The California Department of Health Care Services (DHCS) is proposing significant changes to its telehealth policy in the state’s Medicaid program known as Medi-Cal. The nonprofit Center for Connected Health Policy (CCHP) calls the proposal “a remarkable step forward.”
Since the passage of and enactment of AB 415, the Telehealth Development Act, CCHP has noted that DHCS had the ability in law to create a more expansive telehealth policy. Now it has proposed one.
A CCHP report notes that DHCS is soliciting feedback from stakeholders on a proposal that would clarify when services provided outside of the “four walls” of a federally qualified health center (FQHC) or rural health center (RHC) are eligible for the prospective payment system (PPS). The department is proposing that all such services be paid the PPS when rendered to homebound, migratory, seasonal workers and homeless patients, patients in the hospital, dental services rendered to established patients by a contracted dental provider, and telehealth services provided to its established patients when certain requirements are met.
Providers would still have to document services with the same specificity as would be required when services are provided within the four walls; the FQHC or RHC must provide written policies that describe all of the services that will be provided outside of the four walls, along with circumstances for which the services will be provided; and all HRSA policies and procedures for approved scope of projects apply.
The proposal also lays out specific rules for billing as well as for store-and-forward services provided for ophthalmology, dermatology, and dentistry for its established patients.
DHCS also is proposing to update and clarify its telehealth policy manuals within the Medi-Cal program. Among the most intriguing proposals in the draft, according to CCHP, is allowing the distant site/treating provider to decide when it is appropriate for telehealth to be used and whether it should be via live video or store-and-forward.
E-consult (provide-to-provider consultation), falling under the auspices of store-and-forward, would also be reimbursed through two CPT codes, making California and Connecticut the only state Medicaid programs in the country reimbursing for that particular service. Under Medi-Cal’s proposed draft policy, the services would still need to be a Medi-Cal-reimbursable service and the CPT or HCPCS code definition should allow for technology to be used, but CCHP said this proposed policy is far more advanced than most any other Medicaid policies in the country.
