March 30, 2020
The California Department of Insurance (CDI) today instructed CDI-regulated health insurance companies to take immediate steps to provide increased telehealth access during the COVID-19 emergency.
Insurance carriers will be required to reimburse providers at the same rate for telehealth services as they would for services provided in person. If the service is one that would otherwise have been provided in-person but is now being provided via telehealth, insurers should reimburse for that service as if it were provided in person. Insurers must also reimburse a service provided telephonically at the same rate as services provided via video.
The announcement requires insurers comply immediately and is effective throughout the declared COVID-19 state of emergency.
Additionally, insurance companies were instructed that they may not subject enrollees to cost-sharing greater than it would be if the service were provided in person.
The California Medical Association (CMA) applauds Insurance Commissioner Ricardo Lara and his staff for taking this action to allow physicians to take care of patients during the COVID-19 crisis.
The announcement has similar requirements to the All Plan Letter previously issued by the California Department of Managed Health Care.
It’s important to note that practices must ensure that their documentation matches the requirements of the CPT code they are billing and appropriate use of the place of service code, 02, telehealth.
Note Re: Telehealth and ERISA Plans
These requirements do not apply to self-funded ERISA plans. CMA is advocating for parity at the federal level to require self-funded ERISA plans to recognize and reimburse telehealth services, including telephonic visits, at the same rate as they would for in-person visits. CMA has also learned that some self-funded plans are only covering telehealth if it is provided through the plan’s third-party telehealth vendor. The cost sharing waivers also do not apply to ERISA plans. It is currently up to individual employers to decide whether they will waive cost sharing.
For more information on telehealth during this emergency, see CMA’s COVID-19 Telehealth Overview. This document will be updated regularly as new information becomes available.