Modalities Allowed

Live Video

Temporary Policy – Ends Dec. 31, 2024

In the case that such emergency period ends before December 31, 2024, during the period beginning on the first day after the end of such emergency period and ending on December 31, 2024—

• the Secretary shall pay for telehealth services that are furnished via a telecommunications system by a Federally qualified health center or a rural health clinic to an eligible telehealth individual enrolled under this part notwithstanding that the Federally qualified health center or rural clinic providing the telehealth service is not at the same location as the beneficiary;
• the amount of payment to a Federally qualified health center or rural health clinic that serves as a distant site for such a telehealth service shall be determined under subparagraph (B); and
• for purposes of this subsection—
  • the term “distant site” includes a Federally qualified health center or rural health clinic that furnishes a telehealth service to an eligible telehealth individual; and
  • the term “telehealth services” includes a rural health clinic service or Federally qualified health center service that is furnished using telehealth to the extent that payment codes corresponding to services identified by the Secretary under clause (i) or (ii) of paragraph (4)(F) are listed on the corresponding claim for such rural health clinic service or Federally qualified health center service.

SOURCE:  Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m).  (Accessed Jul. 2023).

Security Act (CARES Act). Section 3704 of the CARES Act authorized RHCs and FQHCs to provide distant site telehealth services to Medicare patients during the COVID-19 PHE. Section 4113 of the Consolidated Appropriations Act, 2023, extended this authority through December 31, 2024.

Any health care practitioner working for you within your scope of practice can provide distant site telehealth services. Practitioners can provide distant site telehealth services – approved by Medicare as a distant site telehealth service under the physician fee schedule (PFS) – from any location, including their home, during the time that they’re working for you.

The statutory language authorizing RHCs and FQHCs as distant site telehealth providers requires that we develop payment rates similar to the national average payment rates for comparable telehealth services under the PFS.  See factsheet for rates.

These rates are the average amount for all PFS telehealth services on the telehealth list, weighted by volume for those services reported under the PFS during the given timeframes. Because we made these changes in policy on an emergency basis, we made changes to claims processing systems in several stages.

Starting July 1, 2020, RHCs and FQHCs should submit G2025 and you may append modifier 95, but it isn’t required. Table 2 shows these reporting instructions.

For services provided between March 18, 2020, through May 11, 2023, which is the end of the COVID-19 PHE, we’ll pay all of the reasonable costs for specified categories of evaluation and management (E/M) services if they result in an order for or administration of a COVID-19 test and relate to the supply or administration of such test or to the evaluation of a person for purposes of deciding the need for such test. For the specified E/M services related to COVID19 testing, including when provided via telehealth, you must waive the collection of coinsurance from patients. For services in which Medicare waives the coinsurance, you must put the “CS” modifier on the service line. Don’t collect coinsurance from patients if the coinsurance is waived.

For dates of service through December 31, 2024, you can provide any Medicare-approved telehealth services under the PFS.

SOURCE: Centers for Medicare and Medicaid Services, New & Expanded Flexibilities for Rural Health Clinics & Federally Qualified Health Centers, MLN Matters Number: SE20016, May 12, 2023, (Accessed Jun. 2023).

Mental Health Visit – Delayed to Jan 1, 2025

A mental health visit is a medically-necessary face-to-face encounter between an RHC or FQHC patient and an RHC or FQHC practitioner during which time one or more RHC or FQHC mental health services are rendered. Effective January 1, 2022, a mental health visit is a face-to-face encounter or an encounter furnished using interactive, real-time, audio and video telecommunications technology or audio-only interactions in cases where the patient is not capable of, or does not consent to, the use of video technology for the purposes of diagnosis, evaluation or treatment of a mental health disorder.

The CAA, 2023 extends the telehealth policies of the CAA, 2022 through December 31, 2024 if the PHE ends prior to that date. The in-person visit requirements for mental health telehealth services and mental health visits furnished by RHCs and FQHCs begin on January 1, 2025 if the PHE ends prior to that date. There must be an in-person mental health service furnished within 6 months prior to the furnishing of the mental health service furnished via telecommunications and that an in-person mental health service (without the use of telecommunications technology) must be provided at least every 12 months while the beneficiary is receiving services furnished via telecommunications technology for diagnosis, evaluation, or treatment of mental health disorders, unless, for a particular 12-month period, the physician or practitioner and patient agree that the risks and burdens outweigh the benefits associated with furnishing the in-person item or service, and the practitioner documents the reasons for this decision in the patient’s medical record.

RHCs and FQHCs are instructed to append modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) in instances where the mental health visit was furnished using audio-video communication technology and to append modifier 93 (Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System) in cases where the service was furnished using audio-only communication.

Mental health services that qualify as stand-alone billable visits in an FQHC are listed on the FQHC center website, http://www.cms.gov/Center/Provider-Type/FederallyQualified-Health-Centers-FQHC- Center.html. Services furnished must be within the practitioner’s state scope of practice.

Medicare-covered mental health services furnished incident to an RHC or FQHC visit are included in the payment for a medically necessary mental health visit when an RHC or FQHC practitioner furnishes a mental health visit. Group mental health services do not meet the criteria for a one-one-one, face-to-face encounter in an FQHC or RHC.

SOURCE:  CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, Jan. 26, 2023, pg. 20 (Accessed Jul. 2023).

RHCs and FQHCs can provide telecommunications for mental health visits using audio-video technology and audio-only technology. You may use audio-only technology in situations when your patient can’t access or doesn’t consent to use audio-video technology. You can report and get paid in the same way as in-person visits.

• Audio-video visits: Use modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System).
• Audio-only visits: Use new service-level modifier FQ or 93.

These in-person visit requirements apply only to a patient getting mental health visits via telecommunications at home:

• There must be an in-person mental health visit 6 months before the telecommunications visit
• In general, there must be an in-person mental health visit at least every 12 months while the patient is getting services from you via telecommunications to diagnose, evaluate, or treat mental health disorders

NOTE: Section 4113 of the Consolidated Appropriations Act (CAA), 2023, delayed the in-person visit requirements under Medicare for mental health visits that RHCs and FQHCs provide via telecommunications technology. For RHCs and FQHCs, we won’t require in-person visits until January 1, 2025.

CMS will allow for limited exceptions to the requirement for an in-person visit every 12 months based on patient circumstances in which the risks and burdens of an in-person visit may outweigh the benefit. These include, but aren’t limited to, when:

• An in-person visit is likely to cause disruption in service delivery or has the potential to worsen the patient’s condition
• The patient getting services is in partial or full remission and only needs maintenance level care
• The clinician’s professional judgment says that the patient is clinically stable and that an in-person visit has the risk of worsening the patient’s condition, creating undue hardship on self or family
• The patient is at risk of withdrawing from care that’s been effective in managing the illness

With proper documentation, the in-person visit requirement isn’t applicable for that 12-month period. You must document the circumstance in the patient’s medical record.

SOURCE: Mental Health Visits via Telecommunications for Rural Health Clinics and Federally Qualified Health Centers, MLN Matters SE22001, (May 23, 2023), (Accessed Jun. 2023).

* The US Health and Human Services Administration maintains a website that summarizes information for Billing Medicare as a safety-net provider.

See: Federal Medicare Live Video

Store and Forward

FQHCs can get reimbursement for general care management services (includes chronic care management, principal care management, chronic pain management and general behavioral health integration services, which can include store and forward elements.  See manual for details.

SOURCE:  CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, Jan. 26, 2023, pg. 27-28 (Accessed Jul. 2023).

Beginning March 1, 2020, and for the duration of the COVID-19 PHE, virtual communication services have been expanded to include online digital evaluation and management services, which are non-face-to-face, patient-initiated, digital communications using a secure patient portal. The payment rate for the virtual communication services HCPCS code (G0071) reflects the online digital evaluation and management CPT codes (99421, 99422, and 99423) in addition to HCPCS codes for virtual communication services (G2012 and G2010). Therefore, payment for HCPCS code G0071 is set at the average of the national non-facility PFS payment rates for these five codes. All virtual communication services would also be available to new patients that had not been seen in the RHC or FQHC within the previous 12 months. Additionally, in situations where obtaining prior beneficiary consent would interfere with the timely provision of these services, or the timely provision of the monthly care management services, consent could be obtained when the services are furnished instead of prior to the service being furnished, but must be obtained before the services are billed. We also have allowed patient consent to be acquired by staff under the general supervision of the RHC or FQHC practitioner for the virtual communication and monthly care management codes.

When the COVID-19 PHE ends, the payment for virtual communication services (G0071) will no longer include online digital evaluation and management services and these services may only be provided to established patients. Additionally, consent for services will require direct supervision.

SOURCE: Centers for Medicare and Medicaid Services, Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs): CMS Flexibilities to Fight COVID-19, 5/10/23, (Accessed Jun. 2023).

See: Federal Medicare Store-and-forward

Remote Patient Monitoring

Services such as RPM are not separately billable because they are already included in the RHC AIR or FQHC PPS payment.

SOURCE: CY 2020 Final Physician Fee Schedule. CMS, p. 432, (Accessed Jul. 2023).

FQHCs can also be reimbursed for chronic care management, which can include elements of RPM.

SOURCE:  Centers for Medicare and Medicaid Services, Care Management in Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs), Frequently Asked Questions, Dec. 2019, (Accessed Jul. 2023).

FQHCs can get reimbursement for general care management services (includes chronic care management, principal care management, chronic pain management and general behavioral health integration services, which can include  RPM elements.  See manual for details.

SOURCE:  CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, Jan. 26, 2023, pg. 27-28 (Accessed Jul. 2023).

See: Federal Medicare Remote Patient Monitoring

Audio-Only

Temporary Policy – Ends Dec. 31, 2024

In the case that such emergency period ends before December 31, 2024, during the period beginning on the first day after the end of such emergency period and ending on December 31, 2024—

• the Secretary shall pay for telehealth services that are furnished via a telecommunications system by a Federally qualified health center or a rural health clinic to an eligible telehealth individual enrolled under this part notwithstanding that the Federally qualified health center or rural clinic providing the telehealth service is not at the same location as the beneficiary;
• the amount of payment to a Federally qualified health center or rural health clinic that serves as a distant site for such a telehealth service shall be determined under subparagraph (B); and
• for purposes of this subsection—
  • the term “distant site” includes a Federally qualified health center or rural health clinic that furnishes a telehealth service to an eligible telehealth individual; and
  • the term “telehealth services” includes a rural health clinic service or Federally qualified health center service that is furnished using telehealth to the extent that payment codes corresponding to services identified by the Secretary under clause (i) or (ii) of paragraph (4)(F) are listed on the corresponding claim for such rural health clinic service or Federally qualified health center service.

SOURCE:  Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m).  (Accessed Jul. 2023).

Mental Health Visit – Delayed to Jan 1, 2025

A mental health visit is a medically-necessary face-to-face encounter between an RHC or FQHC patient and an RHC or FQHC practitioner during which time one or more RHC or FQHC mental health services are rendered. Effective January 1, 2022, a mental health visit is a face-to-face encounter or an encounter furnished using interactive, real-time, audio and video telecommunications technology or audio-only interactions in cases where the patient is not capable of, or does not consent to, the use of video technology for the purposes of diagnosis, evaluation or treatment of a mental health disorder.

The CAA, 2023 extends the telehealth policies of the CAA, 2022 through December 31, 2024 if the PHE ends prior to that date. The in-person visit requirements for mental health telehealth services and mental health visits furnished by RHCs and FQHCs begin on January 1, 2025 if the PHE ends prior to that date. There must be an in-person mental health service furnished within 6 months prior to the furnishing of the mental health service furnished via telecommunications and that an in-person mental health service (without the use of telecommunications technology) must be provided at least every 12 months while the beneficiary is receiving services furnished via telecommunications technology for diagnosis, evaluation, or treatment of mental health disorders, unless, for a particular 12-month period, the physician or practitioner and patient agree that the risks and burdens outweigh the benefits associated with furnishing the in-person item or service, and the practitioner documents the reasons for this decision in the patient’s medical record.

RHCs and FQHCs are instructed to append modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) in instances where the mental health visit was furnished using audio-video communication technology and to append modifier 93 (Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System) in cases where the service was furnished using audio-only communication.

Mental health services that qualify as stand-alone billable visits in an FQHC are listed on the FQHC center website, http://www.cms.gov/Center/Provider-Type/FederallyQualified-Health-Centers-FQHC- Center.html. Services furnished must be within the practitioner’s state scope of practice.

Medicare-covered mental health services furnished incident to an RHC or FQHC visit are included in the payment for a medically necessary mental health visit when an RHC or FQHC practitioner furnishes a mental health visit. Group mental health services do not meet the criteria for a one-one-one, face-to-face encounter in an FQHC or RHC.

SOURCE:  CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, Jan. 26, 2023, pg. 20 (Accessed Jul. 2023).

RHCs and FQHCs can provide telecommunications for mental health visits using audio-video technology and audio-only technology. Use audio-only technology in situations when the patient can’t access or doesn’t consent to use audio-video technology. They can report and get paid in the same way as in-person visits.

Audio-only visits: Use new service-level modifier FQ or 93.

SOURCE: Mental Health Visits via Telecommunications for Rural Health Clinics and Federally Qualified Health Centers, MLN Matters SE22001, (May 23, 2023), (Accessed Jun. 2023).

Also, effective March 1, 2020, these services included CPT codes 99441, 99442, and 99443, which are audio-only telephone E/M services. You can provide and bill for these services using HCPCS code G2025. To bill for these services, a physician or Medicare provider who may report E/M services must provide at least 5 minutes of telephone E/M service to an established patient, parent, or guardian. You can’t bill for these services if they start from a related E/M service provided within the previous 7 days or lead to an E/M service or procedure within the next 24 hours or soonest available appointment.

SOURCE: Centers for Medicare and Medicaid Services, Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs): CMS Flexibilities to Fight COVID-19, 5/10/23, (Accessed Jun. 2023).

Virtual Communications

Medicare waives the RHC and FQHC face-to-face requirements when an RHC or FQHC furnishes communication technology-based services (may include audio-only/telephone) to an RHC or FQHC patient. RHCs and FQHCs receive payment for communication technology-based services or remote evaluation services when an RHC or FQHC practitioner provides at least 5 minutes of communications-based technology or remote evaluation services to a patient who has been seen in the RHC or FQHC within the previous year.

SOURCE:  Medicare Learning Network Matters Factsheet, MM10843, Aug. 10, 2018, & Virtual Communication Services RHCs and FQHCs FAQs, December 2018, (Accessed Jul. 2023).

FQHCs can get reimbursement for general care management services (includes chronic care management, principal care management, chronic pain management and general behavioral health integration services, which can include virtual communications elements).  See manual for details.

SOURCE:  CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, Jan. 26, 2023, pg. 27-28 (Accessed Jul. 2023).

See: Federal Medicare Email, Phone & Fax

Live Video

FQHC manual instructs providers to reference Physician manual. Physician manual outlines reimbursement for live video telemedicine.  See:  AL Medicaid Live Video

Store and Forward

Asynchronous is included in definition of telemedicine and telehealth but no further mention of it is made in telemedicine policy.

There is no reference found for store-and-forward for FQHCs.  See: AL Medicaid Store-and-Forward.

Remote Patient Monitoring

There is no reference found for RPM in Medicaid for FQHCs specifically.  See: AL Medicaid Remote Patient Monitoring

Audio-Only

Audio-only is reimbursed in AL Medicaid, per the AL Telemedicine policy with modifier FQ, however no explicit mention is made to whether or not FQHCs specifically can be reimbursed for the modality. See: AL Medicaid Email, Phone and Fax

Live Video

Submitting a claim for a telemedicine service is identical to the way a claim would be submitted for a face-to-face visit. Depending on the method of telemedicine used and the role of the provider in the consultation determines whether a modifier should be added to the procedure code. The role of the provider falls into three categories:

• Referring Provider: Evaluates a patient, determines the need for a consultation, and arranges services of a consulting provider for the purpose of diagnosis and treatment.
• Presenting Provider: Introduces a patient to the consulting provider during an interactive telemedicine session (may assist in the telemedicine consultation).
• Consulting Provider: Evaluates the patient and/or medical data/images using telemedicine mode of delivery upon recommendation of the referring provider.

SOURCE: AK Dept. of Health and Social Services, FQHC/RHC (6/12), Accessed Jun. 2023).

The department shall pay for all services covered by the medical assistance program provided through telehealth if the department pays for those services when provided in person, including: …

• services provided by a rural health clinic or a federally qualified health center.

SOURCE: AK Statute Sec. 47.07.069, (Accessed Jun. 2023).

Store and Forward

A consulting provider may send data he/she has received during a store-and-forward telemedicine consultation to another consulting provider (with equal or greater scope of practice as determined by his/her occupational license or level of expertise within their field of specialty).

SOURCE: AK Dept. of Health and Social Services, FQHC/RHC (6/12), Accessed Jun. 2023).

The department shall pay for all services covered by the medical assistance program provided through telehealth if the department pays for those services when provided in person, including: …

• services provided by a rural health clinic or a federally qualified health center.

• services provided through audio, visual, or data communications, alone or in any combination, or through communications over the Internet or by telephone, including a telephone that is not part of a dedicated audio conference system, electronic mail, text message, or two-way radio;

SOURCE: AK Statute Sec. 47.07.069, (Accessed Jun. 2023).

Remote Patient Monitoring

No reference found.

Audio-Only

Effective 8/1/2020 through the duration of the COVID-19 public health emergency: Audio only mode of delivery may be reimbursed for the services listed below using CPT codes 98966, 98967, and 98968 (telephone assessment and management services) if all other modes of deliveries, including audio/video modalities, are not available to the recipient. Record documentation should clearly indicate the rationale for utilizing an audio only mode of delivery.

Services covered through an audio only mode of delivery:

• Psychiatric diagnostic interview procedures
• Psychological testing and examination services
• Individual psychotherapy
• Health and behavior assessment and intervention services

SOURCE: AK Dept. of Health and Social Services, FQHC/RHC (6/12), Accessed Jun. 2023).

The department shall pay for all services covered by the medical assistance program provided through telehealth if the department pays for those services when provided in person, including: …

• services provided by a rural health clinic or a federally qualified health center.

• services provided through audio, visual, or data communications, alone or in any combination, or through communications over the Internet or by telephone, including a telephone that is not part of a dedicated audio conference system, electronic mail, text message, or two-way radio;

SOURCE: AK Statute Sec. 47.07.069, (Accessed Jun. 2023).

Audio-Only

Manual specifies that telehealth and telemedicine may qualify as an FQHC/RHC visit if it meets the requirements of the Telehealth and Telemedicine AMPM Manual 320-I.  Reimbursement is provided for audio-only coverage for certain codes in manual section 320-I.  See: AZ Medicaid Email, Phone and Fax.  However, because it is not face-to-face and doesn’t meet the definition of a FQHC visit, it is unclear whether or not this is reimbursable.

Live Video

FQHC Manual refers providers to Telemedicine policy manual for encounters.  AR Medicaid covers live video telemedicine in some circumstances.

See:  AR Medicaid Live Video

Store and Forward

FQHC Manual refers providers to Telemedicine policy manual for encounters.  No information regarding store-and-forward reimbursement is found in the telemedicine policy section beyond a definition.

See: AR Medicaid Store-and-Forward.

Remote Patient Monitoring  

FQHC Manual refers providers to Telemedicine policy manual for encounters.  No information regarding remote patient monitoring reimbursement is found in the telemedicine policy section beyond a definition.

See: AR Medicaid Remote Patient Monitoring

Audio-Only

FQHC Manual refers providers to Telemedicine policy manual for encounters.  Audio-only is allowed only in certain circumstances in telemedicine policy section.  No direct reference to whether or not an FQHC can use the modality is provided.

See: AR Medicaid Email, Phone and Fax

Live Video

Synchronous interaction means a real-time audio-visual, two-way interaction between a new or established patient and an FQHC or RHC billable provider at a distant site.

Medi-Cal benefits or services being provided are clinically appropriate and meet the procedural and billing requirements that would have applied if the applicable services were delivered via a face-to-face encounter.

An FQHC patient who receives telehealth services shall otherwise be eligible to receive in-person services from the FQHC pursuant to the federal Health Resources Services Administration requirements.

A patient may be “established” via synchronous interaction if all of the conditions of the “New Patient” requirements in this manual section are met.

SOURCE: CA Department of Health Care Services (DHCS).  Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHC) Outpatient Services Manual. Jan. 2023. Pg. 14. (Accessed Jun. 2023).

A visit shall also include an encounter between an FQHC patient and a physician, physician assistant, nurse practitioner, certified nurse-midwife, clinical psychologist, licensed clinical social worker, visiting nurse, comprehensive perinatal services program practitioner, dental hygienist, dental hygienist in alternative practice, or marriage and family therapist using video synchronous interaction, when services delivered through that interaction meet the applicable standard of care.

SOURCE: WIC 14132.100, as amended by SB 184 (2022 Session). (Accessed Jun. 2023).

See: CA Medicaid Live Video

Store and Forward

Asynchronous store and forward means the transmission of a patient’s medical information from an originating site to the billable provider at a distant site.

Medi-Cal benefits or services being provided are clinically appropriate and meet the procedural and billing requirements that would have applied if the applicable services were delivered via a face-to-face encounter.

A patient may be “established” on an asynchronous store and forward service, if all of the conditions of the “New Patient” requirements in this manual section are met.

Only one visit or store and forward service may be billed at the PPS rate when there is a service payment contract with a non-FQHC/RHC, contractor, or another FQHC or RHC. Conversely, the non-FQHC/RHC or contractor may request fee-for-service reimbursement for a visit or store and forward service directly from the appropriate managed care plan or the Medi-Cal Fiscal Intermediary if no service payment contract exists with the FQHC or RHC.

An e-consult, e-visit, or remote patient monitoring is not a reimbursable telehealth service for FQHCs or RHCs.

SOURCE: CA Department of Health Care Services (DHCS).  Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHC) Outpatient Services Manual. Jan. 2023. Pg. 13-15. (Accessed Jun. 2023).

A visit shall also include an encounter between an FQHC patient and a physician, physician assistant, nurse practitioner, certified nurse-midwife, clinical psychologist, licensed clinical social worker, visiting nurse, comprehensive perinatal services program practitioner, dental hygienist, dental hygienist in alternative practice, or marriage and family therapist using an asynchronous store and forward modality, when services delivered through that modality meet the applicable standard of care.

SOURCE: WIC 14132.100, as amended by SB 184 (2022 Session). (Accessed Jun. 2023).

See: CA Medicaid Store and Forward

Remote Patient Monitoring

An e-consult, e-visit, or remote patient monitoring is not a reimbursable telehealth service for FQHCs or RHCs.

SOURCE: CA Department of Health Care Services (DHCS).  Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHC) Outpatient Services Manual. Jan. 2023. Pg. 13. (Accessed Jun. 2023).

See: CA Medicaid RPM

Audio-Only

An audio-only synchronous interaction is eligible for reimbursement if provided by a billable provider and FQHC or RHC patient.

Medi-Cal benefits or services being provided are clinically appropriate and meet the procedural and billing requirements that would have applied if the applicable services were delivered via a face-to-face encounter.

A patient may not be “established” using an audio-only synchronous interaction unless the visit is related to a “sensitive service”, as defined in the California Civil Code, section 56.05, subdivision (n), or if the patient requests “audio only” or does not have access to video.

SOURCE: CA Department of Health Care Services (DHCS).  Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHC) Outpatient Services Manual. Jan. 2023. Pg. 14. (Accessed Jun. 2023).

A visit shall also include an encounter between an FQHC patient and a physician, physician assistant, nurse practitioner, certified nurse-midwife, clinical psychologist, licensed clinical social worker, visiting nurse, comprehensive perinatal services program practitioner, dental hygienist, dental hygienist in alternative practice, or marriage and family therapist using audio-only synchronous interaction, when services delivered through that modality meet the applicable standard of care.

SOURCE: WIC 14132.100, as amended by SB 184 (2022 Session). (Accessed Jun. 2023).

See: CA Medicaid Email, Phone, & Fax

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.

See: CO Medicaid Live Video

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 Dept. of Health Care Policy and Financing. Telemedicine Billing Manual. (7/23). (Accessed Aug. 2023).

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.

SOURCE: CO FQHC & RHC Billing Manual 10/22. (Accessed Aug. 2023).

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. In addition, 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.

SOURCE: CO FQHC & RHC Billing Manual 10/22. (Accessed Aug. 2023).

Audio-Only

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 Dept. of Health Care Policy and Financing. Telemedicine Billing Manual. (7/23). (Accessed Aug. 2023).

See: CO Medicaid Email, Phone and Fax

Live Video

CT Medicaid covers specified synchronized telemedicine, which is defined as an audio and video telecommunication system with real-time communication between the patient and practitioner.

See: CT Medicaid Live Video

Store and Forward

CT Medicaid doesn’t have explicit coverage of store-and-forward services.

See: CT Medicaid Store-and-forward

Remote Patient Monitoring

CT Medicaid doesn’t cover RPM.

See: CT Medicaid RPM

Audio-Only

No explicit reimbursement for telephone for FQHCs.

See: CT Medicaid Email, Phone, & Fax

Live Video

Generally, DE Medicaid reimburses for live video telemedicine services.

See: DE Medicaid Live Video

Store and Forward

Generally, DE Medicaid does not cover store-and-forward.

See: DE Medicaid Store-and-Forward.

Remote Patient Monitoring

Generally, DE Medicaid does not cover RPM.

See: DE Medicaid RPM.

Audio-Only

Telephone Services – services by means of a telephone call between a physician and a patient (including those in which the physician provides advice or instructions to or on behalf of the patient) are covered services that are included in the payment made to the FQHC and should not be billed as an encounter.

SOURCE: DE FQHC Policy Manual, 7/1/23, p. 6. (Accessed Jul. 2023).

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

Live Video

No explicit reference to telehealth for FQHCs/RHCs.

Generally, FL Medicaid reimburses for real time, two-way, interactive telemedicine.

See: FL Medicaid Live Video

Store and Forward

A Medicaid notice indicates store-and-forward is covered, however no explicit reference is made for FQHCs.

See: FL Medicaid Store-and-Forward.

Remote Patient Monitoring

A Medicaid notice indicates remote patient monitoring is covered, however no explicit reference is made for FQHCs.

See: FL Medicaid RPM

Audio-Only

No reimbursement for telephone, chart review, e-mail or fax.

See: FL Medicaid Email, Phone, & Fax

Live Video

FQHCs may serve as distant site providers and bill the cost of the visit. They are referred to the GA Medicaid Telehealth Manual.

SOURCE:  Georgia Department of Community Health, Division of Medicaid, Federally Qualified Health Center Services and Rural Health Clinic Services, p. 22. (Apr. 2023). (Accessed Jun. 2023).

Store and Forward

There is no reference found for store-and-forward explicitly for FQHCs although store and forward is allowed under general GA Medicaid policy for teledentistry.

SOURCE:  Georgia Department of Community Health, Division of Medicaid, Telehealth Guidance, p. 40 (Apr.  2023). (Accessed Jun. 2023).

Remote Patient Monitoring

No reference found.

Audio-Only

No reimbursement for telephone, fax or email.

SOURCE: Georgia Department of Community Health, Division of Medicaid, Telehealth Guidance, p. 11 (Apr. 2023). (Accessed Jun. 2023).

Except for services that meet the criteria for a TCM visit, telephone or electronic communication between a physician and a patient, or between a physician and someone on behalf of a patient, are considered physicians’ services and are included in an otherwise billable visit. They do not constitute a separately billable visit.

SOURCE: Georgia Department of Community Health, Division of Medicaid, Federally Qualified Health Center Services and Rural Health Clinic Services, p. 17. (Apr. 2023) (Accessed Jun. 2023).

Live Video

FQHCs may provide services via telehealth. Hawaii Medicaid refers FQHCs to the telehealth memo (MedQUEST Memo QI-2139/FFS 21-15) for the program regarding eligible codes.

SOURCE: HI Medicaid Provider Manual (FQHC) (March 2016), p. 8-9. (Accessed Jun. 2023).

Store and Forward

Telemedicine-based retinal imaging and interpretation is not a covered service for PPS reimbursement. It should be billed with the code and modifier 92014 SE and billed on the CMS 1500 form or electronically in CMS 1500 format. A face-to-face encounter with a member by an ophthalmologist or optometrist is eligible for PPS reimbursement, regardless of whether retinal imaging or interpretation is a component of the services provided.

SOURCE: HI Medicaid Provider Manual (FQHC) (March 2016), p. 4. (Accessed Jun. 2023).

Remote Patient Monitoring

No reference for FQHCs found.

Audio-Only

No reference to FQHCs found.

Live Video

Telehealth services provided as an encounter by a facility are reimbursable if the services are delivered in accordance with the Idaho Medicaid Telehealth Policy and applicable handbooks.

SOURCE: ID Medicaid Provider Handbook: IHS, FQHC, and RHC Services (Nov. 18, 2022)., p. 30.  (Accessed Jun. 2023).

Only one eligible provider may be reimbursed per service per participant per date of service. No reimbursement is available for the use of equipment at the originating or remote sites. Reimbursement is also not available for services that are interrupted and/or terminated early due to equipment difficulties. Claims for services delivered via telehealth will be reimbursed at the same rate as face-to-face services.

Idaho Medicaid will now accept places of service 02 (Telehealth provided other than in patient’s home) and 10 (Telehealth provided in patient’s home). Providers should use these places of service on claims from telehealth going forward. Claims for telehealth must include one of the following modifiers:

• FQ – A telehealth service was furnished using real-time audio-only communication technology.
• GT – A telehealth service was furnished using real-time audio-visual communication technology.

Additionally, providers can also use the following modifier in conjunction with one of the above:

• FR – A supervising practitioner was present through a real-time two-way, audio/video communication technology.

FQHC, RHC or IHS providers should not report the GT or FQ modifier with encounter code T1015 but should include it with each applicable supporting codes.

SOURCE: ID Medicaid Provider Handbook: General Information and Requirements for Providers (NMay 26, 2023), p. 132.  MedicAide May 2023.  (Accessed Jun. 2023).

Store and Forward

Idaho Medicaid does not reimburse for Store and Forward. See ID Medicaid Store and Forward. No specific mention of FQHCs.

Remote Patient Monitoring

Idaho Medicaid reimburses for RPM.  See ID Medicaid RPM. No specific mention of FQHCs.

Audio-Only

Idaho Medicaid will now accept places of service 02 (Telehealth provided other than in patient’s home) and 10 (Telehealth provided in patient’s home). Providers should use these places of service on claims from telehealth going forward. Claims for telehealth must include one of the following modifiers:

• FQ – A telehealth service was furnished using real-time audio-only communication technology.
• GT – A telehealth service was furnished using real-time audio-visual communication technology.

Additionally, providers can also use the following modifier in conjunction with one of the above:

• FR – A supervising practitioner was present through a real-time two-way, audio/video communication technology.

FQHC, RHC or IHS providers should not report the GT or FQ modifier with encounter code T1015 but should include it with each applicable supporting codes.

SOURCE: ID Medicaid Provider Handbook: General Information and Requirements for Providers (NMay 26, 2023), p. 132.  MedicAide May 2023.  (Accessed Jun. 2023).

Live Video

The Department of Healthcare and Family Services shall reimburse psychiatrists, federally qualified health centers as defined in Section 1905(l)(2)(B) of the federal Social Security Act, clinical psychologists, clinical social workers, advanced practice registered nurses certified in psychiatric and mental health nursing, and mental health professionals and clinicians authorized by Illinois law to provide behavioral health services to recipients via telehealth.  The Department shall reimburse epilepsy specialists, as defined by the Department by rule, who are authorized by Illinois law to provide epilepsy treatment services to persons with epilepsy or related disorders via telehealth. The Department, by rule, shall establish: (i) criteria for such services to be reimbursed, including appropriate facilities and equipment to be used at both sites and requirements for a physician or other licensed health care professional to be present at the site where the patient is located; however, the Department shall not require that a physician or other licensed health care professional be physically present in the same room as the patient for the entire time during which the patient is receiving telehealth services; and (ii) a method to reimburse providers for mental health services provided by telehealth.

SOURCE: 305 ILCS 5/5-5.25. (Accessed Jun. 2023).

An encounter clinic serving as the distant site shall be reimbursed as follows:

• If the originating site is another encounter clinic, the distant site encounter clinic shall receive no reimbursement from the Department.  The originating site encounter clinic is responsible for reimbursement to the distant site encounter clinic; and
• If the originating site is not an encounter clinic, the distant site encounter clinic shall be reimbursed for its medical encounter.  The originating site provider will receive a facility fee.

See Encounter Clinic Services Appendices supplement for telehealth billing examples for encounter clinics.

SOURCE: IL Admin. Code Title 89, 140.403; IL Dept. of Healthcare and Family Svcs., Expansion of Telehealth Services, Informational Notice, Jan. 1, 2010; Handbook for Encounter Clinic Services. Ch. 200, pg. 17.  Aug. 2016 & IL All Providers Handbook Supplement (Sept. 2020), pg. 43-45. Encounter Clinic Services – Appendices. (Accessed Feb. 2023).

Store and Forward

No explicit reference to FQHCs.

Remote Patient Monitoring

No explicit reference to FQHCs.

Audio-Only

Modifier 93 is a new modifier used to identify services that are provided via telephone or other real-time interactive audio-only telecommunication systems. It does not replace modifier GT, which should continue to be used to identify telehealth interactions using both audio and video telecommunications systems. When using modifier 93, the communication during the audio-only service must be of an amount or nature that meets the same key components and/or requirements of a face-to-face interaction. Modifier 93 is effective with dates of service beginning April 1, 2022.

SOURCE: IL Dept. of Healthcare and Family Services, Provider Notice 03/21/2022, Modifier 93 and Place of Service 10 Implementation April 1, 2022. (Accessed Feb. 2023).

Exception made during public health emergency:

Notwithstanding the restriction on services provided via phone in Section 140.6(m) and this Section, brief communication technology-based service, e.g. virtual check-in that uses audio-only real-time telephone interactions or synchronous, two-way audio interactions that are enhanced with video or other kinds of data transmission. Virtual check-ins must be rendered by a physician, advanced practice registered nurse, physician assistant, or other qualified health-care professional who can report evaluation and management (E/M) services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment. The Department will reimburse for this service at the rate established on the Department’s fee schedule. Federally Qualified Health Centers, Rural Health Clinics, and Encounter Rate Clinics may also receive reimbursement for this service at the rate established on the Department’s fee schedule.

SOURCE: IL Admin. Code Title 89, 140.403(e)(1)(A) (Accessed Feb. 2023).

Live Video

Special billing considerations apply for federally qualified health center (FQHC) and rural health clinic (RHC) providers. FQHC and RHC providers may bill for telehealth services if the service rendered is considered a valid FQHC or RHC encounter (as defined in the Federally Qualified Health Centers and Rural Health Clinics module) and a covered telehealth service (as defined by the Telehealth and Virtual Services Codes, accessible from the Code Sets page at in.gov/medicaid/providers). Subject to the following criteria, reimbursement is available to FQHCs and RHCS when they are serving as either the distant site or the originating site for telehealth services. See manual for additional details.

SOURCE: Indiana Health Coverage Programs, Provider Reference Module, Telehealth and Virtual Services (Sept. 27, 2022), p. 5.  (Accessed Jun. 2023).

FQHCs may provide services via live video if it is a valid encounter and covered service.  IN Medicaid reimburses a specific code list if service is provided via telehealth.  See Bulletin for code list.

SOURCE: IHCP Bulletin 202239 (May 19, 2022), p. 3. (Accessed Jun 2023).

The Indiana Health Coverage Programs (IHCP) published IHCP Banner Page BR202152 introducing the addition of place of service (POS) code 10. The Family and Social Services Administration (FSSA) Office of Medicaid Policy and Planning (OMPP) is clarifying that the IHCP will allow the use of POS code 10 for federally qualified healthcare centers (FQHCs) and rural health clinics (RHCs) for dates of service (DOS) on or after July 21, 2022. Any FQHC or RHC claims with DOS before July 21, 2022, will deny if the POS 10 is present on the claim. Please correct these claims using the appropriate POS 02 and resubmit. The definitions for the telehealth POS codes changed on Jan. 1, 2022:

• POS 02 – Telehealth provided other than in patient’s home
• POS 10 – Telehealth provided in patient’s home

As posted in IHCP Bulletin BT202239, the following modifiers are used on telehealth claims:

• Modifier 95 – Synchronous telemedicine service rendered via real-time interactive audio and video telecommunications system
• Modifier 93 – Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system

SOURCE: IHCP Allows New POS Code for FQHCs and RHCs July 21 BT 202253 (July 14, 2022).  (Accessed Jun. 2023).

Store and Forward

Store and Forward is not reimbursed by IN Medicaid.

Remote Patient Monitoring

FQHCs are not explicitly mentioned as being eligible to provide remote patient monitoring services.

Audio-Only

FQHCs may provide some services via audio-only, see CPT code list for specific services allowed.

SOURCE: IHCP Bulletin 202239 (May 19, 2022), p. 3. (Accessed Feb 2023).

See: IA Medicaid Email, Phone and Fax

Live Video

Office visits, individual psychotherapy, and pharmacological management services may be reimbursed when provided through telecommunication technology. The consulting or expert provider at the distant site must bill an appropriate code from the list below with place of service (POS) 02 – Telemedicine and will be reimbursed at the same rate as face-to-face services.  See manual for eligible codes.

SOURCE: KS Dept. of Health and Environment, Kansas Medical Assistance Program, Provider Manual, FQHC/RHC, 8-13 (Apr. 2023), (Accessed Jul. 2023).

See: KS Medicaid Live Video

Store and Forward

The member must be present at the originating site, excluding store-and-forward modality.

See: KS Medicaid Store and Forward

Remote Patient Monitoring

Not mentioned in FQHC manual, although reimbursed in other KS Medicaid programs.

See: KS Medicaid Remote Patient Monitoring

Audio-Only

Email, telephone, and facsimile transmissions are not covered as telemedicine services.

SOURCE: KS Dept. of Health and Environment, Kansas Medical Assistance Program, Provider Manual, FQHC/RHC, 8-13 (Apr. 2023), (Accessed Jul. 2023).

See: KS Medicaid Email, Phone and Fax

Live Video

The department must reimburse an eligible telehealth care provider for a telehealth service in an amount that is at least 100 percent of the amount for a comparable in-person service. A managed care plan may establish a different rate for telehealth reimbursement via contract.

SOURCE: KY Admin. Regs. Title, 907, 3:170. (Accessed Jul. 2023).

A request for reimbursement shall not be denied solely because:

• An in-person consultation between a Medicaid-participating practitioner and a patient did not occur; or
• A Medicaid-participating provider employed by a rural health clinic, federally qualified health center, or federally qualified health center look-alike was not physically located on the premises of the clinic or health center when the telehealth service or telehealth consultation was provided.

SOURCE: KY Revised Statute Sec. 205.559. (Accessed Jul. 2023).

See: KY Medicaid Live Video

Store and Forward

KY Medicaid reimburses for store-and-forward, however it’s not explicitly stated whether or not FQHCs qualify for reimbursement.

See: KY Medicaid Store and Forward

Remote Patient Monitoring

Providers who may provide remote patient monitoring services include:

• A federally qualified health center

SOURCE: KY Admin. Regs. Title, 907, 3:170. (Accessed Jul. 2023).

See: KY Medicaid Remote Patient Monitoring

Audio-Only

The definition for telehealth or digital health includes audio-only encounters, and Medicaid has added reimbursement for telephonic services but does not explicitly state FQHCs are eligible.  

See: KY Medicaid Audio-Only

Live Video

If a covered service is provided via an interactive audio and video telecommunications system (telemedicine), providers must refer to Chapter 5 of the Professional Services Provider Manual on www.lamedicaid.com for specific billing instructions.

SOURCE: LA Dept. of Health, Federally Qualified Health Centers Provider Manual, Chapter 22, Sec. 22.4, pg. 33, (As issued on 6/30/22) (Accessed Jun. 2023).

LA Medicaid reimburses for service codes that are appropriate for telemedicine/telehealth via live video, including for FQHCs.

SOURCE: LA Dept. of Health, Informational Bulletin 20-1. (May 20, 2022). (Accessed Jun. 2023).

See: LA Medicaid Live Video

Store and Forward

Store-and-forward is not included in definition of telemedicine for LA Medicaid.  See: LA Medicaid Store and Forward

Remote Patient Monitoring

LA Medicaid provides reimbursement for ‘telecare’ which includes remote monitoring activities in the Community Choice Waiver program. However, there is no reference to whether or not FQHCs could be reimbursed for RPM.  See: LA Medicaid Remote Patient Monitoring

Audio-Only

Services delivered via an audio/video system and via an audio-only system are to be coded the same way (with the 02 or 10 POS and 95 modifier).

SOURCE: LA Dept. of Health, Informational Bulletin 20-1. (May 20, 2022). (Accessed Jun. 2023).

See: LA Medicaid Email, Phone and Fax

Live Video

FQHCs are paid both as a provider site and originating site fee, if approved.

See: ME Medicaid Live Video

Store and Forward

Although ME Medicaid reimburses for two types of store-and-forward, FQHCs are not explicitly mentioned leaving it unclear if they would be eligible for such services.

See: ME Medicaid Store-and-Forward

Remote Patient Monitoring

Although ME Medicaid reimburses for telemonitoring in some situations, FQHCs are not explicitly mentioned leaving it unclear if they would be eligible for such services.

See: ME Medicaid Remote Patient Monitoring

Audio-Only

Although ME Medicaid reimburses for telephonic services in some situations, FQHCs are not explicitly mentioned leaving it unclear if they would be eligible for such services. 

See: ME Medicaid Email, Phone and Fax

Live Video

MD Medicaid covers live video services provided by eligible providers.

See: MD Medicaid Live Video

Store and Forward

There is no explicit reference found for store-and-forward for FQHCs.

See: MD Medicaid Store-and-Forward.

Remote Patient Monitoring

MD Medicaid reimburses RPM for certain chronic conditions and FQHCs are eligible to prescribe RPM. Preauthorization requirements apply.

SOURCE: Remote Patient Monitoring. MD Department of Health. MD Medical Assistance Program PT 14-18. RPM. Jan. 10, 2018. (Accessed May 2023).

See: MD Medicaid RPM.

Audio-Only

No explicit reference found for FQHCs related to audio-only.

See: MD Medicaid Email, Phone & Fax.

Live Video

Community Health Centers, Community Mental Health Centers, and Outpatient Substance Use Disorder providers (provider types 20, 26 and 28) may deliver the following covered services via telehealth:

• All services specified in 101 CMR 306.00 et seq.; and
• The outpatient services specified in the following categories:
• Opioid Treatment Services: Counseling;
• Ambulatory Services: Outpatient Counseling; Clinical Case Management; and
• Services for Pregnant/Postpartum Clients: Outpatient Services

SOURCE: MassHealth All Provider Bulletin 281, p. 1, Jan. 2019. (Accessed Aug. 2023).

MassHealth lists specific codes that may be used by community health centers for services delivered through telehealth. See Transmittal Letter for details.

SOURCE: MassHealth, Community Health Center Manual, Service Codes and Descriptions, 1/1/23, (Access Aug. 2023).

According to statute, there is no restrictions on distant sites, and live video is covered.

See: MA Medicaid Live Video.

Store and Forward

According to teledentistry and the GQ modifier are covered for store-and-forward. However, CCHP has not found an explicit reference to whether or not FQHCs/CHCs are eligible for reimbursement for store-and-forward

See:  MA Medicaid Store and Forward.

Remote Patient Monitoring

Although MassHealth reimburses some select RTM codes, there is no explicit indications to whether or not FQHCs are eligible to be reimbursed those codes.

See: MA Medicaid Remote Patient Monitoring.

Audio-Only

While telephonic delivery of children’s behavioral health initiative services is allowed in some situations, and MA statute indicates reimbursement for audio-only telephone, CCHP has not found an explicit indication that FQHCs/CHCs can be reimbursed for the audio-only modality.

See:  MA Medicaid Email, Phone and Fax.

Live Video

All current Medicaid policy for telemedicine services, including definitions, requirements and parameters of telemedicine apply to FQHCs and RHCs. FQHCs and RHCs are responsible for ensuring compliance with all telemedicine policy within the Medicaid provider manual and any applicable supplemental Medicaid policy bulletins.

SOURCE:  MI Dept. of Health and Human Services. Bulletin 20-09, General Telemedicine Policy, Mar. 12, 2020, [Provider Bulletin 23-10 indicates policy is permanent] & MI Dept. of Health and Human Services, Medicaid Provider Manual, p. 2127, Jul. 1, 2023 (Accessed Sept. 2023).

The provision of bulletin MSA 20-34 which allows providers to work from home, is also allowable per bulletin MSA 20-09, which defines the parameters for the distant site to include “the provider’s office, or any established site considered appropriate by the provider, so long as the privacy of the beneficiary and security of the information shared during the telemedicine visit are maintained”.

Clinics are also permitted to submit for reimbursement telemedicine services (using simultaneous audio/visual technologies) per bulletin MSA 20-09 if all other provisions of telemedicine policy are maintained. Simultaneous audio/visual telemedicine services, as indicated by CPT/HCPCS codes listed on the telemedicine fee schedule and considered qualifying visits, will also be considered face-to-face and will trigger the PPS/AIR if the service billed is listed as a qualifying visit.

For services submitted on the Institutional invoice, the appropriate National Uniform Billing Committee (NUBC) revenue code, along with the appropriate telemedicine Current Procedural Terminology/Healthcare Common Procedure Coding System (CPT/HCPCS) procedure code and modifier 95 or Modifier 93, must be used.

Federally Qualified Health Center (FQHC)/Rural Health Clinic (RHC)/Tribal Health Center (THC)/ Tribal Federally Qualified Health Centers (Tribal FQHC) Considerations – PT, OT and ST, when provided in accordance with this policy using both audio/visual modalities, will be considered face-to-face and will trigger the PPS AIR if the service billed is listed as a qualifying visit.

For FQHCs, RHCs, THCs and Tribal FQHCs, the appropriate CPT/HCPCS code, PPS/AIR payment code (if the service generates a Qualifying Visit), and modifier 95 – synchronous telemedicine must be used. Refer to www.michigan.gov/medicaidproviders >> Provider Specific Information for additional information.

SOURCE:  MI Dept. of Health and Human Services. Bulletin 23-10, Telemedicine Policy Post-COVID PHE, Mar. 2, 2023, (Accessed Sept. 2023).

An FQHC, can be either an originating or distant site for telemedicine services.

SOURCE: MI Dept. of Health and Human Services, Medicaid Provider Manual, p. 750, Jul. 1, 2023 (Accessed Sept. 2023).

Claims for telemedicine services must be submitted using the ASC X 12N 837 5010 form using the appropriate telemedicine HCPCS or CPT code. All telemedicine claims must include the corresponding modifier 95- “Synchronous Telemedicine Service rendered via a real-time interactive audio and video telecommunications system” or 93 – “Synchronous Telemedicine Service rendered via telephone or other real-time interactive audio-only telecommunications system” and the appropriate revenue code.

During the Medicaid provider enrollment process, contracted providers must associate to the FQHC or RHC billing NPI. Refer to the Billing & Reimbursement for Institutional Providers chapter of this Manual for further information.

SOURCE: MI Dept. of Health and Human Services, Medicaid Provider Manual, p. 750, Jul. 1, 2023 (Accessed Sept. 2023).

See: MI Medicaid Live Video.

Store and Forward

Asynchronous telemedicine services are allowed in specific situations, however, CCHP has not found an explicit reference stating whether or not FQHCs can be reimbursed in Medicaid manuals.

See: MI Medicaid Store and Forward.

Remote Patient Monitoring

According to the MI Medicaid provider manual, RPM is covered with restrictions, however there is no indication from Medicaid if FQHCs can bill for this.

See: MI Medicaid Remote Patient Monitoring.

Audio-Only

Clinics will be permitted to submit for reimbursement allowable audio-only service codes, as indicated above, if appropriate for the interaction with the beneficiary. Medicaid clinic billing and reimbursement requirements apply. The provider must be employed by or contracted with the FQHC, RHC, or THC and the procedure code billed must appear on the clinic qualifying visit list located on the MDHHS website.

For services submitted on the Institutional invoice, the appropriate National Uniform Billing Committee (NUBC) revenue code, along with the appropriate telemedicine Current Procedural Terminology/Healthcare Common Procedure Coding System (CPT/HCPCS) procedure code and modifier 95 or Modifier 93, must be used.

SOURCE:  MI Dept. of Health and Human Services., Bulletin 23-10, Telemedicine Policy Post-COVID PHE, Mar. 2, 2023, & MI Dept. of Health and Human Services, Medicaid Provider Manual, p. 2121 & 2128, Jul. 1, 2023 (Accessed Sept. 2023).

See: MI Medicaid Email, Phone and Fax.

Live Video

Telehealth visits provided through audio and visual communication or accessible video-based platforms may be used to satisfy the face-to-face requirement for reimbursement under the payment methods that apply to a federally qualified health center, rural health clinic, Indian health service, 638 tribal clinic, and certified community behavioral health clinic, if the service would have otherwise qualified for payment if performed in person.

SOURCE: MN Statute Sec. 256B.0625, Subd. 3b(d). (Accessed Jun. 2023).

See: MN Medicaid Live Video

Store and Forward

 MN allows some services through store-and-forward. The definition of telehealth includes store-and-forward. No explicit reference is made regarding whether or not FQHCs would be eligible for store-and-forward reimbursement.

See: MN Medicaid Store and Forward

Remote Patient Monitoring

While there is a section for telemonitoring, there is no reference to whether or not a FQHC would be eligible for remote monitoring reimbursement.

See: MN Medicaid Remote Patient Monitoring

Audio-Only

Audio only is included in the definition of telehealth until July 1, 2025. Audio-only services are permitted but not explicitly listed for FQHCs.   

See: MN Medicaid Audio-Only

Live Video

The Division of Medicaid reimburses for telehealth services which meet the requirements of Miss. Admin. Code Part 225 as follows: 1. An encounter for face-to-face telehealth services provided by the FQHC acting as a distant site provider. 2. A fee per completed transmission for telehealth services provided by the RHC acting as an originating site provider. The FQHC may not bill for an encounter visit unless a separately identifiable service is performed. The originating site facility fee will be paid at the existing fee-for-service rate in effect as of January 1, 2021. 3. Reimburses a FQHC for both the distant and originating provider site when such services are appropriately provided by the FQHC.

SOURCE: MS Admin. Code Title 23, Part 211, Rule. 1.5. (Accessed Aug. 2023).

According to Administrative Code, there are no restrictions on originating and distant sites, and live video is covered.

See:  MS Medicaid Live Video.

Store and Forward

According to Administrative Code, store-and-forward is included in the definition of telemedicine, however there is no indication that the Medicaid program is currently reimbursing for any services beyond teleradiology as well as no indication FQHCs can be reimbursed for store-and-forward. Additionally, FQHC manual indicates encounters must be race-to-face which would exclude store-and-forward.

See:  MS Medicaid Store and Forward.

Remote Patient Monitoring

According to Administrative Code, remote patient monitoring is included in the definition of telemedicine, and reimbursed in some circumstances. However, CCHP has not found an explicit reference that FQHCs can bill for this.

See: MS Medicaid Remote Patient Monitoring.

Audio-Only

According to Administrative Code and statute, audio-only telehealth is reimbursed during states of emergencies under some circumstances. However, CCHP has not found an explicit reference that FQHCs can bill for this.

See:  MS Medicaid Email, Phone and Fax.

Live Video

According to statute, there is no restrictions on distant sites, and live video is covered.

See:  MO Medicaid Live Video.

Store and Forward

While store and forward is reimbursed, CCHP has not found an explicit reference to whether FQHCs are qualified for reimbursement in Medicaid manuals.

See:  MO Medicaid Store and Forward.

Remote Patient Monitoring

CCHP has not found an explicit reference in Medicaid manuals.

See: MO Medicaid Remote Patient Monitoring.

Audio-Only

While audio-only is reimbursed in some circumstances, CCHP has not found an explicit reference to whether or not FQHCs are reimbursed in Medicaid manuals.

See:  MO Medicaid Email, Phone and Fax.

Live Video

MT Medicaid reimburses for medically necessary services by means of telehealth (live video) under certain circumstances.  There is no reference found that explicitly references whether or not FQHCs can deliver services via telehealth and be reimbursed.

See: MT Medicaid Live Video

Store-and-Forward

There are no specific requirements for technologies used to deliver services via telemedicine/telehealth and can be provided using secure portal messaging, secure instant messaging, telephone conversations, and audio-visual conversations.  However, there is no explicit reference to FQHCs being able to use store-and-forward technology specifically.

See: MT Medicaid Store-and-forward

Remote Patient Monitoring

No reference found.

See: MT Medicaid Remote Patient Monitoring

Audio-Only

There are no specific requirements for technologies used to deliver services via telemedicine/telehealth and can be provided using secure portal messaging, secure instant messaging, telephone conversations, and audio-visual conversations.  However, there is no explicit reference to FQHCs being able to use telephone/audio-only specifically.

See: MT Medicaid Audio-Only

Live Video

IHS and Tribal 638 facilities can bill the encounter rate for telehealth services as long as these services meet the definition of an encounter. The facility must stay in accordance with the four walls rule to bill for telehealth. Federally qualified health centers and rural health centers may bill the encounter rate for core services that are allowed via telehealth. Learn more about the list of allowable telehealth codes on our website.

SOURCE: NE Medicaid Program, Bulletin 23-08:  Guidance on Telehealth, Mar. 23, 2023, (Accessed Aug. 2023).

See:  NE Medicaid Live Video.

Store and Forward

According to statute, there is no restriction on distant sites, and all modes of telehealth including store-and-forward, is supposed to covered. However, CCHP has not found an explicit reference.

See:  NE Medicaid Store and Forward.

Remote Patient Monitoring

According to statute, RPM is covered with restrictions, however there is no indication from Medicaid they are implementing this, and there is no clarification if FQHCs can bill for this.

See: NE Medicaid Remote Patient Monitoring.

Audio-Only

Audio-only is reimbursed for some codes, however there is nothing explicit that states FQHCs can be reimbursed for those services.

See: NE Medicaid Email, Phone and Fax.

Live Video

Originating Site: The FQHC may bill an encounter rate in lieu of the originating site fee, if the distant site (provider) is providing ancillary services. The originating site code, Q3014, must be used when billing in lieu of an encounter code.

Distant Site: FQHCs providing services for a recipient from a distant site may bill the appropriate encounter rate with Place of Service (POS) Code 02. Use of the POS code certifies the service meets telehealth requirements.

SOURCE: NV Medicaid FQHC Billing Guidelines. 8/30/19. (Accessed Aug. 2023).

Facilities that are eligible for encounter reimbursement (e.g. Indian Health (IH) programs, Federally Qualified Health Centers (FQHCs), Rural Health Centers (RHCs)) may bill for an encounter in lieu of an originating site facility fee, if the distant site is for ancillary services (i.e. consult with specialist). If the originating site and distant site are two different encounter sites, the originating site may only bill the telehealth facility fee, and the distant encounter site may bill the encounter code.

See: NV Medicaid Live Video

Store and Forward

No reference specifically in FQHC manual chapter.  However, Chapter refers providers to telehealth Services Chapter 3400.  In that chapter, store-and-forward is allowed in some circumstances.

See: NV Medicaid Store and Forward

Remote Patient Monitoring

No reference found.

See: NV Medicaid Remote Patient Monitoring

Audio-Only

No reference specifically in FQHC manual chapter.  However, Chapter refers providers to telehealth Services Chapter 3400.  In that chapter, audio-only is allowed for certain behavioral health services.  

See: NV Medicaid Audio-Only

Live Video

According to statute, there is no restrictions on distant sites, and live video is covered.  However, no explicit reference to FQHCs was found.

See: NH Medicaid Live Video.

Store and Forward

According to statute, there is no restriction on distant sites, and all modes of telehealth including store-and-forward, are supposed to be covered. However, CCHP has not found an explicit reference in Medicaid manuals.

See: NH Medicaid Store and Forward.

Remote Patient Monitoring

According to statute, RPM is covered with restrictions, however there is no indication from Medicaid they are implementing this, and there is no clarification if FQHCs can bill for RPM.

See: NH Medicaid Remote Patient Monitoring.

Audio-Only

According to statute, there is no restriction on distant sites, and all modes of telehealth including audio-only, are supposed to be covered. However, CCHP has not found an explicit reference in Medicaid manuals.

SOURCE: NH Revised Statutes 167:4-d (Accessed Jul. 2023).

See: NH Medicaid Email, Phone and Fax.

Live Video

According to the NJ statute, Medicaid is prohibited from placing restrictions on the location or setting of the distant site.  A 2018 newsletter (Vol. 28, No. 17) that was sent to FQHCs (among other providers) indicates reimbursement is provided for live video telehealth.  This follows a 2013 Medicaid Newsletter indicates that only psychiatrists and psychiatric advanced practice nurses are eligible for telehealth reimbursement, while an independent clinic (which includes FQHCs) may be an eligible originating site, although NJ does not reimburse an originating site facility fee.

Additionally, newsletters released in 2020 that apply to FQHCs indicate reimbursement is provided for pediatric and adolescent well care and teledentistry as a response to the COVID emergency.  No expiration date for these policies is provided.

SOURCE: NJ Division of Medical Assistance and Health Services. Newsletter. Vol. 23, No. 21, December 2013, Volume 30, No. 8, Apr 2020, Volume 30, No. 12 & Volume 28, No. 17, Sept. 2018. (Accessed Aug. 2023).

See: NJ Medicaid Live Video.

Store and Forward

NJ statute defines store-and-forward, however NJ Medicaid only lists reimbursement for real-time two way audio in combination with asynchronous store-and-forward technology if the provider has determined that they are able to meet the standard of care of face-to-face service. There is no explicit reference to whether or not this applies to FQHCs specifically.

See: NJ Medicaid Store and Forward.

Remote Patient Monitoring

According to statute, NJ Medicaid is required to cover RPM, however CCHP has not found an indication from NJ Medicaid that they have implemented this.  Additionally, there is no explicit clarification regarding whether or not FQHCs would be eligible for RPM reimbursement.

See: NJ Medicaid Remote Patient Monitoring.

Audio-Only 

Statute states, in no case shall the State Medicaid and NJ Family Care Programs restrict the ability of a provider to use any electronic or technical platform to provide services using telemedicine or telehealth, including but not limited to interactive, real-time, two-way audio, which may be used in combination with asynchronous store-and-forward technology without video capabilities including audio-only telephone conversations, to provide services using telemedicine or telehealth, provided that the platform used:

• Allows the provider to meet the same standard of care as would be provided if the services were provided in person’
• Is compliant with the requirements of the federal health privacy rule set forth at 45 CFR Parts 160 and 164.

 However, there is no explicit clarification to whether or not FQHCs can be reimbursed for the audio-only modality.

See: NJ Medicaid Email, Phone and Fax.

Live Video

The location of a MAP eligible recipient at the time the service is being furnished via an interactive telemedicine communications system. The origination-site can be any of the following medically warranted sites where services are furnished to a MAP eligible recipient.

• A federally qualified health center (as defined in section 1861 (aa)(4) of the Act).

SOURCE: NM Administrative Code 8.310.2.12 (M)(a). (Accessed Jun. 2023).

See: NM Medicaid Live Video

Store and Forward

MAD will reimburse for services delivered through store-and forward.  To be eligible for payment under store-and-forward, the service must be provided through the transference of digital images, sounds, or previously recorded video from one location to another; to allow a consulting provider to obtain information, analyze it, and report back to the referring physician providing the telemedicine consultation.  Store-and-forward telemedicine includes encounters that do not occur in real time (asynchronous) and are consultations that do not require a face-to-face live encounter between patient and telemedicine provider.

The Administrative Code does not explicitly state reimbursement for FQHCs.

SOURCE: NM Administrative Code 8.310.2.12 (M). (Accessed Jun. 2023).

See:  NM Medicaid Store-and-Forward

Remote Patient Monitoring

No Reference Found

See:  NM Medicaid Remote Patient Monitoring

Audio-Only

No explicit reference to FQHCs being reimbursed for audio-only services although NM Medicaid will reimburse certain providers for limited professional services delivered by telephone without video. 

See:  NM Medicaid Email, Phone and Fax

Live Video

Yes, NY Medicaid reimburses for live video telemedicine services.

See: NY Medicaid Live Video

Store and Forward

Generally, reimbursement will be made to the consulting distant-site practitioner when billed with an appropriate procedure code. The consulting distant-site practitioner must provide the requesting originating-site practitioner with a written report of the consultation in order for payment to be made. The consulting practitioner should bill the CPT code for the professional service appended with the telehealth GQ modifier.

SOURCE: NY Dept. of Health, Medicaid Update, Vol. 39, Number 3, February 2023, p. 11. (Accessed June 2023).

Remote Patient Monitoring

FQHCs that have opted out of APGs are unable to bill for RPM services at this time.

SOURCE: NY Dept. of Health, Medicaid Update, Vol. 39, Number 3, February 2023, p. 12. (Accessed June 2023).

Audio-Only

Audio-only rate codes used during the COVID-19 PHE will be retired. FQHCs can bill the Prospective Payment System (PPS) rate code “4012” or “4013”, depending on on-site presence as outlined in “VII. Billing Rules for Telehealth Services”, “M. FFS Billing for Telehealth by Site and Location” on page 14 of this issue. Wrap payments are available for any telehealth services, including telephonic services reimbursed by an MMC Plan, under qualifying PPS and off-site rate codes.

SOURCE: NY Dept. of Health, Medicaid Update, Vol. 39, Number 3, February 2023, p. 11. (Accessed June 2023).

See: NY Medicaid Email, Phone, & Fax

Live Video

Select services may be provided via telehealth, virtual patient communications, and remote patient monitoring. Services delivered via telehealth, virtual patient communications, and remote patient monitoring must follow the requirements and guidance set forth in Clinical Coverage Policy 1-H: Telehealth, Virtual Patient Communications, and Remote Patient Monitoring.

Federally Qualified Health Center (FQHC) and Rural Health Clinic (RHC) core service providers may deliver core services via telehealth if the service is: a. Defined as a core visit service in Section 5.3 of Clinical Coverage Policy 1D-4: Core Services Provided in Federally Qualified Health Centers and Rural Health Clinics; and, b. Covered as a telehealth-eligible core visit service in Attachment A, Section C.1 of this policy.

Non-Core Visit Services: FQHCs and RHCs may also deliver a select set of services via telehealth, virtual patient communications, and remote patient monitoring that are not defined as a core visit service in Section 5.3 of Clinical Coverage Policy 1D-4: Core Services Provided in Federally Qualified Health Centers and Rural Health Clinics. FQHCs and RHCs would be reimbursed on a fee-for-service basis for delivering non-core visit services via telehealth, virtual patient communications, or remote patient monitoring. See Attachment A, Section C.1 of this policy for further guidance for billing virtual patient communications and remote patient monitoring codes.

See: NC Medicaid Live Video

Store and Forward

As outlined in Section 5.7 and Attachment A, select services may be provided via telehealth, virtual patient communications, and remote patient monitoring. Services delivered via telehealth, virtual patient communications, and remote patient monitoring must follow the requirements and guidance set forth in Clinical Coverage Policy 1-H: Telehealth, Virtual Patient Communications, and Remote Patient Monitoring.

FQHCs and RHCs may also deliver a select set of services via telehealth, virtual patient communications, and remote patient monitoring that are not defined as a core visit service in Section 5.3 of Clinical Coverage Policy 1D-4: Core Services Provided in Federally Qualified Health Centers and Rural Health Clinics. FQHCs and RHCs would be reimbursed on a fee-for-service basis for delivering non-core visit services via telehealth, virtual patient communications, or remote patient monitoring. See Attachment A, Section C.1 of this policy for further guidance for billing virtual patient communications and remote patient monitoring codes.

 See: NC Medicaid Store and Forward

Remote Patient Monitoring

As outlined in Section 5.7 and Attachment A, select services may be provided via telehealth, virtual patient communications, and remote patient monitoring. Services delivered via telehealth, virtual patient communications, and remote patient monitoring must follow the requirements and guidance set forth in Clinical Coverage Policy 1-H: Telehealth, Virtual Patient Communications, and Remote Patient Monitoring.

FQHCs and RHCs may also deliver a select set of services via telehealth, virtual patient communications, and remote patient monitoring that are not defined as a core visit service in Section 5.3 of Clinical Coverage Policy 1D-4: Core Services Provided in Federally Qualified Health Centers and Rural Health Clinics. FQHCs and RHCs would be reimbursed on a fee-for-service basis for delivering non-core visit services via telehealth, virtual patient communications, or remote patient monitoring. See Attachment A, Section C.1 of this policy for further guidance for billing virtual patient communications and remote patient monitoring codes.

See: NC Medicaid Remote Patient Monitoring

Audio-Only

FQHCs and RHCs may conduct telephonic evaluation and management services using HCPCS code G0071. Eligible providers include physicians, nurse practitioners, psychiatric nurse practitioners, physician assistants, and certified nurse midwives.

SOURCE: NC Div. of Medical Assistance, Medicaid and Health Choice Manual, Clinical Coverage Policy No: 1D-4, Core Services Provided in Federally Qualified Health Centers and Rural Health Clinics, p. 19, Dec. 1, 2020. (Accessed Jul. 2023).

See: NC Medicaid Audio-Only

Live Video

When providing telehealth services to patients located in their homes or another facility, FQHCs and RHCs should continue to bill the revenue codes listed in the FQHC and RHC portions of this manual along with the CPT® or HCPCS code for the service rendered appended with modifier GT or 95.

SOURCE: ND Medicaid General Information Provider Manual, May 2023, pg. 158, (Accessed Jun. 2023).

See: ND Medicaid Live Video

Store and Forward

Store-and-forward is reimbursed through digital health evaluation and management services but unclear if FQHCs can bill this service specifically.

See: ND Medicaid Store and Forward

Remote Patient Monitoring

Telemonitoring is a covered service under home health services for ND Medicaid but no reference was found to whether or not FQHCs can be reimbursed for remote patient monitoring.

See: ND Medicaid Remote Patient Monitoring

Audio-Only

Audio-only is covered in specific circumstances, but no direct reference to FQHCs, so unclear if FQHCs would be reimbursed.

See: ND Medicaid Audio-Only

Live Video

FQHCs are explicitly allowed as distant and originating site providers in OH Medicaid.  A visit may be conducted through telehealth.

See: OH Medicaid Live Video.

 Store and Forward

FQHCs are required to report modifier ‘GT’ (which indicates telehealth services occurring via real-time interactive audio-video), according to the OH Medicaid Telehealth manual, indicating they are not eligible for store-and-forward reimbursement.

See: OH Medicaid Store and Forward.

Remote Patient Monitoring

Remote patient monitoring will be paid through FFS as a covered non-FQHC/RHC service under the clinic provider type 50 (using ODM’s payment schedules).

SOURCE: The Ohio Department of Medicaid.  Telehealth Billing Guide.  Revised 7/15/2022., p. 9  (Accessed Jun. 2023).

See: OH Medicaid Remote Patient Monitoring.

Audio-Only

While the OH Medicaid Telehealth billing guide billing guide indicates telephone calls fall within the telehealth definition,  CCHP has not found an explicit reference to whether or not FQHCs can be reimbursed for services delivered via telephone.

See: OH Medicaid Email, Phone and Fax.

Live Video

SoonerCare (OK Medicaid) reimburses for live video under certain circumstances, however there is no explicit reference to whether or not FQHCs can be reimbursed for live video telehealth.

See: OK Medicaid Live Video.

 Store and Forward

According to OK Admin Code, health care delivered by telehealth such as store-and-forward must be compensable by OHCA in order to be reimbursed.  There is no explicit reference to whether or not FQHCs can be reimbursed for store-and-forward.

See: OK Medicaid Store and Forward.

Remote Patient Monitoring 

According to OK Admin Code, health care delivered by telehealth such as remote patient monitoring must be compensable by OHCA in order to be reimbursed.  Reimbursement is provided for continuous glucose monitoring in some circumstances.  There is no explicit reference to whether or not FQHCs can be reimbursed for remote patient monitoring.

See: OK Medicaid Remote Patient Monitoring.

 Audio-Only 

According to Administrative Code, Telehealth shall not include consultations provided by telephone audio-only communication, electronic mail, text message, instant messaging conversation, website questionnaire, nonsecure video conference, or facsimile transmission.  Certain audio-only codes are listed as reimbursable on OK Health Authority website but no explicit reference is made to whether FQHCs can bill for such services.

See: OK Medicaid Email, Phone and Fax.

Live Video

OR Medicaid covers health services delivered using telemedicine, however no explicit reference to whether or not FQHCs can be reimbursed was found.

See: OR Medicaid Live Video.

Store and Forward

OR Medicaid covers asynchronous transmissions in some circumstances however no explicit reference to whether or not FQHCs can be reimbursed was found.

See: OR Medicaid Store and Forward.

Remote Patient Monitoring

OR Medicaid covers remote patient monitoring in some circumstances however no explicit reference to whether or not FQHCs can be reimbursed was found.

See: OR Medicaid Remote Patient Monitoring.

Audio-Only 

Telephone encounters qualify as a valid encounter for services provided in accordance with OAR 410-130-0595, Maternity Case Management (MCM) and 410-130-0190, Tobacco Cessation (see also OAR 410-120-1200). Except as set forth below, providers may not make telephone contacts at the exclusion of face-to-face visits. Telephone encounters must include all the same components of the service as if provided face-to-face.

See:  OR Medicaid Email, Phone and Fax.

Live Video

Telepsychiatry Services – Only applicable to Behavioral Health Managed Care delivery system claims and not fee-for-service delivery. Mental health services are provided through the use of approved electronic communication and information technologies to provide or support clinical psychiatric care at a distance. Qualifying telepsych services utilize real-time, two-way interactive audio-video transmission, and do not include a telephone conversation, electronic mail message, or facsimile transmission between a health care practitioner and a service recipient, or a consultation between two healthcare practitioners, although these activities may support the delivery of telepsych services. Telepsych services require service providers to have a service description approved by the Office of Mental Health and Substance Abuse Services (OMHSAS) and deliverable through the managed care option.

SOURCE: PA PROMISe Provider Handbook, Appendix E, FQHC/RHC (Accessed Sept. 2023).

Teledentistry may be used by dentists, FQHCs, and RHCs to provide dental services to MA beneficiaries. The provider must be licensed in Pennsylvania and enrolled in the MA Program.

FQHCs and RHCs are to continue billing procedure code T1015 with the U9 modifier to indicate dental visits/encounters rendered via teledentistry to patients. FQHCs and RHCs should no longer use the GT modifier, as previously directed in Provider Quick Tip # 237, “Teledentistry Guidelines Related to COVID-19 for Dentists, Federally Qualified Health Centers and Rural Health  Clinics”(https://www.dhs.pa.gov/providers/QuickTips/Documents/PROMISeQuickTip237.pdf), and must begin using POS 02 as of May 2, 2022.

Teledentistry visits must be provided according to the same standard of care as if delivered in-person.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Teledentistry Guidelines and Dental Fee Schedule Updates (May 2, 2022). (Accessed Sept. 2023).

See: PA Medicaid Live Video.

Store and Forward

 Telehealth, for purposes of MA Program payment, does not include asynchronous or store and forward technology or facsimile machines, electronic mail systems or remote patient monitoring devices. However, these technologies may be utilized as a part of the provision of a MA-covered service.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, p. 2-3, Aug. 2, 2023, (Accessed Sept. 2023).

There is no explicit reference to whether or not FQHCs  can be reimbursed for Store and Forward.

See:  PA Medicaid Store and Forward.

Remote Patient Monitoring

 Telehealth, for purposes of MA Program payment, does not include asynchronous or store and forward technology or facsimile machines, electronic mail systems or remote patient monitoring devices. However, these technologies may be utilized as a part of the provision of a MA-covered service.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, p. 2-3, Aug. 2, 2023, (Accessed Sept. 2023).

There is no explicit reference to whether or not FQHCs can be reimbursed for remote patient monitoring.

See: PA Medicaid Remote Patient Monitoring.

Audio-Only

PA Medicaid allows audio-only telecommunication technology to be used when the beneficiary does not have video capability or for an urgent medical situation.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, p. 2, Aug. 2, 2023, (Accessed Sept. 2023).

There is no explicit reference to whether or not FQHCs can be reimbursed for audio-only delivery.

See:  PA Medicaid Email, Phone and Fax.

Live Video

No reference found.

Store and Forward

No reference found.

Remote Patient Monitoring

No reference found.

Audio-Only

No reference found.

Live Video

An encounter must include a face-to-face or telemedicine (telephone-only and tele video services) visit with a physician (including optometrists and psychiatrists), physician assistant, nurse practitioner (advanced practice registered nurses), clinical social worker, clinical psychologist, certified nurse midwife, clinical nurse specialist, licensed mental health counselor, licensed marriage and family therapist, dentist or registered dental hygienist.

SOURCE:  RI Executive Office of Health and Human Services, Principles of Reimbursement for FQHCs, Aug. 2022, pg. 5-6, (Accessed May 2023).

See:  RI Medicaid Live Video

Store and Forward

No explicit reference has been found to RI Medicaid reimbursing for store-and-forward.

See: RI Medicaid Store-and-Forward.

Remote Patient Monitoring

No explicit reference has been found to RI Medicaid reimbursing for remote patient monitoring. 

See:  RI Medicaid Remote Patient Monitoring

Audio-Only

An encounter must include a face-to-face or telemedicine (telephone-only and tele video services) visit with a physician (including optometrists and psychiatrists), physician assistant, nurse practitioner (advanced practice registered nurses), clinical social worker, clinical psychologist, certified nurse midwife, clinical nurse specialist, licensed mental health counselor, licensed marriage and family therapist, dentist or registered dental hygienist.

SOURCE:  RI Executive Office of Health and Human Services, Principles of Reimbursement for FQHCs, Aug. 2022, pg. 5-6, (Accessed May 2023).

See: RI Medicaid Email, Phone and Fax

Live Video

South Carolina Medicaid will reimburse for live video.

See: SC Medicaid Live Video

Store and Forward

G2010 (Remote image submitted by a patient) is listed as reimbursed for FQHCs for established patients.

SOURCE: SC Dept. of Health and Human Services. Medicaid Bulletin 22-005. (May 2023). (Accessed Aug. 2023).

Generally, however, SC doesn’t appear to cover store-and-forward services.

See: SC Medicaid Store-and-forward

Remote Patient Monitoring

No RPM coverage for FQHCs.

See: SC Medicaid RPM

Audio-Only

Services rendered through an FQHC or RHC for certain audio-only CPT codes will be reimbursed.

SOURCE: SC Dept. of Health and Human Services. Medicaid Bulletin 22-005. (May 2023). (Accessed Aug. 2023).

See: SC Medicaid Email, Phone, & Fax

Live Video

According to the FQHC manual, there are no restrictions on distant sites, and live video is covered. Reimbursement for distant site telemedicine services is limited to the individual practitioner’s professional fees or the encounter rate if the service qualifies as an FQHC/RHC or IHS/Tribal 638 clinic service. The maximum allowable amount for services provided via telemedicine is the same as services provided in-person.

 See:  SD Medicaid Live Video.

Store and Forward

CCHP has not found an explicit reference in Medicaid manuals.

See:  SD Medicaid Store and Forward.

Remote Patient Monitoring

Remote patient monitoring is not reimbursed by SD Medicaid

See: SD Medicaid Remote Patient Monitoring.

Audio-Only

For FQHCs/RHCs and IHS/Tribal 638 Providers, SUD agency services may also be provided via audio-only if the provider is an accredited and enrolled agency. Audio-only behavioral health services are reimbursed at the encounter rate.

See:  SD Medicaid Email, Phone and Fax.

Live Video

According to statute, a health insurance entity (includes Medicaid) shall provide coverage for healthcare services provided during a telehealth encounter in a manner that is consistent with what the health insurance policy or contract provides for in-person encounters for the same service, and shall reimburse for healthcare services provided during a telehealth encounter without distinction or consideration of the geographic location, or any federal, state, or local designation or classification of the geographic area where the patient is located. Any provisions not stipulated in the telehealth services section of the insurance code shall be governed by the terms and conditions of the health insurance contract. However, no explicit reference to FQHCs was found.

See:  TN Medicaid Live Video.

Store and Forward

TN statute defines store-and-forward telemedicine services, but does not require coverage store-and-forward specifically.  There is also no explicit reference to whether or not FQHCs can be reimbursed for the modality.

See:  TN Medicaid Store and Forward.

Remote Patient Monitoring

According to statute, A health insurance entity may consider any remote patient monitoring service a covered medical service if the same service is covered by Medicare. The appropriate parties may negotiate the rate for these services in the manner in which is deemed appropriate by the parties. There is no clarification if FQHCs can bill for this.

See: TN Medicaid Remote Patient Monitoring.

Audio-Only

According to statute, neither telehealth nor provider-based telemedicine includes audio-only conversation with the exception of HIPAA audio-only conversation for the provision of behavioral health and or healthcare services when other means are unavailable.  A school-based manual indicates reimbursement for audio-only services, however there is no clarification if FQHCs can bill for this.

See:  TN Medicaid Email, Phone and Fax.

Live Video

A medical visit is a face-to-face, telemedicine, or telehealth encounter between an FQHC patient and a physician, physician assistant, nurse practitioner, certified nurse midwife, or visiting nurse. An “other” health visit includes, but is not limited to, a face-to-face, telemedicine, or telehealth encounter between an FQHC patient and a qualified clinical psychologist, clinical social worker, other health professional for mental health services, a dentist, a dental hygienist, an optometrist, or a Texas Health Steps Medical Screen.

SOURCE: TX Admin Code, Title 1, Part 15, Ch. 355 Subchapter J, 355. 8261. (Accessed Aug. 2023).

FQHCs may be reimbursed the distant-site provider fee for telemedicine services at the Prospective Payment System (PPS) rate or Alternative Prospective Payment System (APPS) rate.

FQHCs providing distant-site telehealth services may be reimbursed for the following procedure codes (see manual for specific codes).

SOURCE:  TX Medicaid Telecommunication Services Handbook, pgs. 10 & 12, (Aug. 2023). (Accessed Aug. 2023).

See:  TX Medicaid Live Video.

Store and Forward

TX Administrative Code includes definitions of “Telemedicine Medical Service,” “Telehealth Services” and “Telemedicine” which encompasses store-and-forward, stating that it includes “clinical data transmission using computer imaging by way of still-image capture and store-and-forward.” While the definition of telemedicine includes store-and-forward and the Medicaid manual indicates FQHCs are eligible for reimbursement, there isn’t an explicit mention of FQHCs being reimbursed for store-and-forward specifically.

See:  TX Medicaid Store and Forward.

Remote Patient Monitoring

Home telemonitoring is a covered service in the Texas Medicaid Telecommunications Handbook. However, CCHP has not found an explicit reference in Medicaid manuals for FQHCs.

See: TX Medicaid Remote Patient Monitoring.

Audio-Only

TX Medicaid reimburses for audio-only modality in some circumstances, however CCHP has not found an explicit reference in Medicaid manuals for whether or not FQHCs can be reimbursed for the modality.

See:  TX Medicaid Email, Phone and Fax.

Audio-Only

FQHC Manual refers providers to refer to Section 1: General Information manual for Telemedicine instructions.  General Information manual allows for interprofessional telephone/internet assessments and management services. No reference found on whether or not that service applies to FQHCs.

See: UT Medicaid Email, Phone and Fax

Live Video

Health insurance plans (includes Medicaid) must provide coverage for health care services and dental services delivered through telemedicine by a health care provider at a distant site to a patient at an originating site to the same extent that the plan would cover the services if they were provided through in-person consultation.

SOURCE: VT Statutes Annotated, Title 8 Sec. 4100k (Accessed Jul. 2023).

Covered services must be clinically appropriate for delivery through telemedicine and be medically necessary.

SOURCE:  VT Health Care Administrative Rules 13.174.003 (3.101.2), Telehealth, (Accessed Jul. 2023).

No explicit reference to whether or not FQHC’s are eligible telehealth providers.

See: VT Medicaid Live Video

Store and Forward

While some reimbursement is allowed for store-and-forward in VT Medicaid, including HCPCS G2010, it is unclear whether or not FQHCs can bill for these services.

See: VT Medicaid Store and Forward

Remote Patient Monitoring  

While reimbursement for some remote patient monitoring is provided in VT Medicaid, it is not explicitly specified whether or not FQHCs can bill for these services.

See: VT Medicaid Remote Patient Monitoring

Audio-Only

Beginning Jan. 1, 2022, VT Medicaid is required to permit audio-only services to the extent the Centers for Medicare and Medicaid Services does.

SOURCE:  Senate Bill 117 (2021 Session), (Accessed Jul. 2023).

VT Medicaid allows audio-only reimbursement when clinically appropriate and medically necessary, however no explicit reference is made to whether or not FQHCs can bill for these services.

See: VT Medicaid Audio-Only

Live Video

No reference found.

Store and Forward

No reference found.

Remote Patient Monitoring

No reference found.

Audio-Only

No reference found.

Live Video

Telehealth services may be included in a Federally Qualified Health Center (FQHC), Rural Health Clinic (RHC), or Indian Health Center (IHC) scope of practice, as approved by HRSA and the Commonwealth

SOURCE: VA Dept. of Medical Assistance Svcs., Medicaid Provider Manual Supplement-Telehealth Services (Oct. 2022) (Accessed Aug. 2023).

Policies described in the Telehealth Supplement are applicable to all Providers (including FQHCs) who are able to bill for services listed in Attachment A.

SOURCE: VA Medicaid Telehealth Questions and Answers (Aug. 2021). (Accessed Aug. 2023).

See  VA Medicaid Live Video.

Store and Forward

Certain codes are eligible for reimbursement delivered by store and forward in VA Medicaid.  There is nothing explicit however that indicates FQHCs are eligible for these codes.

See:  VA Medicaid Store and Forward.

Remote Patient Monitoring

Certain RPM services are eligible for reimbursement in VA Medicaid. There is nothing explicit however that indicates FQHCs are eligible for these codes.

See: VA Medicaid Remote Patient Monitoring.

Audio-Only

Certain audio-only codes are eligible for reimbursement in VA Medicaid.  There is nothing explicit however that indicates FQHCs are eligible for those codes.

See:  VA Medicaid Email, Phone and Fax.

Live Video

A face-to-face or telemedicine (including audio-only telemedicine) visit between an encounter eligible client and an FQHC provider who exercises independent judgment when providing services that qualify for encounter rate reimbursement.

SOURCE: Federally Qualified Health Centers, p. 8 (Apr. 2023). (Accessed Jun. 2023).

See: WA Medicaid Live Video

Store and Forward

No explicit reference for FQHCs found.

See: WA Medicaid Store-and-Forward

Remote Patient Monitoring

CPT® code 99453 is encounter-eligible when performed by a Federally Qualified Health Center (FQHC) encounter-qualified provider. Other RPM procedure codes are not FQHC-encounter eligible.

SOURCE: WA State Health Care Authority, Medicaid Provider Guide, Physician-Related Svcs./Health Care Professional Svcs., p. 95 (Jun. 2023). (Accessed Jun. 2023).

See: WA Medicaid RPM

Audio-Only

“Encounter” – A face-to-face or telemedicine (including audio-only telemedicine) visit between an encounter-eligible client and an FQHC provider who exercises independent judgment when providing services that qualify for encounter rate reimbursement.

SOURCE: WA Admin Code 182-548-1100, (Accessed Jun. 2023).

Effective August 1, 2022, HCA pays for audio-only telemedicine services for specific procedure codes when provided and billed as directed in HCA provider billing guides. HCA published the list of audio-only codes on HCA’s Provider billing guides and fee schedules webpage. FQHCs may receive the encounter rate when billing as an audio-only code if the service being billed is encounter eligible and meets the billing requirements as outlined in the Encounters section of the FQHC guide.

SOURCE: Federally Qualified Health Centers, p. 64 (Apr. 2023). (Accessed Jun. 2023).

See: WA Medicaid Email, Phone, & Fax

Live Video

WV Medicaid reimburses live video telehealth services. The member must be able to see and interact with the off-site provider at the time services (“real-time not delayed”) are provided through Telehealth. Services provided through videophone or webcam are not covered.

SOURCE: WV Dept. of Health and Human Svcs. Medicaid Provider Manual. Chapter 522.8 Federally Qualified Health Center and Rural Health Clinic Svcs. P. 9. (July 1, 2019). (Accessed May 2023).

See: WV Medicaid Live Video

Store and Forward

WV Medicaid does not explicitly cover store-and-forward for FQHCs.

See: WV Medicaid Store-and-Forward

Remote Patient Monitoring

WV Medicaid does not explicitly cover RPM for FQHCs.

See: WV Medicaid RPM

Audio-Only

Telehealth is not a telephone conversation, email, or faxed transmission between a healthcare provider and a member, or a consultation between two healthcare providers.

SOURCE: WV Dept. of Health and Human Svcs. Medicaid Provider Manual. Chapter 522.8 Federally Qualified Health Center and Rural Health Clinic Svcs. P. 9. (July 1, 2019). (Accessed May 2023).

See: WV Email, Phone & Fax

Live Video

FQHCs may serve as originating and distant site providers for telehealth services.

SOURCE: WI ForwardHealth Handbook, Originating and Distant Sites, Topic #22739, (Accessed Aug. 2023).

See:  WI Medicaid Live Video.

Store and Forward

According to ForwardHealth Telehealth handbook, Services must be functionally equivalent to face-to-face visits.  There is no indication that store-and-forward is reimbursed.

See: WI Medicaid Store and Forward.

Remote Patient Monitoring

According to statute, RPM is covered with restrictions, however there is no indication if FQHCs can bill for this.

See: WI Medicaid Remote Patient Monitoring.

 Audio-Only

According to statute, there is no restriction on distant sites, and all modes of telehealth including audio-only, is supposed to covered. However, CCHP has not found an explicit reference in Medicaid manuals to whether or not FQHCs can be reimbursed for audio-only.

See: WI Medicaid Email, Phone and Fax.

Live Video

Each site will be able to bill for their own services as long as they are an enrolled Medicaid Provider (this includes out-of-state Medicaid Providers). Providers shall not bill for both the spoke and hub site; unless the Provider is at one location and the Member is at a different location even though the pay to Provider is the same. Examples include Community Mental Health Centers and Substance Abuse Treatment Centers. A single pay to Provider can bill both the originating site (spoke site) and the distant site Provider (hub site) when applicable.

SOURCE: WY Dept. of Public Health Insurance, Medicaid, CMS 1500 Provider Manual, p. 141 (Apr. 3, 2023), WY Division of Healthcare Financing Tribal Provider Manual, pgs. 142 & 221 (Apr. 3, 2023) & Institutional Provider Manual pg. 138.  (Apr. 3, 2023). (Accessed May 2023).

See:  WY Medicaid Live Video

Store and Forward

WY Medicaid’s definition of telehealth excludes store-and-forward.

See:  WY Medicaid Store-and-Forward

Remote Patient Monitoring

No reference found.

See:  WY Medicaid Remote Patient Monitoring

Audio-Only

WY Medicaid’s definition of telehealth excludes audio-only telephone conversations.

See: WY Medicaid Email, Phone and Fax