Wisconsin Telehealth Policy
Wisconsin does not currently have an active PHE.
Wisconsin is a non-expansion state with full Medicaid parity (full commercial payment parity is pending until January 1, 2022).
Wisconsin Medicaid is almost entirely managed by Forward Health.
WI Medicaid allows telehealth for any Medicaid-eligible provider and any Medicaid-eligible service.
Originating site facility fees (Q3014) are paid to hospitals, offices, clinics, and skilled nursing facilities.
Medicaid pays FQHCs a PPS rate and covers RPM services.
Wisconsin participates in the following interstate licensure compacts: Medical, eRN, PT, OT, and Psycology.
RECIPROCITY: Physicians must be licensed in Wisconsin to provide telehealth services to a patient in Wisconsin
*Published Feb 7, 2022* Requires the Medical Assistance program, Department of Safety and Professional Services and any attached examining board or affiliated credentialing board to define and use the term “telehealth” as follows: “a practice of health care delivery, diagnosis, consultation, treatment, or transfer of medically relevant data by means of audio, video, or data communications that are used either during a patient visit or a consultation or are used to transfer medically relevant data about a patient.”
*Effective the 1st day of the month after the federal PHE ends* Telehealth may include audio-only communication
*Effective the 1st day of the month after the federal PHE ends* FQHCs guidance:
PPS Eligible Telehealth Services: “For currently covered services, services that are considered direct when provided in-person will be considered direct when provided via telehealth.”
Originating Site Fee: “Although [FQHCs] are not directly reimbursed an originating site fee, HCPCS procedure code Q3014 should be billed for tracking purposes and for consideration in any potential future changes in scope.”
*Effective the 1st day of the month after the federal PHE ends* Providers should refer to the maximum allowable fee schedule for a complete list of services allowed under permanent telehealth policy. Procedure codes for services allowed under permanent telehealth policy have a POS code 02.
TELEHEALTH DEFINITION: "Asynchronous telehealth service" is telehealth that is used to transmit medical data about a patient to a provider when the transmission is not a 2-way, real-time, interactive communication. “Interactive telehealth” means telehealth delivered using multimedia communication technology that permits 2-way, real-time, interactive communications between a certified provider of Medical Assistance at a distant site and the Medical Assistance recipient or the recipient's provider (reimbursable).
PAYMENT PARITY: "The department shall provide reimbursement under the Medical Assistance program for any benefit that is a covered benefit under s. 49.46 (2) and that is delivered by a certified provider for Medical Assistance through interactive telehealth." Additionally, the Department cannot limit reimbursement based on the location of the recipient when the service was provided.
SERVICE PARITY: The Department of Health cannot require Medical Assistance providers to meet additional criteria solely because they are delivering services via telehealth. The services must be "functionally equivalent to face-to-face contact."
PREREQUISITES TO TELEHEALTH: Certified providers of Medical Assistance are not required to have additional certification or meet additional requirements to deliver telehealth
ADDITIONAL PROVIDER REQUIREMENTS: The department may require providers to show that the telehealth service is functionally equivalent to face-to-face
NON-COVERED SERVICES: Store and forward, services that are not covered when delivered face to face
REMOTE MONITORING: Reimbursed (along with Remote physiologic monitoring, Remote evaluation of prerecorded patient information, Brief communication technology-based services, Care management services delivered through telehealth, Any other telehealth or communication technology-based services.)
ORIGINATING SITES ELIGIBLE FOR FACILITY FEE: Hospitals (including ED), office/clinic, SNF. There are no restrictions on originating sites for telehealth visits.
PROVIDERS AT DISTANT SITES: Audiologists, mental health and substance abuse practitioners, Nurse midwives, Nurse practitioners, Ph.D. psychologists, Physician assistants, Physicians, Psychiatrists. There are no restrictions on distant sites for telehealth visits (for reimbursement purposes).
FQHCs & RHCs:
*Effective the 1st day of the month after the federal PHE ends* PPS Eligible Telehealth Services: “For currently covered services, services that are considered direct when provided in-person will be considered direct when provided via telehealth.” Originating Site Fee: “Although [FQHCs] are not directly reimbursed an originating site fee, HCPCS procedure code Q3014 should be billed for tracking purposes and for consideration in any potential future changes in scope.” (effective 1st day of the month after the federal PHE ends)
PPS rate
CHCs, tribal FQHCs, and RHCs may serve as originating site and distant site providers for telehealth services
CHCs may not report services provided via telehealth as an encounter. Instead, CHCs should submit claims for distant site services on a professional claim form and will be reimbursed in accordance with the maximum allowable fee schedule.
FQHC services billed with modifier GT (indicating telehealth) will be reimbursed under PPS. Billing HCPCS procedure code T1015 (Clinic visit/encounter, all-inclusive) with a telehealth procedure code will result in a PPS rate for fee-for-service encounters.
OTHER WI MEDICAID POLICIES:
Coverage/reimbursement of a service cannot be limited based on the location of the Medical Assistance recipient when the service is provided
Mental health and substance abuse practitioners providing services in settings other than those certified by the Division of Quality Assurance may be reimbursed for telehealth services
No telehealth parity legislation.
*Published March 27, 2020* Health care providers licensed in states other than Wisconsin may be temporarily credentialed to provide telehealth services to patients within Wisconsin IF the health care provider applies to the department for a temporary credential within 30 days of beginning to provide services AND is licensed without restrictions in their state AND has applied for a permanent credential granted by the department or an examining board, as applicable.
If the practitioner is providing health care services ONLY during the COVID-19 national public health emergency or during the 30 days immediately after the national emergency ends, a temporary credential granted under this section to the health care provider expires 30 days after the national emergency ends. A practitioner providing services only during the COVID-19 national public health emergency or in the 30 days after the emergency need not have applied for a permanent credential granted by the department or an examining board.
Out-of-state physicians must hold a valid Wisconsin medical license in order to diagnose and treat patients located in Wisconsin
A physician-patient relationship may be established through telemedicine.
*Published March 27, 2020* Health care providers licensed in states other than Wisconsin may be temporarily credentialed to provide telehealth services to patients within Wisconsin IF the health care provider applies to the department for a temporary credential within 30 days of beginning to provide services AND is licensed without restrictions in their state AND has applied for a permanent credential granted by the department or an examining board, as applicable.
If the practitioner is providing health care services ONLY during the COVID-19 national public health emergency or during the 30 days immediately after the national emergency ends, a temporary credential granted under this section to the health care provider expires 30 days after the national emergency ends. A practitioner providing services only during the COVID-19 national public health emergency or in the 30 days after the emergency need not have applied for a permanent credential granted by the department or an examining board.
Wisconsin Medical Examining Board Rule CR 15-087, Chapter 24: “The rules in this chapter may not be construed to prohibit any of the following: … Use of telemedicine by a physician assistant licensed by the medical examining board to provide patient care, treatment, or services within the licensee’s scope of practice under s. Med 8.07.”
*Published Feb 5, 2022* PSYCHOLOGY: Adopt the Psychology Interjurisdictional Compact.
*Published March 27, 2020* Health care providers licensed in states other than Wisconsin may be temporarily credentialed to provide telehealth services to patients within Wisconsin IF the health care provider applies to the department for a temporary credential within 30 days of beginning to provide services AND is licensed without restrictions in their state AND has applied for a permanent credential granted by the department or an examining board, as applicable.
If the practitioner is providing health care services ONLY during the COVID-19 national public health emergency or during the 30 days immediately after the national emergency ends, a temporary credential granted under this section to the health care provider expires 30 days after the national emergency ends. A practitioner providing services only during the COVID-19 national public health emergency or in the 30 days after the emergency need not have applied for a permanent credential granted by the department or an examining board.
*Published Feb 5, 2022* OCCUPATIONAL THERAPY: Enact the Occupational Therapy Licensure Compact.
*Published March 27, 2020* Health care providers licensed in states other than Wisconsin may be temporarily credentialed to provide telehealth services to patients within Wisconsin IF the health care provider applies to the department for a temporary credential within 30 days of beginning to provide services AND is licensed without restrictions in their state AND has applied for a permanent credential granted by the department or an examining board, as applicable.
If the practitioner is providing health care services ONLY during the COVID-19 national public health emergency or during the 30 days immediately after the national emergency ends, a temporary credential granted under this section to the health care provider expires 30 days after the national emergency ends. A practitioner providing services only during the COVID-19 national public health emergency or in the 30 days after the emergency need not have applied for a permanent credential granted by the department or an examining board.
PARTNER TELEHEALTH RESOURCE CENTERS
This project is supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS) under grant numbers U1UTH42525 and G01RH32157. This information or content and conclusions are those of the author and should not be construed as the official position or policy of, nor should any endorsements be inferred by HRSA, HHS or the U.S. Government.