Medicaid Policies
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).
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: Hospitals (including ED), office/clinic, SNF
PROVIDERS AT DISTANT SITES: Audiologists, Individual mental health and substance abuse practitioners not in a facility certified by the DQA (Division of Quality Assurance), Nurse midwives, Nurse practitioners, Ph.D. psychologists, Physician assistants, Physicians, Psychiatrists, Professionals providing services in mental health or substance abuse programs certified by the DQA
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)
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
- Teledentistry
WAIVED REQUIREMENTS:
- 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
Commercial Payer Policies
There is no private payer telehealth parity legislation in Wisconsin
Temporary COVID-19 Policies (WI Commercial Payers)
A letter from the Office of the Commissioner of Insurance “requests that medical malpractice insurers provide coverage for telemedicine under the same terms for providers as if they were providing services in-person.
Out of state practitioners can practice in Wisconsin without first obtaining a temporary license
Medical Board Policies
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.
Telemedicine abortions are prohibited
Wisconsin Professional Licensure Compacts
Interstate Medical Licensure Compact
EXPIRED: Temporary COVID-19 Policies (WI Medical Board)
According to Governor’s executive order:
- Physicians providing telemedicine to patients in WI must have a valid and current license from WI, another state, or Canada
* This temporary guidance is expired due to the Wisconsin Supreme Court ruling (5/13/2020)
Mid-Level Providers
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.”
Wisconsin Mid-Levels Professional Licensure Compacts
Enhanced Nurse Licensure Compact
EXPIRED: Temporary COVID-19 Policies (WI Mid-Levels)
According to Governor’s executive order:
- Physicians providing telemedicine to patients in WI must have a valid and current license from WI, another state, or Canada
- Scope and limitations for Physician Assistants partially altered
- Scope and limitations for Nurses partially altered
* This temporary guidance is expired due to the Wisconsin Supreme Court ruling (5/13/2020)
Behavioral Health Providers
There are no commercial payer telehealth statutes in WI
Wisconsin Mental Health Professional Licensure Compacts
None
EXPIRED: Temporary COVID-19 Policies (WI Mental Health)
According to Governor’s executive order:
- Physicians providing telemedicine to patients in WI must have a valid and current license from WI, another state, or Canada
- An individual credentialed by the MPSW Examining Board or authorized to practice in Wisconsin under PHEO #16 or Act 185 §105 (6) may provide treatment to individuals physically located in Wisconsin via telehealth so long as the treatment is within provider’s scope of practice
* This temporary guidance is expired due to the Wisconsin Supreme Court ruling (5/13/2020)
