG, Certain Medicare Beneficiaries Were More Likely to Use Telehealth Than Others During the Pandemic, OEI-02-20-00522, 
forthcoming.  
3 OIG, Medicare Telehealth Services During the COVID-19 Pandemic: Program Integrity Risks, OEI-02-20-00720, forthcoming.  
Another related report looked at the extent to which beneficiaries received telehealth services from providers with whom they 
had an established relationship.  See OIG, Most Medicare Beneficiaries Received Telehealth Services Only from Providers with 
Whom They Had an Established Relationship, OEI-02-20-00521.  See also Pandemic Response Accountability Committee, 
Telehealth Services in Select Federal Health Care Programs, forthcoming. 
4 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 their home and in urban areas.  In addition, beginning in 
2020, beneficiaries enrolled in Medicare Advantage plans were allowed to use telehealth services in their homes and in urban 
areas.  
5 For the purposes of this study, we included the telehealth services approved for payment by Medicare as of February 28, 
2021.   
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. 
7 Prior to the pandemic, beneficiaries could receive certain virtual care services, such as virtual check-ins, through audio-only. 
8 See OIG, Most Medicare Beneficiaries Received Telehealth Services Only From Providers with Whom They Had an Established 
Relationship, OEI-02-20-00521, October 2021.   
9 For example, plans could provide services to beneficiaries in their homes and regardless of their geographic location.  See 84 
F.R. 15680 (April 16, 2019). 
10 Payment information is not available for beneficiaries enrolled in Medicare Advantage.   
11 Unlike Medicare fee-for-service beneficiaries enrolled in Medicare Advantage plans were allowed to receive telehealth 
services both from home and in urban areas as of January 1, 2020.  Further, beneficiaries using virtual care services, as well as 
those using telehealth for certain services such as substance use disorder treatment and end-stage renal disease, were able to 
receive these services from home and in urban areas prior to the pandemic. 
12 For the purposes of this report, we refer to all services as those approved services that were provided either via telehealth 
or in-person during the pandemic or in the prior year.   
13 See Centers for Disease Control and Prevention, Delay or Avoidance of Medical Care Because of COVID-19-Related Concerns 
 United States, June 2020, September 11, 2020.  Accessed at https://www.cdc.gov/mmwr/volumes/69/wr/mm6936a4.htm on 
 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Endnotes | 18   
 
February 9, 2022.  See also Commonwealth Fund, The Impact of the COVID-19 Pandemic on Outpatient Visits: A Rebound 
Emerges, May 19, 2020.  Accessed at https://www.commonwealthfund.org/publications/2020/apr/impact-covid-19-outpatient-
visits on February 18, 2022.   
14 Virtual check-ins can also include evaluation of video or images submitted by a beneficiary.  
15 See Medicare Payment Commission, Telehealth: Updates on use, beneficiary and clinician experiences, and other topics of 
interest, November 8, 2021.  Accessed at https://www.medpac.gov/wp-content/uploads/2021/09/Telehealth-MedPAC-Nov-
2021.pdf on December 8, 2021.  
16 For more information about the use of telehealth in Medicare during the COVID-19 pandemic, see CMS, Medicare 
Telemedicine Snapshot.  Accessed at https://www.cms.gov/medicare-telemedicine-snapshot on December 6, 2021.  
17 See the HHS-OIG Work Plan, which can be found at https://oig.hhs.gov/reports-and-publications/workplan/index.asp.  
18 See OIG, Certain Medicare Beneficiaries Were More Likely to Use Telehealth Than Others During the Pandemic, OEI-02-20-
00522, forthcoming.  See also, OIG, Medicare Telehealth Services During the COVID-19 Pandemic: Program Integrity Risks, OEI-
02-20-00720, forthcoming.   
19 The codes used in the analysis for this data brief include 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).  
20 All virtual care service codes were considered as being provided via telehealth as they can only be provided remotely. 
21 We determined enrollment based on beneficiaries enrolled in Medicare fee-for-service or Medicare Advantage as of 
February 28, 2021.   
22 This payment amount does not include amounts paid by, or on behalf of, beneficiaries, such as a deductible or co-payment. 
23 CMSs service classification system is known as the Restructured Berenson-Eggers Type of Service Classification System.  For 
more information see https://data.cms.gov/provider-summary-by-type-of-service/provider-service-classifications/restructured-
betos-classification-
system#:~:text=The%20Restructured%20BETOS%20Classification%20System,clinically%20meaningful%20categories%20and%2
0subcategories.&text=The%20RBCS%20will%20undergo%20annual,panel%20of%20researchers%20and%20clinicians.  
 
Data Brief: Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 
Pandemic 
OEI-02-20-00520  Endnotes | 19