Modalities Allowed
Live Video
Telemedicine may be provided through interactive audio, interactive video, or interactive data communication, including but not limited to telephone, relay calls, interactive audiovisual modalities, and live chat, as long as the technologies are compliant with the federal “Health Insurance Portability and Accountability Act of 1996”, Pub.L. 104-191, as amended. The health-care or mental health-care services are subject to reimbursement policies developed pursuant to the medical assistance program. A telemedicine service meets the definition of a face-to-face encounter for a rural health clinic, Indian health service, or federally qualified health center.
Health First Colorado allows 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.
SOURCE: CO Department of Health Care Policy and Financing. “Telemedicine Billing Manual” 2/25, (Accessed May 2025).
Store and Forward
The member typically must be present during any Telemedicine visit, limiting ability to use store-and-forward modalities.
See: CO Medicaid Store-and-Forward
Health First Colorado only allows reimbursement for a visit, which is a face-to-face encounter between a Health First Colorado member and a provider listed at 10 CCR 2505-10 sections 8.700.6 and 8.700.1. A direct visualization by a physician without the member present is not billable as an encounter. For the technical component of an imaging service, when free standing FQHCs own the equipment, the costs are accounted for in the Prospective Payment System (PPS) rate and the technical component is not billable. When free standing FQHCs order imaging from another provider, the technical component services are billed by the rendering provider. For hospital based FQHCs, the costs of imaging and labs are removed from the cost report when determining the encounter rate. Since the costs are removed from the cost report, the technical component of imaging may be billed separately to Health First Colorado by the hospital.
eConsult dialogues between Treating Practitioners and Consulting Practitioners do not meet the definition of an FQHC or RHC visit as defined in CCR 8.700. Costs associated with performing eConsults through an FQHC/RHC are considered allowable costs for the cost report and will be included in the calculation of the reimbursement rate for a patient visit at an FQHC/RHC.
SOURCE: CO Department of Health Care Policy and Financing. “Telemedicine Billing Manual” 2/25, (Accessed May 2025).
eConsult visits between primary care providers and specialty providers do not meet the definition of an FQHC or RHC visit as defined in 10 C.C.R. 2505-10 8.700. Costs associated with services provided through eConsult visits through an FQHC/RHC are considered allowable costs for the cost report and will be included in the calculation of the reimbursement rate for a patient visit at an FQHC/RHC.
SOURCE: CO Department of Health Care Policy and Financing, FQHC/RHC Billing Manual (4/25). (Accessed May 2025).
Remote Patient Monitoring
Health First Colorado only allows RPM coverage in limited circumstances.
See: CO Medicaid RPM
For FQHCs/RHCs, a direct visualization by a physician without the member present is not billable as an encounter. For the technical component of an imaging service, when free standing FQHCs own the equipment, the costs are accounted for in the Prospective Payment System (PPS) rate and the technical component is not billable. When free standing FQHCs order imaging from another provider, the technical component services are billed by the rendering provider.
Audio-Only
Any health benefits provided through interactive audio (including but not limited to telephone and relay calls), interactive video (including but not limited to interactive audiovisual modalities), or interactive data communication (including but not limited to live chat and excluding text messaging, electronic mail, and facsimile transmission) must meet the same standard of care as in-person care in accordance with Section 8.095.
SOURCE: Colorado Adopted Rule 8.700.1. (Accessed May 2025).
Health First Colorado allows 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.
SOURCE: CO Department of Health Care Policy and Financing. “Telemedicine Billing Manual” 2/25. (Accessed May 2025).
eConsult dialogues between Treating Practitioners and Consulting Practitioners do not meet the definition of an FQHC or RHC visit as defined in CCR 8.700. Costs associated with performing eConsults through an FQHC/RHC are considered allowable costs for the cost report and will be included in the calculation of the reimbursement rate for a patient visit at an FQHC/RHC.
SOURCE: CO Department of Health Care Policy and Financing. “Telemedicine Billing Manual” 2/25, (Accessed May 2025).
eConsult visits between primary care providers and specialty providers do not meet the definition of an FQHC or RHC visit as defined in 10 C.C.R. 2505-10 8.700. Costs associated with services provided through eConsult visits through an FQHC/RHC are considered allowable costs for the cost report and will be included in the calculation of the reimbursement rate for a patient visit at an FQHC/RHC.
SOURCE: CO Department of Health Care Policy and Financing, FQHC/RHC Billing Manual (4/25). (Accessed May 2025).
See: CO Medicaid Email, Phone and Fax
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