California Retroactively Changes Telehealth Reimbursement - Part 1

California Retroactively Changes Telehealth Reimbursement - Part 1

On 5/7/2020 the California Division of Workers’ Comp (DWC) Administrative Director, George P. Parisotto, issued a new Order with retroactive changes to the reimbursement calculation for telehealth services.

In a Newsline dated 5/12/2020, the DWC informed the California workers’ comp community of substantial changes to rules and reimbursements that impact all providers furnishing telehealth services to ill and injured workers. These changes include:

  • Retroactive changes to the place of service used to report telehealth service
  • Increased reimbursement for audio-only CPT codes 99441 – 99443
  • Adoption of the CMS updated Covered Telehealth Services, including newly added audio telehealth services

These reimbursement changes impact all telehealth services for dates of service on or after 3/1/2020. Over the next three posts, we will explain each of these newly adopted changes.

We’ll also explain the steps that providers need to take to appeal for the additional revenue that is now due as a result of this retroactive reimbursement change.

DaisyBill applauds the quick action by the DWC to implement these changes that will help providers provide telehealth services to the ill and injured workers of California.

Retroactive Change to Telehealth Place of Service

For telehealth services, the 5/7/2020 Administrative Director Order amends CCR § 9789.12.2. to direct providers to report the Place of Service (POS) code that would have been reported had the telehealth service been furnished in person for dates of service on or after 3/1/2020.

This retroactive order means that many providers are now entitled to substantially increased amounts of reimbursement for all telehealth bills which they submitted using the POS code 02 populating box 24B on the CMS 1500.

Telehealth Reimbursement: Previous to this 5/7/2020 order, § 9789.12.2. assigned a lower facility reimbursement to all telehealth services furnished 3/1/2020 through 4/14/2020. With this retroactive Order for dates of service on or after 3/1/2020, if the provider normally furnished the telehealth services from a non-facility POS, the provider is entitled to the higher non-facility reimbursement for those telehealth services.

Telehealth Billing Instructions: For telehealth services with a date of service on or after 3/1/2020, providers are instructed to populate the CMS 1500 box 24B with the POS code that the provider normally reported had the telehealth service been furnished in person.

Appeal Incorrect Telehealth Reimbursements

This retroactive order means that for telehealth services with a date of service on or after 3/1/2020, where a provider submitted a CMS 1500 with telehealth POS code 02 populating box 24B, providers will need to submit an appeal for the additional reimbursement which is now due.

For those bills, if the provider normally reported that telehealth service from a non-facility location, such as an office (POS 11) or urgent care facility (POS 20), the provider will need to appeal for the higher non-facility reimbursement.

To receive the additional revenue allowed by this 5/7/2020 Administrative Director Order, a provider must submit the mandated California Second Review appeal within 90 days of receipt of the original bill explanation of review (EOR). Upon receipt of the Second Review appeal, the claims administrator is mandated to reimburse the provider any additional reimbursement within 14 days.

For all bills that received an incorrect lower reimbursement for telehealth services, providers need to immediately submit a Second Review appeal with the following Reason for Requesting Second Bill Review:

The reimbursement for this telehealth service was calculated using a POS code 02. Per the Order of the Administrative Director of the California Division of Workers’ Comp dated May 7th, 2020, the reimbursement for this telehealth service should be calculated using a non-facility POS code XX which is the POS that the provider would normally report had the service been furnished in person.

For these Second Review appeals, providers should furnish the correct Place of Service code that the provider normally reported had the telehealth service been furnished in person.

In the blog posting tomorrow we will explore additional retroactive reimbursement changes to audio-only CPT codes 99441 – 99443.


For a deeper dive into these changes, sign up for our next webinar on telehealth rules for workers’ comp. We’ll break down and simplify the many recent changes to rules and reimbursements -- and provide up-to-date telehealth cheat sheets.

Subscribe to DaisyNews

Recent Posts

Popular Topics

California (464) claims administrators News Updates Billing Education Fee Schedule OMFS Second Review e-Billing RFA California DWC Electronic Billing
New York (5) CMS 1500 Billing Education Electronic Billing e-Billing
intercom_chat_bubble_icon