Telemedicine - Provider Information

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Frequently Asked Questions

What constitutes a valid patient consent signature?

Providers must document the member's consent, either verbal or written, to receive telemedicine services.

Can providers bill HCPCS Q3014 when the provider is delivering the care from a clinical setting?

Q3014 should be billed by a provider at the originating site. The originating site is the location of the patient at the time the service is being furnished via a telemedicine modality.

If the member is not physically present at the site, then the Q3014 code would not be appropriate.

For providers other than FQHCs: If a patient receives a covered service and also is connected with a distant provider via telemedicine during the visit, then Q3014 may be billed in addition to the services provided during that visit.

For FQHCs: If a patient is at an FQHC and receives a covered service and also is connected with a distant provider via telemedicine, the FQHC can only submit a claim for an encounter. All services provided during the visit are included in the encounter payment and that would include Q3014. The only way an FQHC would receive the Q3014 payment is if there is no payable encounter for the patient on that day.

Can providers work from home (e.g. Dr. is quarantined) but still provide telemedicine services?

Yes. The distant provider may participate in the telemedicine interaction from any appropriate location.

If my patient has private insurance (third party liability, TPL) that doesn\'t cover the telemedicine visit, will Health First Colorado (Colorado Medicaid) still cover it?

Yes. Standard TPL policy still applies. See theGeneral Provider Manual for details.

Early Intervention Providers

How does telemedicine work for Early Intervention therapies?

Telemedicine is a method of delivering services remotely. Is it not a distinct service itself, therefore it does not have a distinct billing CPT code. In order to bill a CPT which is delivered using telemedicine the service should meet the same standard of care as if it were delivered in-person.

Are short telephone call check-ins with the family billable to Medicaid (Health First Colorado)?

No. Short telephone only check ins with the family are not a billable service at this time.

Are telephone-only therapy services billable to Medicaid when they meet the minimum time thresholds for billing?

No. Telephone-only physical, occupational, and speech therapy services are not billable to Medicaid (regardless of the time spent). Telemedicine PT, OT, ST requires an audio/visual connection with the member.

Is a new, or second, Prior Authorization Request (PAR) required to provide telemedicine visits?

No. Professional claims may use Place of Service code 02 without needing a PAR changed. Place of Service does not need to be entered when submitting a PAR. Institutional claims for Home Health Agencies do not have the Place of Service field.

Is Electronic Visit Verification (EVV) required for telemedicine?

Not at this time.

Should documentation be any different for services delivered with telemedicine?

No. The same documentation standards apply for services delivered with telemedicine as they would in-person. Documentation should state that services were delivered with telemedicine.

Is a notation of the verbal parental consent on the IFSP acceptable for the Prior Authorization process?

Yes, for the duration of the COVID-19 state of emergency.

Are verbal signatures on the Individual Family Service Plan (IFSP) for Prior Authorization acceptable?

Yes. Providers may indicate a verbal signature for the IFSP during the PAR process. Ink signatures are not required.

Indian Health Services

Is modifier GT required to be on a claim for telemedicine-delivered services?

For CMS1500 claim types, modifier GT is not required. It can optionally be used for certain codes that are indicated in the telemedicine billing manual. Modifier GT gives extra payment for certain codes.

For UB-04 claim types, modifier GT is required for Home Health Agencies, Hospice, Federally Qualified Health Centers, Rural Health Clinics, and Outpatient Hospitals. Modifier GT should be appended to each line item that was performed via telemedicine. Indian Health Services providers should refer to specific guidance elsewhere in the FAQ.

Do telephone-only visits qualify as an encounter claim submission? 

Yes.

Outpatient Hospitals

Is modifier GT required to be on a claim for Outpatient Hospitals?

No. Outpatient Hospitals are required to use modifier GT on claims for telemedicine therapies. Modifier 95 is not required but may be optionally used.

Physical, Occupational, and Speech Therapy Providers

Can therapy assistants provide telemedicine?

Yes, however, DORA supervision rules are still applicable to telemedicine visits.

Will new/existing Prior Authorization Requests require telemedicine Place of Service 02 to be indicated?

No. The Place of Service field in the request does not need to be populated.

Will new or existing Prior Authorization Requests require modifier GT to be indicated?

No. Modifier GT does not need to be on the Prior Authorization Request for it to be billed on a claim.

Requirements for Telemedicine Services:

It is acceptable to use telemedicine to facilitate live contact directly between a member and a provider. Services can be provided between a member and a distant provider when a member is in their home or other location of their choice. Additionally, the distant provider may participate in the telemedicine interaction from any appropriate location.

Other standard requirements for telemedicine services include:

1. The reimbursement rate for a telemedicine service shall, as a minimum, be set at the same rate as the medical assistance program rate for a comparable in-person service. [C. R. S. 2017, 25.5-5-320(2)].
2. Providers may only bill procedure codes which they are already eligible to bill.
3. Any health benefits provided through telemedicine shall meet the same standard of care as in-person care.
4. Providers must document the member's consent, either verbal or written, to receive telemedicine services.
5. Contact with the provider must be initiated by the member for the service rendered.
6. The availability of services through telemedicine in no way alters the scope of practice of any health care provider, nor does it authorize the delivery of health care services in a setting or manner not otherwise authorized by law.
7. Services not otherwise covered by Health First Colorado are not covered when delivered via telemedicine.
8. The use of telemedicine does not change prior authorization requirements that have been established for the services being provided.
9. Record-keeping and patient privacy standards should comply with normal Medicaid requirements and HIPAA. Office for Civil Rights (OCR) Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency

Early and Periodic Screening, Diagnostic, and Treatment (EPSDT)
8.280.4.E Other EPSDT Benefits

Other healthcare services may include other EPSDT benefits if the need for such services is identified. The services are a benefit when they meet the following requirements:

1. All goods and services described in Section 1905(a) of the Social Security Act are a covered benefit under EPSDT when medically necessary as defined at 10 C.C.R. 2505-10, Section 8.076.1.8, regardless of whether such goods and services are covered under the Colorado Medicaid State Plan.
2. For the purposes of EPSDT, medical necessity includes a good or service that will, or is reasonably expected to, assist the client to achieve or maintain maximum functional capacity in performing one or more Activities of Daily Living; and meets the criteria set forth at Section 8.076.1.8.b - g.
3. The service provides a safe environment or situation for the child.
4. The service is not for the convenience of the caregiver.
5. The service is medically necessary.
6. The service is not experimental or investigational and is generally accepted by the medical community for the purpose stated.
7. The service is the least costly.

Billing Guidance:
To receive reimbursement for telemedicine services, providers must follow the following billing practices:

• UB-04 Institutional Claims - Providers must indicate that the service(s) were provided through telemedicine by appending modifier GT to the UB-04 institutional claim form with the service's usual billing codes. This identifies the service as provided via telemedicine during the COVID-19 State of Emergency.
• CMS 1500 Professional Claims - Place of Service code 02 or 10 must be indicated on all CMS 1500 professional claims for telemedicine. Only specific CPT/HCPCS are allowed (see below).

Telemedicine Place of Service Coding

Place of Service code 02 or 10 should be used to report services delivered via telecommunication depending on the location of the member when receiving telehealth services.

• Place of Service 02 is used when the member is receiving telehealth services in a place that is not their home.
• Place of Services 10 is used when a member is receiving telehealth services when the member is located in their home.

Additionally, modifiers FQ, FR, 93 and 95 can be added to POS 2 and 10:

• FQ: The service was furnished using audio-only communication technology.
• FR: The supervising practitioner was present through two-way, audio/video communication technology.
• 93: Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System
• 95: Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System

The following list of CPT/HCPCS codes may be billed using Place of Service code 02 or 10:

Health First Colorado has added temporary coverage of well-child check-ups provided via telemedicine during the public health emergency for COVID-19. Effective November 12, 2020, Health First Colorado will reimburse providers for well-child check-up visits with procedure codes 99382, 99383, 99384, 99392, 99393, 99394 via telemedicine for children between the ages of 2 and 18. Place of Service 02 or 10 must be indicated on all CMS 1500 professional claims for well-child check-ups delivered via telemedicine.

Providers are encouraged to complete the physical examination the next time the member is seen in person. Fee for service providers who perform a physical examination within 4 months of the telemedicine well-child check-up should void the previously paid claim with the Place of Service 02 or 10 and resubmit for payment of the well-child check-up using the date of service of the physical examination. Due to the nature of their billing, FQHC/RHCs and IHS/Tribal 638 providers do not need to void a previous encounter when a physical examination is performed within 4 months of the telemedicine well-child check-up. FQHC/RHC and IHS/Tribal 638 providers must indicate the well-child check-up provided through telemedicine by appending modifier GT to the UB-04 institutional claim form with the service's usual billing codes.

This temporary well-child check coverage ended at the end of the Public Health Emergency on May 11, 2023.

What Health First Colorado services are reimbursed using telemedicine?

Any Health First Colorado-covered physician services that are within the scope of a provider's practice and training and appropriate for telemedicine may be rendered via telemedicine.

Telemedicine is the delivery of medical services and any diagnosis, consultation, treatment, transfer of medical data or education related to health care services using interactive audio or interactive video communication instead of in-person contact.

• Physician services may be provided as telemedicine.
• Providers may only bill procedure codes, which they are already eligible to bill.
• Any health benefits provided through telemedicine shall meet the same standard of care as in-person care.

Services not otherwise covered by Health First Colorado are not covered when delivered via telemedicine. Additionally, the use of telemedicine does not change prior authorization requirements that have been established for the services being provided.

Telemedicine does not include provider-to-provider consultations provided by telephone (interactive audio), email or facsimile machines.

Confidentiality

• Same standard of care as in-person care. Record keeping and patient privacy standards should comply with normal Medicaid requirements and HIPAA.

How do I bill for telemedicine services?

1. A single provider may bill a service with Place of Service 02 or 10, for professional claims, when the member is not physically present in the provider's office and services are rendered through telemedicine. See the coding table below. Place of Service 02 or 10 (Telehealth) should be used for all telemedicine visits depending on the location of the member when receiving telehealth services.
2. When two providers are involved, one provider can be reimbursed as the "originating provider" where the member is present with the provider at the "originating site" and that originating provider is consulting with a "distant provider". Another provider can also be reimbursed as a "distant provider" for any covered Telemedicine Services. See the description at the bottom of this page.

Originating/Distant Providers and Q3014

Origination providers:

• An originating provider that only makes a room and telecommunications equipment available and is not providing clinical services bills Q3014 (telemedicine originating site facility fee).
• If the originating provider also provides clinical services to the member, the provider bills the appropriate procedure code in addition to Q3014.

Distant Providers:

• All distant providers bill the appropriate procedure code and Place of Service 02 or 10 and FQ or FR modifiers if appropriate on the CMS 1500 paper claim form or as an 837P transaction.
• When the member is located in a hospital, please use the appropriate place of service code for where the member is located.

Where can I get more information about telemedicine?

The Telemedicine Billing Manual, located on the Billing Manuals web page under the CMS 1500 dropdown, provides information on covered services, billing, reimbursement, and confidentiality requirements.