October 20, 2020
Area(s) of Interest: Payor Issues and Reimbursement
Over the past few months, the California Medical Association (CMA) has received a number of inquiries from physician practices concerned that the requirement to reimburse providers at in-office rates for telehealth services, including telephonic visits, may be ending. However, according to guidance from California regulators, payors are required to continue with telehealth payment parity.
On September 4, 2020, the California Department of Managed Health Care (DMHC) issued an all plan letter (APL) reminding DMHC-regulated health plans of the continued requirement to reimburse providers at the same rate for telehealth services, including telephonic visits, as they would for services provided in person. This APL clarified that the prior APLs issued (20-009 and 20-013) remain in effect for the duration of California’s declared state of emergency or until further notice from DMHC, whichever is earlier. The APL also clarified that these requirements apply to delegated entities to the extent the health plan delegated the services impacted by these APLs.
On March 30, 2020, the California Department of Insurance (CDI) issued guidance requiring CDI-regulated insurance companies to reimburse providers at the same rate for telehealth services as they would for services provided in person. Insurers were also required to reimburse a service provided telephonically at the same rate as services provided via video. These requirements are effective throughout the declared COVID-19 state of emergency.
CMA has also heard from several practices that some payors aren’t reimbursing for the telephone services CPT codes, 99441-99443. It’s important to note that while the regulators’ guidance requires payors to reimburse telehealth services, including telephonic visits, at the same rates as in person E/M office visits, such as CPT 99201-99205 and 99211-99215, the guidance does not require payors to reimburse for the telephone services codes, CPT 99441-99443. Practices are encouraged to document thoroughly as though the visit had occurred in person and consider which in-person E/M office visit codes are appropriate to bill.
For more information, see CMA’s COVID-19 Telehealth Toolkit for Medical Practices. This toolkit is currently available for free to all physicians as part of CMA’s ongoing support for physicians during the public health emergency.
CMA has also produced a 12-part webinar series – Telehealth for Small and Medium Sized Practices – covering all aspects of implementing telehealth in a medical practice – selecting a platform, reimbursement rules and patient interactions. The webinar series is open to all providers and will have an emphasis on the use of telehealth in Medi-Cal. For more information or to register, visit cmadocs.org/telehealth-webinars.