Medi-Cal Expands Provider Reach Through Revised Telehealth Policy

The California Department of Health Care Services recently revised its Medi-Cal Provider Manual (the “Manual”) to permit additional flexibility for providers who wish to render health care services through telehealth. Medi-Cal defines telehealth as:

“The mode of delivering health care services and public health via information and communication technologies to facilitate the diagnosis, consultation, treatment, education, care management and self-management of a patient’s health care while the patient is at the originating site, and the health care provider is at a distant site.”

Telehealth now includes synchronous interactions as well as asynchronous store and forward transfers, which is the “transmission of a patient’s medical information from an originating site to the health care provider at a distant site without the presence of the patient.” The synchronous interaction must include a real-time, interactive, audio-video, or data telecommunication between the patient and provider. The revised Manual no longer places limitations on the distant and originating sites, allowing providers more flexibility in where and to whom they provide treatment through telehealth. Notably, documenting barriers to in-person visits and the cost effectiveness of telehealth is no longer required.

Providers who submit claims to Medi-Cal for services rendered through telehealth must be enrolled as Medi-Cal providers and be licensed in California. Additionally, they must maintain appropriate documentation consistent with in-person services to substantiate the billed CPT or HCPCS codes for services delivered through telehealth. The Manual also requires providers obtain and document either written or verbal consent from the patient to receive services through telehealth.

Medi-Cal will reimburse claims for covered services and benefits provided through telehealth subject to the appropriate CPT or HCPCS codes and modifiers. The Place of Service code 02 must be documented on submitted claims to indicate that services were provided through a telecommunications system. Furthermore, claims submitted for services or benefits provided through synchronous, interactive audio and telecommunications systems must be billed with modifier 95, whereas claims submitted for asynchronous store and forward telecommunications systems must be billed with modifier GQ.

California’s revision to its Medi-Cal Manual represents a significant deviation from current Medicare reimbursement requirements, and reinforces trends towards greater adoption of, and access to, telemedicine. For further details on the revised Manual, which significantly expands providers’ ability to render healthcare services through telehealth in California, contact Frier Levitt today.