Telehealth Cheat Sheet: California Providers' Guide

Telehealth Cheat Sheet: California Providers' Guide

For providers, COVID-19 has necessitated rapid shifts in healthcare delivery. Suddenly, telehealth is critical to continuing treatment while maintaining social distance and helping the state to “flatten the curve.”

As if the logistical challenges of this pivot aren’t daunting enough, keeping up with constantly shifting rules and regulations is yet another drain on provider time and resources. To help, we’ve created a simple “cheat sheet” for California providers, featuring the most important regulatory must-knows for workers’ compensation, Medicare, and private insurance plans.

Edit 5/14/2020: On 5/7/2020 the California Division of Workers’ Comp Administrative Director, George P. Parisotto, issued a new Order retroactively changing the reimbursement calculation for telehealth services. Some of the information on this page may not be correct, depending on the date of service. For the latest reimbursement rules, consult the latest Administrative Orders here and check our dedicated COVID-19 page for updates.

Telehealth Current Rules & Regulations

The following guide is an easy reference regarding telehealth rules for:

  • California workers’ comp
  • Medicare
  • California private health insurers

For each category, the guide provides information and linked resources regarding key areas of telehealth and telehealth billing. This includes technical audio/visual requirements, billing instructions, authorization requirements, and more.

Of particular note are certain COVID-19-specific modifications to HIPAA requirements, applicable to Medicare and private insurance during the national public health emergency (HIPAA requirements do not apply to California workers’ compensation).

We invite providers to refer to this guide when establishing and billing for telehealth services.

CA Workers’ Compensation (Physician Services) Telehealth

Date of Service

DOS From 4/15/2020

Telehealth Services Allowed

Medicare List of Telehealth Services, including Code Status: Temporary Addition for PHE Codes

CMS 1500 Billing Form Box 24B (Place of Service Code)

Location at which provider normally treats patients

Modifier

Modifier 95

Facility or Non-Facility Reimbursement

Higher in-person reimbursement

Technical  Requirements

Video Connection Required

Authorization Requirements

Utilization review required for every medical treatment in California workers’ compensation system. 

Other Applicable Regulations, Orders, and Notices

California Physician Services: Orders of Administrative Director - Effective April 15, 2020

Medicare Telehealth

Date of Service

DOS From 3/01/2020

Telehealth Services Allowed

Medicare List of Telehealth Services, including Code Status: Temporary Addition for the PHE Codes

CMS 1500 Billing Form Box 24B (Place of Service Code)

Location at which provider normally treats patients

Modifier

Modifier 95

Facility or Non-Facility Reimbursement

Non-Facility Reimbursement

Technical  Requirements

Video Connection Required

HIPAA modifications during COVID-19 Nationwide Public Health Emergency

Penalties waived  for good-faith provision of telehealth during COVID-19 emergency

CA Health Insurers Telehealth

Date of Service

DOS From 3/30/2020

Telehealth Services Allowed

All medically necessary health care, when clinically appropriate

CMS 1500 Billing Form Box 24B (Place of Service Code)

Contact insurer for instructions

Modifier

Contact insurer for instructions

Facility or Non-Facility Reimbursement

Requires parity between in-person and telehealth reimbursement

Technical  Requirements

Video Connection or Telephonic Service Permitted

HIPAA modifications during COVID-19 Nationwide Public Health Emergency

Penalties waived for good-faith provision of telehealth during the COVID-19 emergency

Authorization Requirements

Authorizations to receive online, video, or telephone services to be given verbally, as long as cost-sharing is clearly disclosed.

Other Applicable Regulations, Orders, or Notices

Ricardo Lara, California Insurance Commissioner March 30, 2020 Notice

As updates to telehealth rules and best practices emerge, we’ll keep our readers updated here on the blog, and through our regular free webinars —  including our two most recent:


For more on telehealth rules for Medicare, California health insurers, and California workers’ compensation, look through the free resources available on our COVID-19 page.

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