As states begin to open and expand the availability of the various COVID vaccines, there still remains the fact that the rollout is based on a variety of factors, which can include certain medical morbidities and comorbidities.  From our discussions with people, it appears that the general proof requirements for getting an appointment are wide and varied, from merely checking a box making an attestation that the person meets the criteria, to having to provide a note from a healthcare professional indicating that the person has the condition upon presentation for the vaccine.  While this will facilitate getting the vaccine to the right people, in the right order, as with everything, fraud, waste and abuse opportunities will become prevalent.

Most recently, the broad latitude of access for telemedicine has created an immeasurable volume of fraud opportunities.  So to is the case with COVID vaccination eligibility documentation.  Some recent social media posts have identified that capitalization, where telemedicine companies are now advertising that they will prove you with the requisite documentation to support an appointment and ultimately, receipt of a COVID vaccination. 

In some advertisements, the telemedicine companies are indicating that a simple 15 minute virtual visit will provide the required time to facilitate receipt of that note.  For the desperate, those who want to get in the front of the line, or whatever the personal motivation, this has the ability of creating a money stream for this type of provider, that was not previously available.  As with many of these groups, the telemedicine provider may not have any prior interaction with the patient prior to the 15 minute visit.  As we have all seen with the genetic testing, pharmacy and durable medical equipment telemedicine schemes, we have to ask ourselves “is this any different?” In some respects, it is as the telemedicine doctor is actually billing either the patient or the insurance for the 15 minute visit, whereas in the traditional telemedicine frauds, that patient interaction either does not exist, or is not a billable event.  In another sense, it does beg the question of how many of the patients that have these visits are denied the documentation to substantiate the early vaccination.  If the patient truly has a medical condition that provides that early access, would it not then also beg the follow up question that if a person has such a condition, are they not already under the care of a healthcare provider and can get the same documentation from their healthcare provider (and likely would be able to get it without the need for an office visit, in person, or virtual)? 

When we talk to our retired OIG agents about this, there is the typical eye roll that comes along with the phrase “it doesn’t pass the OIG stink test.”  Although that is not any measure of fraud, these people are well trained, knowledgeable of fraud schemes and have a mindset that works a bit differently.  Is it fraud?  Maybe not, but it certainly does open the discussion.