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  • Alex Lipovtsev

Comprehensive Guidance Regarding Use of Telehealth including Telephonic Services During COVID-19

Updated (3/24/2020)

The intent of this guidance is to provide broad expansion for the ability of all Medicaid providers in all situations to use a wide variety of communication methods to deliver services remotely during the COVID-19 State of Emergency, to the extent it is appropriate for the care of the member.

Telehealth services will be reimbursed at parity with existing off-site visit payments (clinics) or face-to-face visits (i.e., 100% of Medicaid payment rates). This guidance relaxes rules on the types of clinicians, facilities, and services eligible for billing under telehealth rules.

This guidance additionally addresses some technological barriers to telehealth by allowing clinicians and health care organizations to bill for telephonic services if they cannot provide the audiovisual technology traditionally referred to as “telemedicine.”

This guidance replaces previously issued guidance regarding telehealth and telephonic communication services during the COVID-19 State of Emergency (Medicaid Update March 2020 Vol 36, Numbers 3 and 4).

This guidance does not change any other Medicaid program requirements with respect to authorized services or provider enrollment and does not expand authorization to bill Medicaid beyond service providers who are currently enrolled to bill Medicaid Fee for Service (FFS) or contracted with a Medicaid Managed Care Plan.

Click here for full guidance.


On March 21 DOH released updated Medicaid telehealth billing guidance applicable during the current state of emergency. This guidance is only applicable to Art 28 providers and covers all visits on or after March 1, 2020. The following are changes relevant to FQHCs:

Distant site location

  • A provider’s home may be a distant site location for purposes of providing telehealth/telephone services.

Reimbursement for Telephone visits (audio only)

  • Physicians, Nurse Practitioners, Physicians Assistants, Licensed Midwives: bill offsite rate (4012).

  • Other billable providers (including LCSW): we are seeking additional guidance as the rate codes listed are not FQHCs rate codes.

Reimbursement for Telehealth visits (audio-visual)

  • There is a discrepancy in the guidance as written, which says both that FQHC acting as distant sites to patients at their homes should bill their off-site rate (4012) and that FQHCs acting as distant site providers may bill their PPS rate, which we take to mean the full threshold rate (4013). While we are seeking additional guidance, we urge health centers to document any threshold visit provided to a patient in their home for which you bill rate code 4013.

Reimbursement for dual-eligible patients

  • FQHCs will be reimbursed by Medicaid when providing services via telehealth/telephone to dual eligible patients. Follow reimbursement guidelines for telehealth/telephone visits as above for reimbursement for the Medicaid portion of the rate.

Please carefully review the updated guidance for additional details.

As a reminder, recent FTCA guidance clarified that a provider’s home would be considered an in scope site for telehealth purposes during the state of emergency, as long as “1) The service being provided via telehealth is within the health center's approved scope of project (recorded on Form 5A); 2) the clinician delivering the service is a health center provider; and 3) the individual receiving the service is a health center patient.”

Finally, we are continuing to work closely with NACHC to waive current Medicare restrictions on FQHCs acting as distant site providers. Our understanding is that there is a provision to allow Medicare reimbursement for FQHCs as distant sites in the current legislation that is being considered by the Senate. We will update you as we learn more on this issue.

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