Telemedicine - Provider Information

Please check this page regularly as updates and changes to the telemedicine policy will be announced here.

COVID-19 State of Emergency Changes to Telemedicine Services

To facilitate the safe delivery of health care services to members throughout the COVID-19 state of emergency, the Department is authorizing three temporary changes to the existing telemedicine policy. See Health First Colorado Announces Telemedicine Changes for more information.

Federally Qualified Health Centers, Rural Health Clinics, and Indian Health Services
For the duration of the COVID-19 state of emergency, Health First Colorado is allowing telemedicine visits to qualify as billable encounters for Federally Qualified Health Centers (FQHCs), Rural Health Clinic (RHCs), and Indian Health Services (IHS). Services allowed under telemedicine may be provided via telephone, live chat, or interactive audiovisual modality for these provider types.
Physical Therapy, Occupational Therapy, Home Health, Hospice and Pediatric Behavioral Health Providers
Health First Colorado has expanded the list of providers eligible to deliver telemedicine services to include physical therapists, occupational therapists, hospice, home health providers and pediatric behavioral health providers.
1. Home Health Agency services and therapies, Hospice, and Pediatric Behavioral Treatment may be provided via telephone-only.
2. Outpatient Physical, Occupational, and Speech Therapy services must have an interactive audio/visual connection with the member to be provided via telemedicine.

Telemedicine is covered for behavioral health providers under the capitated behavioral health benefit administered by the Regional Accountable Entities (RAEs). Behavioral health providers should contact their RAE for guidance. Visit the Accountable Care Collaborative Phase II web page for more information.

Frequently Asked Questions

All Providers (general)

What constitutes a valid patient consent signature?

Providers must document the member’s consent, either verbal or written, to receive telemedicine services.

Can providers bill HCPCS Q3014 when the provider is delivering the care from a clinical setting?

Q3014 should be billed by a provider at the originating site. The originating site is the location of the patient at the time the service is being furnished via a telemedicine modality.

If the member is not physically present at the site, then the Q3014 code would not be appropriate.

For providers other than FQHCs: If a patient receives a covered service and also is connected with a distant provider via telemedicine during the visit, then Q3014 may be billed in addition to the services provided during that visit.

For FQHCs: If a patient is at an FQHC and receives a covered service and also is connected with a distant provider via telemedicine, the FQHC can only submit a claim for an encounter. All services provided during the visit are included in the encounter payment and that would include Q3014. The only way an FQHC would receive the Q3014 payment is if there is no payable encounter for the patient on that day.

Can providers work from home (e.g. Dr. is quarantined) but still provide telemedicine services?

Yes. The distant provider may participate in the telemedicine interaction from any appropriate location.

If my patient has private insurance (third party liability, TPL) that doesn't cover the telemedicine visit, will Health First Colorado (Colorado Medicaid) still cover it?

Yes. Standard TPL policy still applies. See the General Provider Manual for details.

Will new/existing Prior Authorization Requests require telemedicine Place of Service 02 to be indicated?

No. The Place of Service field in the request does not need to be populated.

Will new or existing Prior Authorization Requests require modifier GT to be indicated?

No. Modifier GT does not need to be on the Prior Authorization Request for it to be billed on a claim.

Is modifier GT required to be on a claim for telemedicine-delivered services?

For CMS1500 claim types, modifier GT is not required. It can optionally be used for certain codes that are indicated in the telemedicine billing manual. Modifier GT gives extra payment for certain codes.

For UB-04 claim types, modifier GT is required for Home Health Agencies, Hospice, Federally Qualified Health Centers, Rural Health Clinics, and Outpatient Hospitals. Modifier GT should be appended to each line item that was performed via telemedicine. Indian Health Services providers should refer to specific guidance elsewhere in the FAQ.

Early Intervention Providers

How does telemedicine work for Early Intervention therapies?: Telemedicine is a method of delivering services remotely. Is it not a distinct service itself, therefore it does not have a distinct billing CPT code. In order to bill a CPT which is delivered using telemedicine the service should meet the same standard of care as if it were delivered in-person.
Are short telephone call check-ins with the family billable to Medicaid (Health First Colorado)?: No. Short telephone only check ins with the family are not a billable service at this time.
Are telephone-only therapy services billable to Medicaid when they meet the minimum time thresholds for billing?: No. Telephone-only physical, occupational, and speech therapy services are not billable to Medicaid (regardless of the time spent). Telemedicine PT, OT, ST requires an audio/visual connection with the member.
Is a new, or second, Prior Authorization Request (PAR) required to provide telemedicine visits?: No. Professional claims may use Place of Service code 02 without needing a PAR changed. Place of Service does not need to be entered when submitting a PAR. Institutional claims for Home Health Agencies do not have the Place of Service field.
Will new or existing Prior Authorization Requests require modifier GT to be indicated?: No. Modifier GT does not need to be on the PAR for it to be billed on a claim.
Is Electronic Visit Verification (EVV) required for telemedicine?: Not at this time.
Should documentation be any different for services delivered with telemedicine?: No. The same documentation standards apply for services delivered with telemedicine as they would in-person. Documentation should state that services were delivered with telemedicine.
Is a notation of the verbal parental consent on the IFSP acceptable for the Prior Authorization process?: Yes, for the duration of the COVID-19 state of emergency.
Are verbal signatures on the Individual Family Service Plan (IFSP) for Prior Authorization acceptable?: Yes. Providers may indicate a verbal signature for the IFSP during the PAR process. Ink signatures are not required.

Indian Health Services

Is modifier GT required to be on a claim for telemedicine-delivered services?: No. Appending modifier GT to a line item is optional but encouraged.
Do telephone-only visits qualify as an encounter claim submission?: Yes.

Outpatient Hospitals

Is modifier 95 required?: No. Outpatient Hospitals are required to use modifier GT on claims for telemedicine therapies. Modifier 95 is not required but may be optionally used.

Physical, Occupational, and Speech Therapy Providers

Can therapy assistants provide telemedicine?: Yes; however DORA supervision rules are still applicable to telemedicine visits.

Requirements for Telemedicine Services:

It is acceptable to use telemedicine to facilitate live contact directly between a member and a provider. Services can be provided between a member and a distant provider when a member is in their home or other location of their choice. Additionally, the distant provider may participate in the telemedicine interaction from any appropriate location.

Other standard requirements for telemedicine services include:

The reimbursement rate for a telemedicine service shall, as a minimum, be set at the same rate as the medical assistance program rate for a comparable in-person service. [C. R. S. 2017, 25.5-5-320(2)].
Providers may only bill procedure codes which they are already eligible to bill.
Any health benefits provided through telemedicine shall meet the same standard of care as in-person care.
Providers must document the member’s consent, either verbal or written, to receive telemedicine services.
Contact with the provider must be initiated by the member for the service rendered.
The availability of services through telemedicine in no way alters the scope of practice of any health care provider; nor does it authorize the delivery of health care services in a setting or manner not otherwise authorized by law.
Services not otherwise covered by Health First Colorado are not covered when delivered via telemedicine.
The use of telemedicine does not change prior authorization requirements that have been established for the services being provided.
Record-keeping and patient privacy standards should comply with normal Medicaid requirements and HIPAA. Office for Civil Rights (OCR) Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency

Billing Guidance:
To receive reimbursement for telemedicine services, providers must follow the following billing practices:

UB-04 Institutional Claims - Providers must indicate that the service(s) were provided through telemedicine by appending modifier GT to the UB-04 institutional claim form with the service's usual billing codes. This identifies the service as provided via telemedicine during the COVID-19 State of Emergency.
CMS 1500 Professional Claims - Place of Service code 02 must be indicated on all CMS 1500 professional claims for telemedicine. Only specific CPT/HCPCS are allowed (see below).

Place of Service 02 (telemedicine)

Place of Service 02 should be used to report services delivered via telecommunication, where the member may be in their home and the provider may be at their office. The following list of CPT/HCPCS may be billed using Place of Service code 02:

76801	76802	76805	76811	76812	76813	76814	76815
76816	76817	90791	90792	90832	90833	90834	90836
90837	90838	90839	90840	90846	90847	90849	90853
90863	92507	92508	92521	92522	92523	92524	92526
92606	92609	92610	96110	96112	96113	96116	96121
96125	96130	96131	96132	96133	96136	96137	96138
96139	96146	97110	97112	97129	97130	97140	97150
97151	97153	97154	97155	97158	97161	97162	97163
97164	97165	97166	97167	97168	97530	97533	97535
97537	97542	97755	97760	97761	97763	97802	98703
98704	98966	98967	98968	99201	99202	99203	99204
99205	99211	99212	99213	99214	99215	99402	99402
99403	99404	99406	99407	99408	99409	99441	99442
99443	G0108	G0109	G8431	G8510	G9006	H0001	H0002
H0004	H0006	H0025	H0031	H0032	H0049	H1005	H2000
H2011	H2015	H2016	S9445	S9485	T1017	V5011

What Health First Colorado services are reimbursed using telemedicine?

Any Health First Colorado covered physician services that are within the scope of a provider’s practice and training and appropriate for telemedicine may be rendered via telemedicine.

Telemedicine is the delivery of medical services and any diagnosis, consultation, treatment, transfer of medical data or education related to health care services using interactive audio or interactive video communication instead of in-person contact.

Physician services may be provided as telemedicine.
Providers may only bill procedure codes, which they are already eligible to bill.
Any health benefits provided through telemedicine shall meet the same standard of care as in-person care.

Services not otherwise covered by Health First Colorado are not covered when delivered via telemedicine. Additionally, the use of telemedicine does not change prior authorization requirements that have been established for the services being provided.

Telemedicine does not include consultations provided by facsimile machines, text, email or instant messaging.

Confidentiality

Same standard of care as in-person care. Record keeping and patient privacy standards should comply with normal Medicaid requirements and HIPAA.

How do I bill for telemedicine services?

A single provider may bill a service with Place of Service 02, for professional claims, when the member is not physically present in the provider’s office and services are rendered through telemedicine. See the coding table below. Place of Service 02 (Telehealth) should be used for all telemedicine visits.
When two providers are involved, one provider can be reimbursed as the "originating provider" where the member is present with the provider at the "originating site" and that originating provider is consulting with a "distant provider". Another provider can also be reimbursed as a "distant provider" for any covered Telemedicine Services. See the description at the bottom of this page.

Originating/Distant Providers and Q3014

Origination providers:

An originating provider that only makes a room and telecommunications equipment available and is not providing clinical services bills Q3014 (telemedicine originating site facility fee).
If the originating provider also provides clinical services to the member, the provider bills the appropriate procedure code in addition to Q3014.

Distant Providers:

All distant providers bill the appropriate procedure code and Place of Service 02 on the CMS 1500 paper claim form or as an 837P transaction.

Where can I get more information about telemedicine?

The Telemedicine Billing Manual, located on the Billing Manuals web page under the CMS 1500 dropdown, provides information on covered services, billing, reimbursement, and confidentiality requirements.

Telemedicine Utilization Data

Overview

In compliance with SB20-212, the presentation linked below displays data on telemedicine utilization in Health First Colorado. The data is for services rendered during the period of July 1, 2019, through May 16, 2020. The services in this dashboard are limited to the services eligible for telemedicine reimbursement. Services that are not eligible for telemedicine reimbursement are not included in this data. The data is not adjusted for changes in caseload.

SB 20-212 Data Slideshow

Data displayed in orange in the graphs represent telemedicine services. Data displayed in blue represent non-telemedicine services. For each provider type grouping, telemedicine data (in orange) is displayed by:

Eligibility Category: These are groups used by the Department to organize members into categories based on their eligibility type. The data are sorted by the total paid amount for telemedicine services received by members in the eligibility category. A hierarchy is used to determine which eligibility group a member is categorized into. For example, a child with disabilities would fall into the members with disabilities group rather than the children group. Members over 65 and with a disability, however, would fall into the Adults 65 and Older group. Retroactively eligible refers to members who were not yet determined eligible for Health First Colorado on the date of their service, but who later received coverage that extends back to their date of service.
Age Group: Member’s age group at time of service. The data are sorted by total paid amount for telemedicine services received by members in that age category.
Billing Provider Type: Provides a further level of detail of the provider category. Provider Type is the classification of how a provider enrolls with Health First Colorado. The data are sorted by total paid amount for telemedicine services billed by the detailed provider type.
Procedure Codes: These are the CPT/HCPCS codes billed by providers to Health First Colorado as being delivered via telemedicine. The data are sorted by total dollar amount billed for telemedicine services under that code.
Benefit Category: Displays the total paid amount paid for services delivered by telemedicine in the selected benefit category.
Primary Diagnosis Codes: This is the primary diagnosis code listed on the billed telemedicine claim. The data are sorted by total dollar amount billed for telemedicine services under that code.
Member County Map: The map displays the total paid amount for members who received a telemedicine service by county. Dark orange indicates a higher paid amount, light orange indicates lower paid amounts. This is based on the county of residence for each member.
Trend Over Time: The data in this bar graph are actual paid amounts for services in the time period identified. The bar graph shows what portion of telemedicine eligible services were delivered via telemedicine as opposed to in-person care. Paid amounts are in actual totals – meaning these are services that have been provided and paid for. This means they do not include services that have been provided but have not yet been paid for.

Provider Types

The data is broken out into the following provider types:

Federally Qualified Health Centers
Rural Health Clinics
Indian Health Services. Please note this data is limited to the overall trend due to small sample sizes.
Certified Nursing Assistant/Registered Nurse Home Health
Physical Therapy/Occupational Therapy Home Health
Speech Therapy Home Health
Physical Therapy/Occupational Therapy
Speech Therapy
Other medical/professional providers. These are providers with professional claims billing for CPT/HCPCS that are allowed with place of service 02 (telemedicine), excluding those providers already covered in groups above. The most common provider types covered in this category are clinics, pediatric behavioral therapists, nurse practitioners, and physicians.

Coronavirus Disease 2019 (COVID-19) in Colorado: State & National Resources