*Effective the 1st day of the month after the federal PHE ends (published December 2021)* Telehealth may include audio-only communication
*Effective the 1st day of the month after the federal PHE ends (published December 2021)* 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 (published December 2021)* 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.
*proposed update* Update administrative rules that guide behavioral health services reimbursed by Medical Assistance to align with the telehealth policies in Act 56 (2019). This will bring the Department of Health Services’ Division of Care and Treatment Services into compliance with Act 56.
*proposed update* Revise Department of Health Services Chapter 75 to update language around substance use disorders, better align SUD services with evidence-based practice standards in the industry, and address gaps in service delivery related to the opioid epidemic in. All requirements in this chapter shall also be applicable to telehealth services delivered under this chapter.
*proposed update* Amend Medical Assistance telehealth rules specifying certain reimbursable and non-reimbursable Medical Assistance telehealth services.
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).
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."
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.
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:
- PROSPECTIVE PAYMENT SYSTEM (PPS) REIMBURSEMENT STRUCTURE
- Services that are currently reimbursed at the PPS rate for Medicaid is reimbursed when delivered via telehealth provided it is functionally equivalent
- Some services are considered “indirect” and are not eligible for a PPS rate as they are wrapped into the PPS rate
- Some FFS services such as SBIRT
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
Temporary COVID-19 Policies (WI Medicaid)
Wisconsin's ForwardHealth guidance is set to expire at the end of the federal PHE
NEWLY ELIGIBLE SERVICES:
- Temporarily allowing telehealth services for currently covered services that can be delivered with functional equivalency to the face-to-face service
- Temporarily allowing remote services that use interactive, real-time technology INCLUDING audio-only for targeted case management services & community recovery services if they can be provided with functional equivalency
- Temporarily allowing real-time telephonic communication in lieu of face‐to‐face daily dosing contact by RNs or LPNs working in an opioid treatment program clinic
- Temporarily allowing remote supervision for personal care services by registered nurses
- Temporarily allowing the following mental health services: mental health screenings, comprehensive community services, community support program, community recovery services, targeted case management
- Telehealth must be synchronous, but can include audio-only
- No penalties for using non-HIPAA compliant technology
- Suspended face to face visit requirement for initial prescription of durable medical equipment or disposable medical supplies (can be completed by telehealth)
OTHER TEMPORARY WI MEDICAID POLICIES:
- Originating sites that are not listed in current policy are not eligible for facility fee
- Extends prior authorization
- Medicaid members can participate in telehealth visits from any location, including their homes
- Medicaid members can have telehealth visits over the phone, not just face-to-face technology
- Healthcare providers do not need separate certification to provide telehealth
- Out-of-state licensed providers can deliver telehealth service if they are enrolled in WI Medicaid
- Prior authorization required for any service delivered on fee-for-service basis by OOS provider
- FQHCs and RHCs:
- Distant site telehealth services provided by a non-tribal FQHC/CHC will be counted as encounters (following PPS reimbursement guidelines)
- Distant site telehealth services provided by a tribal provider will either follow PPS or Alternative Payment Methodology guidelines