Telehealth Updates During Statewide Shelter in Place

In an effort to reduce exposure to the coronavirus, health providers and our state government are working to move as much care as possible to remote services. 

FQHCs | School Medi-Cal | Behavioral Health Services | Tips for Telehealth | Confidentiality Requirements | Family PACT Providers

 

Federally Qualified Health Centers (FQHCs)

FQHCs can receive PPS Medi-Cal reimbursement for telephone (i.e. audio only) and telehealth (i.e. interactive audio and video platform) visits. This includes medical, behavioral health, and some dentistry services.

The CA Department of Health Care Services (DHCS) relaxed some restrictions on telehealth visits so that:

  • Providers may see enrolled and new patients;
  • Patients may receive services anywhere including in their home; and
  • Providers may provide services anywhere including in their home.

Reimbursement 

  • For existing billable providers and eligible services within the FQHC’s scope
  • At prospective payment system (PPS) rate
  • Using the same process as an in-person visit

Documentation Guidelines

  • Maintain appropriate documentation to substantiate the corresponding technical and professional components of billed CPT or HCPCS codes.
  • Documentation for benefits or services should be the same as for in-person visits.
  • Document patient’s and provider’s location, that the patient consented, and reason for telehealth visit.
Billing guidelines for Medi-Cal (for medical and behavioral health visits)

For telephone visits:

  • DHCS has instructed FQHCs to bill with: Revenue code 0521 + HCPC Code T1015 SE (for managed care) and T1015 (for Fee for Service) in the “payable claim” line
  • Providers should include the appropriate CPT code (i.e. 99201-99205 for “new patients” and 99211-99215 for “established” patients) on the “informational” line relative to the complexity of the telephonic communication 
  • Providers may also include appropriate CPT codes corresponding to services provided (e.g. psychotherapy codes) as additional informational line items

For telehealth (i.e. with video in real-time) visits

  • Billing is the same as face-to-face visits
  • Some providers have elected to note “telehealth” as an informational line item for their own tracking purposes
  • Do not include POS 2 or 95/GQ Modifier when billing DHCS for the wraparound or FFS. Some Medi-Cal Managed Care plans may require a POS and a modifier. Check with your sponsor agency and/or health plan.

FQHCs can see the DHCS Guidance and FAQ for Telehealth Visits dated March 24. 

School Medi-Cal

LEA Billing Option Program (Medicaid reimbursement for school-based health services) allows reimbursement for direct services provided via telehealth.

You can watch a recording of a training on telehealth policy relative to COVID-19 (password: eUskqfZ2) and download slides and Q&A from the training.

Behavioral Health Services

See the National Center for School Mental Health’s Telemental Health 101 webinar on YouTube.

Tips for Telehealth

The California Primary Care Association has a quick 7-minute video on YouTube: Quality Control in Video Conferencing.

Northwest Regional Telehealth Resource Center’s Quick Start Guide to Telehealth includes information about technology, sample workflow, and legal considerations.

Confidentiality Requirements

The state of emergency has prompted the federal and state governments to relax their enforcement against health care providers using HIPAA-compliant technology for telehealth.

  • Common HIPAA-compliant platforms: Cisco, doxy.me, GoToMeeting, Skype for Business, or Zoom
  • Allowable non-HIPAA compliant platforms: Apple FaceTime, Facebook Messenger video chat, Google Hangouts, WhatsApp and Skype
  • Not allowable platforms: any public-facing remote communication such as Facebook Live, Slack, Twitch, or TikTok

More information can be found on the U.S. Department of Health & Human Services website.

Family PACT Providers

DHCS has confirmed that Family PACT providers may utilize existing telehealth policies as an alternative modality for delivering Family PACT covered services when medically appropriate, as a means to limit patients’ exposure to others who may be infected with COVID-19, and to increase provider capacity.

This includes Client Enrollment and Re-Certification: FPACT providers may enroll and recertify clients through telehealth or other virtual/telephonic communication modalities. Please note that these temporary client enrollment and re-certification flexibilities are only in place during the COVID-19 emergency, and will end upon termination of the public health emergency.

FPACT providers may complete the Client Eligibility Certification (CEC) form (DHCS 4461) and Retroactively Eligibility Certification (REC) form, if applicable, on behalf of the applicant/client. Providers must obtain verbal consent to sign the form on behalf of the client and should note “Information and consent captured verbally by “(provider or designee’s name)” in the signature field on the CEC form (DHCS 4461) or REC form (DHCS 4001). A witness signature is not needed.

The CEC form (DHCS 4461) and a copy of the REC form (DHCS 4001) must be maintained in the client’s medical file.

The provider must arrange for the client to receive their HAP card/number to ensure a client has continued access to pharmacy, laboratory services, or other Family PACT covered benefits. Options may include, but are not limited to, in-person pick up of the HAP card or mailing the HAP card to the client’s address. If the HAP card is mailed to the client’s address, the provider must receive the express consent of the client to mail it, and must ensure that the address is verified.

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