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February 28, 2023
With the federal public health emergency remaining in effect until May 11, 2023, Medi-Cal providers remain subject to certain flexibilities. Providers should, however, re-familiarize themselves with the standard requirements when providing care to Medi-Cal recipients to be prepared once flexibilities lift later this year.
Telehealth Flexibilities Telehealth services should be reimbursed at the same rate as in-person services. Providers are encouraged to review Medi-Cal’s telehealth policy for additional information. Healthcare providers performing services via telehealth 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. Telehealth policy and billing information for Federally Qualified Health Centers (FQHCs), Rural Health Clinics (RHCs) and Indian Health Services (IHS) can be found in the Medi-Cal provider manuals for those settings.
Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)
Indian Health Services (IHS) Providers may establish relationships with new patients through synchronous (real-time) video telehealth (i.e., video teleconference) visits. Providers are also permitted to establish relationships with new patients through audio-only (i.e., telephone-only) synchronous (real-time) interaction if one or more of the following circumstances applies:
Consent for Telehealth Before conducting telehealth services, providers must inform the patient about the use of telehealth and obtain verbal or written consent from the patient for the use of telehealth. Consent must be documented in the patient’s record and be available to DHCS upon request. Providers must also document when a patient consents to audio-only services before delivering those services. Providers are required to share the following information with their Medi-Cal patients:
Note: The requirements for consent for telehealth services are found in Business and Professions Code, Section 2290.5(b) and Welfare and Institutions Code Section 14132.725(d).
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.
Emergency Fee-For-Service Enrollment Ending Soon As of March 29, 2023, providers who were temporarily enrolled as Medi-Cal Fee-For-Service providers during the pandemic and wish to remain enrolled must submit an application and meet all program requirements.
Providers will be given a period of 90 days after March 29, 2023 to submit an application through PAVE, DHCS’s Provider Application and Validation Enrollment portal. Providers who fail to apply by June 27, 2023 will be disenrolled (I.e. no longer recognized as a Medi-Cal provider) as of June 28, 2023.
More information regarding requirements for temporary FFS providers can be found at Medi-Cal NewsFlash: Discontinuation of COVID-19 Emergency Fee-For-Service Medi-Cal Enrollment.
DHCS Telehealth Research and Evaluation Plan The California Department of Health Care Services (DHCS) continues to monitor the use and impact of telehealth throughout the Medi-Cal system. The Department’s Telehealth Research and Evaluation Plan, which describes those efforts, can be found at DHCS RE Plan (ca.gov).