District of Columbia

Disclaimer

PLEASE NOTE: CCHP is providing the following for informational purposes only. We are not providing legal advice or interpretation of the laws and regulations and policies. CCHP encourages you to check with the appropriate state agency for further information and direction. This information should not be construed as legal counsel. Consult with an attorney if you are seeking a legal opinion.

At A Glance
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MEDICAID REIMBURSEMENT

  • Live Video: Yes
  • Store-and-Forward: No
  • Remote Patient Monitoring: No
  • Audio Only: Yes

PRIVATE PAYER LAW

  • Law Exists: Yes
  • Payment Parity: No

PROFESSIONAL REQUIREMENTS

  • Licensure Compacts: IMLC, PSY, PTC
  • Consent Requirements: Yes

FQHCs

  • Originating sites explicitly allowed for Live Video: Yes
  • Distant sites explicitly allowed for Live Video: Yes
  • Store and forward explicitly reimbursed: No
  • Audio-only explicitly reimbursed: No
  • Allowed to collect PPS rate for telehealth: Yes

STATE RESOURCES

  1. Medicaid Program: District of Columbia Medicaid
  2. Administrator: District of Columbia Dept. of Health Care Finance
  3. Regional Telehealth Resource Center: Mid-Atlantic Telehealth Resource Center
Disclaimer

PLEASE NOTE: CCHP is providing the following for informational purposes only. We are not providing legal advice or interpretation of the laws and regulations and policies. CCHP encourages you to check with the appropriate state agency for further information and direction. This information should not be construed as legal counsel. Consult with an attorney if you are seeking a legal opinion.

Last updated 12/07/2023

Definitions

“Telehealth” means the delivery of healthcare services through the use of interactive audio, video, or other electronic media used for the purpose of diagnosis, consultation, or treatment; provided, that services delivered through email messages or facsimile transmissions are not included.

SOURCE: DC Code Sec. 31-3861. (Accessed Dec. 2023).

Last updated 12/07/2023

Parity

SERVICE PARITY

A health insurer offering a health benefits plan in the District may not deny coverage for a healthcare service on the basis that the service is provided through telehealth if the same service would be covered when delivered in person.

A health insurer must reimburse a provider for the diagnosis, consultation or treatment of the patient when the service is delivered by telehealth.

SOURCE: DC Code Sec. 31-3862. (Accessed Dec. 2023).


PAYMENT PARITY

No explicit payment parity.

Last updated 12/07/2023

Requirements

Health insurers are required to pay for telehealth services if the same service would be covered when delivered in-person.

A health insurer shall reimburse the provider for the diagnosis, consultation, or treatment of the insured when the service is delivered through telehealth.

A health insurer may require a deductible, copayment, or coinsurance that may not exceed the amount applicable to the same service delivered in-person.  A health insurer shall not impose any annual or lifetime dollar maximum on coverage for telehealth services other than an annual or lifetime dollar maximum that applies in the aggregate to all items and services under the health benefits plan.

SOURCE: DC Code Sec. 31-3862. (Accessed Dec. 2023).

Last updated 12/06/2023

Definitions

Telemedicine is a service delivery model that delivers healthcare services through a two-way, real time interactive video-audio communication or audio-only communication for the purpose of evaluation, diagnosis, consultation, or treatment.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.2; Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 2. (Accessed Dec. 2023).

Telemedicine is a service delivery model that delivers healthcare services through a two-way, real time interactive video-audio communication for the purpose of evaluation, diagnosis, consultation, or treatment.

SOURCE: Physicians Billing Manual. DC Medicaid. (Sept. 2023) Sec. 15.1, P. 51; FQHC Billing Manual (Oct. 2023), 15.1, P. 51.; Clinic Billing Manual (Sept. 2023) 15.1, P. 49.; Behavioral Health Billing Manual (Sept. 2023) 14.1, p. 67. (Accessed Dec. 2023).

“Telehealth” means the delivery of healthcare services through the use of interactive audio, video, or other electronic media used for the purpose of diagnosis, consultation, or treatment; provided, that services delivered through email messages or facsimile transmissions are not included.

SOURCE; DC Code Sec. 31-3861 & Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 1, (Accessed Dec. 2023).

“Telehealth” means the delivery of healthcare services using interactive audio, video, or other electronic media used for the purpose of diagnosis, consultation, or treatment, provided, that services delivered through audio-only telephones, electronic mail messages, or facsimile transmissions are not included.

SOURCE: Physicians Billing Manual, DC Medicaid (Sept. 2023). Section 15, p. 51.  Clinic Billing Manual (Sept. 2023) 15, P. 49; Behavioral Health Billing Manual (Sept. 2023) 14, p. 67. FQHC Billing Manual (Oct. 2023), 15, P 51. (Accessed Dec. 2023).

For the purposes of coverage by the Department of Health Care Finance (DHCF), telehealth and telemedicine shall be deemed synonymous.

SOURCE: Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 1 & Physicians Billing Manual, DC Medicaid (Sept. 2023). Section 15, p. 51.  Clinic Billing Manual (Sept. 2023) 15, P. 49; Behavioral Health Billing Manual (Sept. 2023) 14, p. 67. FQHC Billing Manual (Oct. 2023), 15, P 51. (Accessed Dec. 2023).

Last updated 12/06/2023

Email, Phone & Fax

When billing for any audio-only telemedicine services, distant site providers shall enter the “93” procedure modifier on the claim.

SOURCE: Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, p. 4,  Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.4. P. 52, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.4, P. 50. FQHC Billing Manual, DC Medicaid 15.4 P. 52. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.4, p. 68., Inpatient Hospital Billing Guide, 11.4, p. 61 (Sept. 2023), Long-Term Care Billing Manual, 15.4, p. 52 (Sept. 2023). (Accessed Dec. 2023).

Under recently effective final regulations, DHCF added audio-only communication as an allowable method of telemedicine services.

A telemedicine provider that utilizes audio-only communication methods is required to use audio equipment that ensures clear communication and includes echo cancellation.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.2. & 910.13Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, p. 6. (Accessed Dec. 2023).

DC Medicaid does not reimburse for service delivery using e-mail messages or facsimile transmissions.

SOURCE: DC Code Sec. 31-3861 & Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, p. 1. (Accessed Dec. 2023).

Services delivered through audio-only telephones, electronic mail messages or facsimile transmission are not included under telehealth services.

SOURCE: Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15. P. 51, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15, P. 49. FQHC Billing Manual, DC Medicaid 15 P. 51. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14, p. 67., Outpatient Hospital Billing Guide, 15.8, p. 74 (Sept. 2023), Inpatient Hospital Billing Guide, 11, p. 60 (Sept. 2023), Long-Term Care Billing Manual, 15, p. 51 (Sept. 2023). (Accessed Dec. 2023).

Last updated 12/06/2023

Live Video

POLICY

DC Medicaid must reimburse for health care services through telehealth if the same service would be covered when delivered in person.

SOURCE: DC Code Sec. 31-3863 (Accessed Dec. 2023).

The DC Medical Assistance Program will reimburse telemedicine services, if the Medicaid beneficiary meets the following conditions:

  • Be enrolled in the DC Medicaid Program;
  • Be physically present at the originating site at the time the telemedicine service is rendered; and
  • Provide written or verbal consent to receive telemedicine services in lieu of in-person healthcare services, consistent with all applicable DC laws.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.5, Physicians Billing Manual. DC Medicaid. Sept. 2023, Sec. 15.2. P. 51 & Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 2Clinic Billing Manual (Sept. 2023) 15.2, P. 49; Behavioral Health Billing Manual (Sept. 2023) 14.2, p. 67. FQHC Billing Manual (Oct. 2023), 15.2, P 51. (Accessed Dec. 2023).


ELIGIBLE SERVICES/SPECIALTIES

Medicaid shall cover and reimburse for healthcare services appropriately delivered through telehealth if the same services would be covered when delivered in person.

SOURCE: DC Code Sec. 31-3863 (Accessed Dec. 2023)

Covered Services:

  • Evaluation and management
  • Consultation of an evaluation and management of a specific healthcare problem requested by an originating site provider
  • Behavioral healthcare services including, but not limited to, psychiatric evaluation and treatment, psychotherapies, and counseling
  • Speech therapy (Outpatient Hospital Billing Guide states: Rehabilitation services including speech therapy)

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.11 & Physicians Billing Manual. DC Medicaid. (Sept. 2023) Sec. 15.7. P. 53-54, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.7, P. 51-52. FQHC Billing Manual, DC Medicaid 15.6.1, P. 53-54. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.7, p. 69-70. & Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 5-6, Outpatient Hospital Billing Guide, 15.8.5, p. 75 (Sept. 2023), Inpatient Hospital Billing Guide, 11.7, p. 62-63 (Sept. 2023), Long-Term Care Billing Manual, 15.7, p. 53-54 (Sept. 2023). (Accessed Dec. 2023).

The provider shall determine if the service can reasonably be delivered at the standard of care via telemedicine.

SOURCE: Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 6. Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.7. P. 54, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.7, P. 51-52. FQHC Billing Manual, DC Medicaid 15.6.1, P. 54. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.7, p. 70., Inpatient Hospital Billing Guide, 11.7, p. 63 (Sept. 2023), Long-Term Care Billing Manual, 15.7, p. 54 (Sept. 2023) (Accessed Dec. 2023).

Distant site providers may only bill for the appropriate codes outlined.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.12.(Accessed Dec. 2023).

Telemedicine listed as a covered service in the following manuals, but no other information is provided.

SOURCE:  DC MMIS Provider Billing Manual (Dental) Sept. 14, 2023, 2.4, p. 12DC MMIS Provider Billing Manual (Dialysis), 2.4, p. 11 (Sept. 14, 2023). DC MMIS Provider Billing Manual (DME/POS), 2.4, p. 12 (Sept. 14, 2023), DC MMIS Provider Billing Manual (EPSDT), 2.4, p. 12 (May 14, 2023), DC MMIS Provider Billing Manual (Home Health), 2.4, p. 10-11. (Sept. 14, 2023), DC MMIS Provider Billing Manual (Hospice) 2.4, p. 10-11, (Sept. 14, 2023), DC MMIS Provider Billing Manual (Independent Lab & X-Ray), 2.4, p. 10-11 (Sept. 14, 2023), DC MMIS Provider Billing Manual (Podiatry), 2.4, p. 10-11 (Sept. 15, 2023), DC MMIS Provider Billing Manual (Residential Treatment Facilities), 2.4, p. 9-10 (Sept. 15, 2023), DC MMIS Provider Billing Manual (Transportation), 2.4, p. 10-11, (Sept. 15, 2023), DC MMIS Provider Billing Manual (Vision), 2.4, p. 10-11 (Sept. 15, 2023). (Accessed Dec. 2023).

Education-Related Services

Office of the State Superintendent of Education shall only bill for distant site services that are allowable healthcare services to be delivered by the individual fee-for-service providers delivering Strong Start DC Early Intervention Program (DC EIP) services under them and can be delivered at the standard of care via telemedicine.

The following reimbursement parameters apply for services delivered under the Office of the State Superintendent of Education through the Strong Start DC Early Intervention Program:

  • The LEA shall only bill for distant site services that are allowable healthcare services to be delivered at DCPS/DCPCS and can be delivered at the standard of care via telemedicine;
  • The LEA shall provide an appropriate primary support professional to attend the medical encounter with the member at the originating site. In instances where it is clinically indicated, an appropriate healthcare professional shall attend the encounter with the member at the originating site.

SOURCE: Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 5. Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.6. P. 53, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.6, P. 51. FQHC Billing Manual, DC Medicaid 15.6, P. 53. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.6, p. 69., Inpatient Hospital Billing Guide, 11.6, p. 62 (Sept. 2023), Long-Term Care Billing Manual, 15.6, p. 53 (Sept. 2023) (Accessed Dec. 2023).

Excluded Services

The Program will not reimburse telemedicine providers for the following:

  • Incomplete delivery of services via telemedicine, including technical interruptions that result in partial service delivery.
  • When a provider is only assisting the beneficiary with technology and not delivering a clinical service.
  • For a telemedicine transaction fee and/or facility fee.
  • For store and forward and remote patient monitoring

SOURCE: Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 6, Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.8. P. 54, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.8, P. 52. FQHC Billing Manual, DC Medicaid 15.6.2, P. 54. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.8, p. 70. Outpatient Hospital Billing Guide, 15.8.6, p. 75 (Sept. 2023), Inpatient Hospital Billing Guide, 11.8, p. 63 (Sept. 2023), Long-Term Care Billing Manual, 15.8, p. 54 (Sept. 2023). (Accessed Dec. 2023).

Mental Health Rehabilitation Services Provider Certification Standards

Telemedicine/telehealth are included under reimbursable services. See rule for specific requirements.

SOURCE: DC Municipal Regulation, Title 22, Ch. 34, Sec. 3434. (Accessed Dec. 2023).

Mental Health Crisis/Emergency Services

A Crisis/Emergency Service is an immediate response face-to-face or via telehealth in accordance with 29 DCMR § 910 to an emergency situation involving a consumer with mental illness or emotional disturbance that is available twenty-four (24) hours per day, seven (7) days per week.

SOURCE: DC Municipal Regulation, Title 22, Ch. 34, Sec. 3422. (Accessed Dec. 2023).

Clinical Care Coordination (CCC)

CCC may be rendered by a qualified practitioner pursuant to § 3432.8 practicing within the scope of their license in person or through telehealth in accordance with 29 DCMR § 910.

Qualified practitioners providing CCC shall:

  • Communicate treatment needs, assessments and treatment information to healthcare providers external to the consumer’s CSA or specialty provider;
  • Facilitate appropriate linkages for the consumer with other healthcare professionals external to the consumer’s CSA or specialty provider; and
  • Provide planning and Plan of Care implementation activities separate from the diagnostic assessment service when the clinician and consumer meet face-to-face or through telehealth pursuant to 29 DCMR § 910.

Providers must document CCC in an encounter note that meets the requirements of § 3413.19 and indicates the intended purpose of the service, the modality of communication, time spent reviewing or preparing records, the actions taken, and the result(s) achieved.

SOURCE: DC Municipal Regulation, Title 22, Ch. 34, Sec. 3432. (Accessed Dec. 2023).


ELIGIBLE PROVIDERS

Telemedicine providers must comply with the following:

  • Be an enrolled Medicaid provider and comply with requirements including having a completed, signed Medicaid Provider Agreement
  • Comply with technical, programmatic and reporting requirements
  • Be licensed; and
  • Appropriately document the beneficiary’s written or verbal consent.
  • Comply with any other applicable consent requirements under District laws, including but not limited to Section 3026 of Title 5-E of the District of Columbia Municipal Regulations if providing telemedicine services at a District of Columbia Public School (DCPS) or District of Columbia Public Charter School (DCPCS).

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.6. (Accessed Dec. 2023)

D.C. Medicaid enrolled providers are eligible to deliver telemedicine services, using fee-for-service reimbursement, at the same rate as in-person consultations. All reimbursement rates for services delivered via telemedicine are consistent with the District’s Medical State Plan and implementing regulations.

The eligible distant site providers include but are not limited to the following:

  • Hospital
  • Nursing facility
  • Federally Qualified Health Center
  • Clinic
  • Physician Group/Office
  • Nurse Practitioner Group/Office
  • DCPS
  • DCPCS; and
  • MHRS provider, ASARS provider and ASTEP provider certified by DBH and eligible to provide behavioral health services set forth under the State Plan

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.7 & Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 3-4. Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.3. P. 52, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.3, P. 50. FQHC Billing Manual, DC Medicaid 15.3, P. 52. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.3, p. 68., Outpatient Hospital Billing Guide, 15.8.3, p. 74-75 (Sept. 2023), Inpatient Hospital Billing Guide, 11.3, p. 61 (Sept. 2023), Long-Term Care Billing Manual, 15.3, p. 52 (Sept. 2023). (Accessed Dec. 2023).

At the discretion of the rendering provider, personnel delivering telemedicine services may work remotely, as long as all other requirements in the rule are met. See sections on technology, documentation in medical records, and confidentiality in guidance document for further specifications.

SOURCE: Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 3-4. Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.3. P. 52, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.3, P. 50. FQHC Billing Manual, DC Medicaid 15.3, P. 52. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.3, p. 68, Inpatient Hospital Billing Guide, 11.3, p. 61 (Sept. 2023), Long-Term Care Billing Manual, 15.3, p. 52 (Sept. 2023) (Accessed Dec. 2023).

When a beneficiary’s home is the originating site, the distant site provider shall ensure the technology in use meets the minimum requirements.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.30. (Accessed Dec. 2023).

Federally Qualified Health Center (FQHC) Reimbursement

In accordance with the District’s Prospective Payment System (PPS) or alternative payment methodology (APM) for FQHCs, the following reimbursement parameters apply:

  • Originating Site: An FQHC provider must deliver an FQHC-eligible service in order to be reimbursed the appropriate PPS, APM, or fee-for-service (FFS) rate at the originating site;
  • Distant Site: An FQHC provider must deliver an FQHC-eligible service that is listed in Appendix A in order to be reimbursed the appropriate PPS, APM, or FFS rate; and
  • Originating and Distant Site: If both the originating and the distant site are FQHCs, for both to receive reimbursement, each site must deliver a different PPS or APM service (e.g. medical or behavioral). If both sites submit a claim for the same PPS or APM service (e.g. medical), then only the distance site will be eligible to receive reimbursement.

SOURCE: Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 4-5.,Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.5. P. 53, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.5, P. 51. FQHC Billing Manual, DC Medicaid 15.5, P. 53. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.5, p. 69. Inpatient Hospital Billing Guide, 11.5, p. 62 (Sept. 2023), Long-Term Care Billing Manual, 15.5, p. 53 (Sept. 2023) (Accessed Dec. 2023).


ELIGIBLE SITES

Eligible services can be delivered via telemedicine when the beneficiary is at the originating site, while the eligible “distant” provider renders services via the audio/video or audio-only connection.

When clinically indicated, an originating site provider or its designee shall be in attendance during the patient’s medical encounter with the distant site professional. An originating site provider shall not be required to be in attendance when the beneficiary prefers to be unaccompanied because the beneficiary feels the subject is sensitive. An originating site provider shall note their attendance status in the patient’s medical record.

To receive reimbursement, originating site providers must deliver an eligible service, distinct from the service delivered at the distant site, in order to receive reimbursement.

Telemedicine providers will submit claims in the same manner the provider uses for in person services.

When billing for services delivered via video-audio telemedicine, distant site providers shall enter the “GT” procedure modifier on the claim. When billing for any audio-only telemedicine services, distant site providers shall enter the “93” procedure modifier on the claim.

Additionally, the distant site provider must appropriately specify the place of service (POS) using the following POS codes:

  • In the event the beneficiary’s home is the originating site, the distant site provider must specify the place of service “10” which is defined as “telehealth provided in patient’s home”.
  • In the event a DCPS or a DCPCS is the originating site, the distant site provider must specific the place of service “03” which is defined as “school”.
  • In the event the beneficiary is at any other eligible originating site (see section IV above), the distant site provider must specify the place of service “02” which is defined as “telehealth provided other than in patient’s home”. When utilizing place of service “02”, the distant site provider must also report the National Provider Identifier (NPI) of the originating site provider in the “referring provider” portion of the claim.

Services billed where telemedicine is the mode of service delivery, but the claim form and/or service documentation do not indicate telemedicine (using the appropriate procedure modifiers and appropriate POS codes) are subject to disallowances in the course of an audit.

The Program will implement this telemedicine service for both providers and participants in the Medicaid fee-for-service, Medicaid managed care, Health Care Alliance, and Immigrant Children’s programs. All requirements stipulated in this provider guidance apply to all programs DHCF administers.

SOURCE: Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 1-4. Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.4. P. 52-53, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.4, P. 50-51. FQHC Billing Manual, DC Medicaid 15.4, P. 52-53. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.4, p. 68-69., Inpatient Hospital Billing Guide, 11.4, p. 61-62 (Sept. 2023), Long-Term Care Billing Manual, 15.4, p. 52-53 (Sept. 2023) (Accessed Dec. 2023).

Effective March 1st, 2023, District health care providers rendering services to beneficiaries in Medicaid fee-for-service, Medicaid managed care, Health Care Alliance, and Immigrant Children’s programs must comply with these revised billing requirements. Refer to Transmittal #23-11 for additional information.

SOURCE: Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.4. P. 52-53, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.4, P. 50-51. FQHC Billing Manual, DC Medicaid 15.4, P. 52-53. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.4, p. 68-69., Inpatient Hospital Billing Guide, 11.4, p. 61-62 (Sept. 2023), Long-Term Care Billing Manual, 15.4, p. 52-53 (Sept. 2023) (Accessed Dec. 2023).

The beneficiary’s home, or other settings authorized by DHCF, may serve as the originating site. When the originating site is the beneficiary’s home the distant site provider is responsible for ensuring that the technology in use meets the minimum requirements set forth in Subsection 910.13.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.7 & 910.30. (Accessed Dec. 2023).

DHCF defines “the definition of “the beneficiary’s home or other settings” to include temporary lodging, such as hotels and homeless shelters. Additionally, for circumstances where the patient, for privacy or other personal reasons, chooses to travel a short distance from the exact home location during a telehealth service, the service is still considered to be furnished” in the home of an individual.

SOURCE: Department of Health Care Finance. Telemedicine Provider Guidance Clarification “Beneficiary’s Home or Other Settings”. March 2023. (Accessed Dec. 2023).

Must be an approved telemedicine provider.  The following providers are considered an eligible originating site:

  • Hospital
  • Nursing facility
  • Federally Qualified Health Center
  • Clinic
  • Physician Group/Office
  • Nurse Practitioner Group/Office
  • District of Columbia Public Schools (DCPS)
  • District of Columbia Public Charter Schools (DCPCS)
  • Mental Health Rehabilitation Service (MHRS) provider, Adult Substance Abuse Rehabilitation Service (ASARS) provider, and Adolescent Substance Abuse Treatment Expansion Program (ASTEP) provider certified by the Department of Behavioral Health (DBH) and eligible to provide behavioral health services set forth under the District of Columbia Medicaid State Plan (State Plan).
  • The beneficiary’s home or other settings identified in guidance published on the DHCF website.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.7, Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 2-3. Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.3. P. 52, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.3, P. 50. FQHC Billing Manual, DC Medicaid 15.3, P. 52. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.3, p. 68. Outpatient Hospital Billing Guide, 15.8.3, p. 74 (Sept. 2023), Inpatient Hospital Billing Guide, 11.3, p. 61 (Sept. 2023), Long-Term Care Billing Manual, 15.3, p. 52 (Sept. 2023). (Accessed Dec. 2023).

When a beneficiary’s home is the originating site, the distant site provider shall ensure the technology in use meets the minimum requirements set forth in Subsection 910.13.

SOURCE: Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 7. (Accessed Dec. 2023).

When DCPS or DCPCS is the originating site provider, a primary support professional (an individual designated by the school) shall be in attendance during the patient’s medical encounter.

An originating site provider shall not be required to be in attendance when the beneficiary prefers to be unaccompanied because the beneficiary feels the subject is sensitive. Sensitive topics may include counseling related to abuse, or other psychiatric matters. An originating site provider shall note their attendance status in the patient’s medical record.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.16-17. (Accessed Dec. 2023).


GEOGRAPHIC LIMITS

No Reference Found


FACILITY/TRANSMISSION FEE

No transaction or facility fee.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.28, Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 6, Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.8. P. 54, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.8, P. 52. FQHC Billing Manual, DC Medicaid 15.6.2, P. 54. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.8, p. 70. Outpatient Hospital Billing Guide, 15.8.6, p. 75 (Sept. 2023), Inpatient Hospital Billing Guide, 11.8, p. 63 (Sept. 2023), Long-Term Care Billing Manual, 15.8, p. 54 (Sept. 2023). (Accessed Dec. 2023).

Last updated 12/06/2023

Miscellaneous

Where an FQHC provides an allowable healthcare service at the originating or distant site, the FQHC shall be reimbursed the applicable rate (PPS, APM or FFS).  If an FQHC is both the originating and distant site, and both sites render the same healthcare service, only the distant site will be reimbursed.

When DCPS or DCPCS provides any of the allowable healthcare services at the originating or distant site, the provider shall only be reimbursed for distant site healthcare services that are Medicaid eligible and are to be delivered in a licensed education agency.

When an originating site and a distant site are CSAs, and the same provider identification number is used for a service delivered via telemedicine, only the distant site provider shall be eligible for reimbursement of the allowable healthcare services described within this section.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.24, 25, 26 & 27. (Accessed Dec. 2023).

See Transmittal for documentation standards for services delivered via telemedicine in DC Medicaid.

SOURCE: DC Medicaid Department of Health Care Finance. Transmittal #20-42: Documentation Standards for Services Delivered Via Telemedicine. Nov. 30, 2020 (Accessed Dec. 2023).

Telemedicine section also appears in Provider Manuals on:

See regulation and telemedicine guidance for specific technology and medical record requirements.

A provider is required to develop a confidentiality compliance plan.

DHCF is required to send a Telemedicine Program Evaluation survey to providers.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.13, 14 & 15 & Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 6-7. (Accessed Dec. 2023).

Emergency Rules

Emergency regulations will expand services for persons with developmental disabilities in the Medicaid Home and Community-Based Services programs and allow the use of remote support services that employ technology.

SOURCE: Department of Health Care Finance, Notice of Emergency and Proposed Rulemaking – Amending 29 DCMR Chapter 90 – Governing Home and Community Based Services Waiver for Individual and Family Support. March 2023. (Accessed Dec. 2023).

Emergency regulations amend billing requirements for Assertive Community Treatment (ACT). This rule also defines the services that constitute a contact, when telehealth can be used, and establishes standards for the types of contacts that a provider must deliver to receive the monthly payment. In addition, this rulemaking updates the procedure by which the Department determines supported employment service eligibility by eliminating the requirement that DBH perform both a needs-based assessment and an independent Diagnostic Assessment or Comprehensive Diagnostic Assessment. DBH will only conduct needs-based assessments to determine service eligibility and such assessments can be conducted through telehealth.

See Transmittals 23-39 and 23-50 for additional details.

SOURCE: Department of Health Care Finance, Notice of Emergency and Proposed Rulemaking – Amending 29 DCMR Chapter 52 – Governing Assertive Community Treatment. Nov. 2023; Department of Behavioral Health – Notice of Emergency and Proposed Rulemaking – Amending 22-A DCMR Ch. 34 and 37 – Assertive Community Treatment Reimbursement, Sept. 2023. (Accessed Dec. 2023).

Last updated 12/06/2023

Out of State Providers

Providers must be enrolled in the Program and licensed, by the applicable Board, to practice in the jurisdiction where services are rendered. For services rendered outside of the District, providers shall meet any licensure requirements of the jurisdiction where the patient is physically located. See Appendix A for illustrative examples.

SOURCE: Department of Health Care Finance. Telehealth Provider Guidance. Jan. 2023. p. 1-2. (Accessed Dec. 2023).

Providers must be enrolled in the Program and licensed, by the applicable Board, to practice in the jurisdiction where services are rendered. For services rendered outside of the District, providers shall meet any licensure requirements of the jurisdiction where he/she is physically located and the jurisdiction where the patient is physically located.

When the provider and patient receiving healthcare services are located in the District of Columbia, all individual practitioners shall be licensed in the state. For healthcare services rendered outside of the District, the provider of the services shall meet any licensure requirements of the jurisdiction in which the patient is physically located.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.9. (Accessed Dec. 2023).

Providers whose practice address is located outside of the geographic boundaries of the District of Columbia are eligible to request consideration for participation in the DC Medicaid program if licensed in the state of the practice address.

SOURCE: Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 5.3.2 P. 17, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 5.3.2, P. 17. FQHC Billing Manual, DC Medicaid 5.3.2 P. 17. (Oct. 2023),  Outpatient Hospital Billing Guide, 5.3.2, p. 17 (Sept. 2023), Inpatient Hospital Billing Guide, 5.3.2, p. 18 (Sept. 2023), Long-Term Care Billing Manual, 5.3.2, p. 20 (Sept. 2023). (Accessed Dec. 2023).

Last updated 12/06/2023

Overview

Medicaid is required to cover healthcare services appropriately delivered through telehealth if the same services would be covered when delivered in person. Medicaid enrolled providers are eligible to deliver telemedicine services at the same rate as in-person consultations. Medicaid is also now covering audio-only telehealth. Medicaid continues to not cover asynchronous telehealth or remote patient monitoring, and billing manuals still reference an exclusion of audio-only in addition to e-mail and fax.

Source: DC Code 31-3863; DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.2. & 910.13.; Telemedicine Provider Guidance, Jan. 2023. (Accessed Dec. 2023).

Last updated 12/07/2023

Cross-State Licensing

Must have license to practice medicine in the District of Columbia.

For any services rendered outside the District of Columbia, the provider of the services shall meet any licensure requirement of the jurisdiction in which the patient is physically located.

A District of Columbia-licensed physician may rely on a patient evaluation performed by another District of Columbia-licensed physician if the former is providing coverage for the latter.

SOURCE: DC Regs. Sec. 17-4618.1 & .6. (Accessed Dec. 2023).

Expedited licensure pathways exist for certain out-of-state physicians. See DC Health Regulation and Licensing Administration DMV Physician Licensure Reciprocity Pathway and DC Board of Medicine website for more details.

SOURCE: DC Board of Medicine. DMV Reciprocity Pathway. (Accessed Dec. 2023).

Last updated 12/07/2023

Definitions

Telemedicine – The practice of medicine by a licensed practitioner to provide patient care, treatment or services, between a licensee in one location and a patient in another location with or without an intervening healthcare provider, through the use of health information and technology communications, subject to the existing standards of care and conduct.

SOURCE: DC Regs. Sec. 17-4699., DC Department of Health Board of Medicine Policy No. 15-01 (Accessed Dec. 2023).

“Telehealth” means the delivery of healthcare services through interactive audio, video, or other electronic media used for the purpose of diagnosis, consultation, or treatment; provided, that services delivered through audio-only telephones, electronic mail messages, or facsimile transmissions are not included.

SOURCE: Code of the District of Columbia Sec. 7-3201(13). (Accessed Dec. 2023).

Last updated 12/07/2023

Licensure Compacts

Member of the Interstate Medical Licensure Compact.

SOURCE: Interstate Medical Licensure Compact. (Accessed Dec. 2023).

Member of Physical Therapy Compact

SOURCE: PT Compact, Compact Map (Accessed Dec. 2023).

Member of the Psychology Interjurisdictional Compact.

SOURCE: PSYPACT, Map, (Accessed Dec. 2023).

* See Compact websites for implementation and license issuing status and other related requirements.

Last updated 12/07/2023

Miscellaneous

Recently effective legislation creates requirements for members of licensing boards related to residency and active practice, in addition to stating that they must demonstrate that their practice in the District is not primarily through telehealth.

SOURCE: DC Official Code Sec. 3-1204.01; B 25-0312 (2023 Session). (Accessed Dec. 2023).

Last updated 12/07/2023

Online Prescribing

A physician shall perform a patient evaluation to establish diagnoses and identify underlying conditions or contraindications to recommended treatment options before providing treatment or prescribing medication for a patient utilizing the appropriate standards of care, except when performing interpretive services.

If a physician-patient relationship does not include a prior in-person interaction with a patient, the physician may use real-time telemedicine to allow a free exchange of protected health information between the patient and the physician to establish the physician-patient relationship and perform the patient evaluation.

SOURCE: DC Reg Sec. 17-4618.3 & 4 (Accessed Dec. 2023).

Last updated 12/07/2023

Professional Board Standards

Board of Medicine

SOURCE: DCMR Title 17, Ch. 46 Sec. 4618.; Board of Medicine Policy No. 15-01 Telemedicine Policy. (Accessed Dec. 2023).

Professional Art Therapy

SOURCE: DCMR Title 17, Ch. 116 Sec. 11613. (Accessed Dec. 2023).

Last updated 12/07/2023

Definition of Visit

No explicit definition.

The FQHC will receive a separate encounter rate for each type of FQHC service offered: primary care, behavioral health, preventive/diagnostic dental and comprehensive dental. The FQHC will be able to bill for same day encounters and be paid one encounter per day.

SOURCE: FQHC Billing Manual, DC Medicaid 17.1.1, P. 67. (Oct. 2023). (Accessed Dec. 2023).

Last updated 12/07/2023

Home Eligible

The beneficiary’s home, or other settings authorized by DHCF, may serve as the originating site. When the originating site is the beneficiary’s home the distant site provider is responsible for ensuring that the technology in use meets the minimum requirements set forth in Subsection 910.13.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.7 & 910.30. (Accessed Dec. 2023).

An originating site shall include the following provider types and settings:

  • Hospital
  • Nursing Facility
  • Federally Qualified Health Center
  • Clinic
  • Physician Group/Office
  • Nurse Practitioner Group/Office
  • District of Columbia Public Schools (DCPS)
  • District of Columbia Public Charter Schools (DCPCS)
  • Mental Health Rehabilitation Service (MHRS) provider, Adult Substance Abuse Rehabilitation Service (ASARS) provider, and Adolescent Substance Abuse Treatment Expansion Program (ASTEP) provider
  • The beneficiary’s home or other settings identified in guidance published on the DHCF website at dhcf.dc.gov.

SOURCE: DC MMIS Provider Billing Manual (FQHC), 15.3, p. 52 (Oct. 2023). (Accessed Dec. 2023).

Last updated 12/07/2023

Modalities Allowed

Live Video

FQHCs are allowed to use live video telehealth.

See: DC Medicaid Live Video


Store and Forward

DC Medicaid does not cover store-and-forward.

See: DC Medicaid Store-and-Forward


Remote Patient Monitoring

DC Medicaid does not cover RPM.

See: DC Medicaid RPM


Audio-Only

DC Medicaid recently began covering audio-only, but there is no explicit mention for FQHCs.

See: DC Medicaid Email, Phone, & Fax

Last updated 12/07/2023

Patient-Provider Relationship

No Reference Found

Last updated 12/07/2023

PPS Rate

Where an FQHC provides an allowable healthcare service at the originating or distant site, the FQHC shall be reimbursed the applicable rate (PPS, APM or FFS).  If an FQHC is both the originating and distant site, and both sites render the same healthcare service, only the distant site will be reimbursed.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.24, 25, 26 & 27. (Accessed Dec. 2023).

In accordance with the District’s Prospective Payment System (PPS) or alternative payment methodology (APM) for FQHCs, the following reimbursement parameters apply:

  • Originating Site: An FQHC provider must deliver an FQHC-eligible service in order to be reimbursed the appropriate PPS, APM, or fee-for-service (FFS) rate at the originating site;
  • Distant Site: An FQHC provider must deliver an FQHC-eligible service that is listed in Appendix A in order to be reimbursed the appropriate PPS, APM, or FFS rate; and
  • Originating and Distant Site: If both the originating and the distant site are FQHCs, for both to receive reimbursement, each site must deliver a different PPS or APM service (e.g. medical or behavioral). If both sites submit a claim for the same PPS or APM service (e.g. medical), then only the distance site will be eligible to receive reimbursement.

SOURCE: Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 4-5.,Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.5. P. 53, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.5, P. 51. FQHC Billing Manual, DC Medicaid 15.5, P. 53. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.5, p. 69. Inpatient Hospital Billing Guide, 11.5, p. 62 (Sept. 2023), Long-Term Care Billing Manual, 15.5, p. 53 (Sept. 2023) (Accessed Dec. 2023).

D.C. Medicaid enrolled providers are eligible to deliver telemedicine services, using fee-for-service reimbursement, at the same rate as in-person consultations. All reimbursement rates for services delivered via telemedicine are consistent with the District’s Medical State Plan and implementing regulations.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.8 & Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 4. Physicians Billing Manual.  DC Medicaid.  (Sept. 2023) Sec. 15.4. P. 52, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.4, P. 50. FQHC Billing Manual, DC Medicaid 15.4, P. 52. (Oct. 2023), Behavioral Health Billing Manual (Sept. 2023) 14.4, p. 68., Outpatient Hospital Billing Guide, 15.8.4, p. 75 (Sept. 2023), Inpatient Hospital Billing Guide, 11.4, p. 61 (Sept. 2023), Long-Term Care Billing Manual, 15.4, p. 52 (Sept. 2023). (Accessed Dec. 2023).

If an FQHC does not elect the APM, it will be paid the PPS for every encounter, regardless of the type of encounter. New FQHC providers will be reimbursed at the PPS rate. The FQHC will receive a separate encounter rate for each type of FQHC service offered: primary care, behavioral health, preventive/diagnostic dental and comprehensive dental.

SOURCE: FQHC Billing Manual, DC Medicaid 17.1, P. 67-68. (Oct. 2023). (Accessed Dec. 2023).

Last updated 12/07/2023

Same Day Encounters

The FQHC will receive a separate encounter rate for each type of FQHC service offered: primary care, behavioral health, preventive/diagnostic dental and comprehensive dental. The FQHC will be able to bill for same day encounters and be paid one encounter per day.

FQHCs must ensure that treatment requiring multiple procedures generally provided in a single visit are billed as a single encounter unless multiple visits are required to complete the treatment plan. Every claim should be a complete record of all services provided for the date of service.

SOURCE: FQHC Billing Manual, DC Medicaid 17.1.1, P. 67-68. (Oct. 2023). (Accessed Dec. 2023).