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.
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	90833	92508	96130	97140	97167	99203	H0004
76802	90834	92521	96131	97150	97168	99204	H0006
76805	90836	92522	96132	97151	97530	99205	H0025
76811	90837	92523	96133	97153	97533	99211	H0031
76812	90838	92524	96136	97154	97535	99212	H0032
76813	90839	92526	96137	97155	97537	99213	H2000
76814	90840	92609	96138	97158	97542	99214	H2011
76815	90846	96110	96139	97161	97755	99215	H2015
76816	90847	96112	96146	97162	97760	99451	H2016
76817	90849	96113	97110	97163	97761	G0108	S9445
90791	90853	96116	97112	97164	97763	G0109	S9485
90792	90863	96121	97129	97165	99201	H0001	T1017
90832	92507	96125	97130	97166	99202	H0002	V5011
92606	99408	99409	H0049	99402	99402	99403	99404
99406	99407	G8431	G8510	G9006	H1005	92610	99441
99442	99443	98966	98967	98968

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.

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