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AB 744, the telehealth reimbursement law that took effect in 2021, prohibits insurance plans from doing the following:
Unfortunately, AB 744 does not prohibit plans from requiring providers to be credentialed and trained in the use of telehealth and providers should, therefore, check-in with the health plans they are contracted with to determine the plan’s policies regarding the use of telehealth.
For more information about AB 744, see CAMFT’s Article, Updates and Resources for Providers Navigating Managed Care in California.
Billing Telehealth Sessions Providers are encouraged to check with their plans regarding policies, requirements, and billing codes related to the provision of psychotherapy via telehealth. Plans vary in which CPT code modifier they are accepting to indicate a psychotherapy session was conducted via telehealth. Some plans are accepting the modifier “GT,” “95”, or either, and some plans do not need a modifier. For example, some plans are accepting 90834 with modifier 95 for individual psychotherapy via telehealth. Additionally, the place of service code (POS) for telehealth is 10 (Patient is located in their home when receiving health services through telecommunication technology).
Provider Address for Telehealth-Only Practices State provider directory laws require health plans and health insurers to publish and maintain online and printed provider directories with information about contracting providers who offer services to their enrollees or insureds. Providers who maintain telehealth-only practices out of their homes and wish to keep their home addresses private, should be aware of, and prepared to cite, the Uniform Provider Directory Standards.
With regard to provider directory displays of provider information, subsection (c)(7) of the standards states:
“Practice addresses and practice locations must be listed consistent with United States Postal Service conventions. "If health care services are provided only in a patient’s home, or through telehealth services, this should be clearly noted and a practice address does not need to be listed.”
This provision means that while health plans and health insurers have a right to obtain providers’ practice addresses, plans and insurers are not required to include those addresses as part of the provider directory when providers are offering telehealth-only services. If providers are offering telehealth-only services, the standards simply require the plans and insurers to clearly state that fact within the provider directory.
These standards are set forth by the Department of Managed Health Care and the Department of Insurance in accordance with Health and Safety Code §1367.27(k).
For a complete discussion of provider directory law, see CAMFT article titled, “What Providers Need to Know About the Provider Directory Law.”
Providers who are contracted with Medi-Cal to provide services should be familiar with Medi-Cal's Telehealth Policy.
Essentially, providers performing services via telehealth for the Medi-Cal program must meet the following requirements: 1) be licensed in California; 2) be enrolled as a Medi-Cal rendering provider; and 3) be affiliated with an enrolled Medi-Cal provider group.
Documentation of Telehealth Services Clinicians should follow the same documentation requirements as for services provided in-person, keeping in mind California’s additional documentation requirements when providing care via telehealth. Providers should ensure they are billing for services delivered via telehealth using the appropriate CPT Code and modifier. Billing modifiers for telehealth depend on how services are rendered:
Provider Addresses Within the Medi-Cal system, the term “business address” means the location where an applicant or provider provides services, goods, supplies, or merchandise, directly or indirectly, to a Medi-Cal beneficiary. A post office box or commercial box (such as a virtual business address) is not a business address for purposes of providing care to Medi-Cal recipients. Information regarding acceptable provider business addresses comes from the Medi-Cal Provider Enrollment Regulations.
Types of Settings for Originating or Distant Sites Medi-Cal does not limit the type of setting where telehealth services may be provided (i.e., the originating site) or the type of setting where a provider must be located when rendering telehealth services (i.e., the distant site). Providers are, however, required to ensure and maintain patient privacy in any location from where they are delivering services.
Remote Service (Telehealth-Only) Providers Beginning March 29, 2023, Medi-Cal provider enrollment requirements and procedures will create exemptions from place of business requirements for mental-health providers who offer “remote-only” (I.e. telehealth-only) services.
The providers who may apply for enrollment as remote service-only (I.e. telehealth-only) providers include:
Providers who wish to be considered for enrollment in the Medi-Cal program must submit an application through PAVE, DHCS’s Provider Application and Validation Enrollment portal. The online application requires the submission of supporting documents and a signed Remote Services-Only attestation. For more information go to PED_Requirement and Procedures for Medi-Cal Enrollment of Providers Offering Services Remotely or Indirectly from their Business Address (PED_EPOB Exceptions). This information can also be found on the Provider Enrollment page of the Medi-Cal website.
To read more about the requirements under the Medi-Cal Telehealth Policy, click here.