Wisconsin

Disclaimer

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

At A Glance
1 / 5

MEDICAID REIMBURSEMENT

  • Live Video: Yes
  • Store-and-Forward: Yes*
  • Remote Patient Monitoring: Yes
  • Audio Only: Yes

PRIVATE PAYER LAW

  • Law Exists: No
  • Payment Parity: No

PROFESSIONAL REQUIREMENTS

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

FQHCs

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

STATE RESOURCES

  1. Medicaid Program: Forward Health
  2. Administrator: Wisconsin Dept. of Health Services
  3. Regional Telehealth Resource Center: Great Plains Telehealth Resource and Assistance Center
Disclaimer

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

Last updated 11/22/2022

Audio-Only Delivery

Medicaid: Telehealth Expansion and Related Resources

STATUS: Active. Expires day after end of federal public health emergency (PHE). The federal PHE is currently set to expire Jan. 2023.

Medicaid: Transition from Temporary to Permanent Synchronous Telehealth Coverage Policy and Billing Guidelines 

STATUS: Expired Dec. 31, 2021. Some policies may have been extended until end of federal public health emergency. See link above.

Medicaid: Alert 019: Opioid Treatment Program Phone Calls

STATUS: Active, until ForwardHealth announces otherwise

Medicaid: Temporary Changes to Telehealth Policy and Clarifications for Behavioral Health and Targeted Case Management Providers

STATUS: ForwardHealth will publish additional guidance that includes a reasonable timeframe to allow providers to adjust to the expiration of the temporary policies addressed in this ForwardHealth Update.

Medicaid: Changes to ForwardHealth Telehealth Policies for Covered Services, Originating Sites, and Federally Qualified Health Centers

STATUS: Permanent

Medicaid: Additional Services to be Provided Via Telehealth

STATUS: Active, until rescinded or modified when emergency orders issued by the state and federal governments expire

Medicaid: Changes to Narcotic Treatment Services

STATUS: Active, until further notice

Medicaid 1915(c) Waiver: Appendix K – Children’s Long Term Support Waiver Program

STATUS:  Extended to no later than six months after the expiration of the national public health emergency, see below.

Medicaid 1915(c) Waiver: Appendix K Extension – Children’s Long Term Support Waiver Program

STATUS: Active, no later than six months after the expiration of the national public health emergency

Medicaid 1915(c) Waiver: Appendix K –Family Care Waiver Renewal 2020

STATUS: Extended to no later than six months after the expiration of the national public health emergency, see below.

Medicaid 1915(c) Waiver: Appendix K Extension – Family Care Waiver Renewal 2020

STATUS: Active, no later than six months after the expiration of the national public health emergency

Medicaid 1915(c) Waiver: Appendix K – Self-Directed Support Waiver, Intellectual/developmental Disability and Aged/Physical Disability

STATUS: Extended to no later than six months after the expiration of the national public health emergency, see below.

Medicaid 1915(c) Waiver: Appendix K Extension – Self-Directed Support Waiver, Intellectual/developmental Disability and Aged/Physical Disability

STATUS: Active, no later than six months after the expiration of the national public health emergency

PERMANENT TELEHEALTH COVERAGE POLICY AND BILLING GUIDELINES

*Only synchronous (two-way, real-time, interactive communications) and remote physiological monitoring services identified under permanent policy may be reimbursed when provided via telehealth effective on the first day of the first month after the federal public health emergency related to the COVID-19 pandemic expires.

Temporary telehealth policy will remain in effect until the switch to permanent policy occurs when ForwardHealth will require providers to follow permanent billing guidelines for synchronous telehealth and remote physiological monitoring services. Telehealth-related updates to the ForwardHealth Online Handbook will be available following the implementation of permanent policy.

PERMANENT TELEDENTISTRY POLICY

*ForwardHealth will transition to permanent telehealth coverage policy and billing guidelines for synchronous (two-way, real-time, interactive communications) telehealth services effective on the first day of the first month after the public health emergency related to the COVID-19 pandemic expires.

This telehealth coverage policy will include coverage for synchronous teledentistry services. Asynchronous teledentistry policy is still in development and will be published in a future ForwardHealth Update. Temporary public health emergency allowances, including Health Insurance Portability and Accountability Act of 1996 flexibilities, will continue through the end of the federal health public emergency unless providers are notified otherwise in writing prior to that time.

PERMANENT TELEHEALTH POLICY FOR SCHOOL-BASED SERVICES

*ForwardHealth will transition to permanent telehealth coverage policy and billing guidelines for school-based services effective on the first day of the first month after the federal public health emergency related to the COVID-19 pandemic expires.

Temporary telehealth policy will remain in effect until the switch to permanent policy occurs. Telehealth related updates to the ForwardHealth Online Handbook will be available following the implementation of permanent policy. Refer to ForwardHealth Update 2021-50, titled “Permanent Telehealth Coverage Policy and Billing Guidelines,” for additional information. This Update highlights permanent telehealth policy for school-based services in support of the child’s needs in the virtual environment.

Temporary public health emergency allowances including Health Insurance Portability and Accountability Act of 1996 flexibilities will continue through the end of the federal health public emergency unless providers are notified otherwise in writing prior to that time.

Last updated 11/22/2022

Cross-State Licensing

AB 148: Out of State Practice

STATUS: Enacted.

Last updated 11/21/2022

Easing Prescribing Requirements

Medicaid: Changes to Narcotic Treatment Services

STATUS: Active, policy will continue through end of federal PHE see alert

 

Last updated 11/22/2022

Miscellaneous

Medicaid: Remote Supervision

STATUS: Active, until further notice

Medicaid: Additional Services To Be Provided Via Telehealth

STATUS: Active

PERMANENT TELEHEALTH COVERAGE POLICY AND BILLING GUIDELINES

*Only synchronous (two-way, real-time, interactive communications) and remote physiological monitoring services identified under permanent policy may be reimbursed when provided via telehealth effective on the first day of the first month after the federal public health emergency related to the COVID-19 pandemic expires.

Temporary telehealth policy will remain in effect until the switch to permanent policy occurs when ForwardHealth will require providers to follow permanent billing guidelines for synchronous telehealth and remote physiological monitoring services. Telehealth-related updates to the ForwardHealth Online Handbook will be available following the implementation of permanent policy.

PERMANENT TELEDENTISTRY POLICY

*ForwardHealth will transition to permanent telehealth coverage policy and billing guidelines for synchronous (two-way, real-time, interactive communications) telehealth services effective on the first day of the first month after the public health emergency related to the COVID-19 pandemic expires.

This telehealth coverage policy will include coverage for synchronous teledentistry services. Asynchronous teledentistry policy is still in development and will be published in a future ForwardHealth Update. Temporary public health emergency allowances, including Health Insurance Portability and Accountability Act of 1996 flexibilities, will continue through the end of the federal health public emergency unless providers are notified otherwise in writing prior to that time.

PERMANENT TELEHEALTH POLICY FOR SCHOOL-BASED SERVICES

*ForwardHealth will transition to permanent telehealth coverage policy and billing guidelines for school-based services effective on the first day of the first month after the federal public health emergency related to the COVID-19 pandemic expires.

Temporary telehealth policy will remain in effect until the switch to permanent policy occurs. Telehealth related updates to the ForwardHealth Online Handbook will be available following the implementation of permanent policy. Refer to ForwardHealth Update 2021-50, titled “Permanent Telehealth Coverage Policy and Billing Guidelines,” for additional information. This Update highlights permanent telehealth policy for school-based services in support of the child’s needs in the virtual environment.

Temporary public health emergency allowances including Health Insurance Portability and Accountability Act of 1996 flexibilities will continue through the end of the federal health public emergency unless providers are notified otherwise in writing prior to that time.

Last updated 11/22/2022

Originating Site

Medicaid: Telehealth Expansion and Related Resources

STATUS: Active. Expires day after end of federal public health emergency (PHE). The federal PHE is currently set to expire Jan. 2023.

Medicaid: Transition from Temporary to Permanent Synchronous Telehealth Coverage Policy and Billing Guidelines

STATUS: Expired Dec. 31, 2021. Some policies may have been extended until end of federal public health emergency. See link above.

Medicaid: Temporary Changes to Telehealth Policy and Clarifications for Behavioral Health and Targeted Case Management Providers

STATUS: ForwardHealth will publish additional guidance that includes a reasonable timeframe to allow providers to adjust to the expiration of the temporary policies addressed in this ForwardHealth Update.

Medicaid: Changes to ForwardHealth Telehealth Policies for Covered Services, Originating Sites, and Federally Qualified Health Centers

STATUS: Permanent

PERMANENT TELEHEALTH COVERAGE POLICY AND BILLING GUIDELINES

*Only synchronous (two-way, real-time, interactive communications) and remote physiological monitoring services identified under permanent policy may be reimbursed when provided via telehealth effective on the first day of the first month after the federal public health emergency related to the COVID-19 pandemic expires.

Temporary telehealth policy will remain in effect until the switch to permanent policy occurs when ForwardHealth will require providers to follow permanent billing guidelines for synchronous telehealth and remote physiological monitoring services. Telehealth-related updates to the ForwardHealth Online Handbook will be available following the implementation of permanent policy.

 

Last updated 11/22/2022

Private Payer

Commissioner of Insurance: Telemedicine Coverage Request Related to COVID-19

STATUS: Active

Last updated 11/22/2022

Provider Type

Medicaid: Telehealth Expansion and Related Resources

STATUS: Active. Expires day after end of federal public health emergency (PHE). The federal PHE is currently set to expire Jan. 2023.

Medicaid: Transition from Temporary to Permanent Synchronous Telehealth Coverage Policy and Billing Guidelines

STATUS: Expired Dec. 31, 2021. Some policies may have been extended until end of federal public health emergency. See link above.

Medicaid: Temporary Changes to Telehealth Policy and Clarifications for Behavioral Health and Targeted Case Management Providers

STATUS: ForwardHealth will publish additional guidance that includes a reasonable timeframe to allow providers to adjust to the expiration of the temporary policies addressed in this ForwardHealth Update.

Medicaid: Changes to ForwardHealth Telehealth Policies for Covered Services, Originating Sites, and Federally Qualified Health Centers

STATUS: Permanent

Medicaid:  Dental Telehealth Services

STATUS: Active, until Medicaid: Additional Services Update expires

Medicaid: Durable Medical Equipment and Disposable Medical Supplies Face-to-Face Requirements

STATUS: Active, until further notice

Medicaid:  Tribal and Non-Tribal Federally Qualified Health Centers Billing Guidance

STATUS: Permanent

Medicaid: FAQs about Telehealth Policy Changes

STATUS: Active

PERMANENT TELEHEALTH COVERAGE POLICY AND BILLING GUIDELINES

*Only synchronous (two-way, real-time, interactive communications) and remote physiological monitoring services identified under permanent policy may be reimbursed when provided via telehealth effective on the first day of the first month after the federal public health emergency related to the COVID-19 pandemic expires.

Temporary telehealth policy will remain in effect until the switch to permanent policy occurs when ForwardHealth will require providers to follow permanent billing guidelines for synchronous telehealth and remote physiological monitoring services. Telehealth-related updates to the ForwardHealth Online Handbook will be available following the implementation of permanent policy.

PERMANENT TELEDENTISTRY POLICY

*ForwardHealth will transition to permanent telehealth coverage policy and billing guidelines for synchronous (two-way, real-time, interactive communications) telehealth services effective on the first day of the first month after the public health emergency related to the COVID-19 pandemic expires.

This telehealth coverage policy will include coverage for synchronous teledentistry services. Asynchronous teledentistry policy is still in development and will be published in a future ForwardHealth Update. Temporary public health emergency allowances, including Health Insurance Portability and Accountability Act of 1996 flexibilities, will continue through the end of the federal health public emergency unless providers are notified otherwise in writing prior to that time.

Last updated 11/22/2022

Service Expansion

Medicaid: Telehealth Expansion and Related Resources

STATUS: Active. Expires day after end of federal public health emergency (PHE). The federal PHE is currently set to expire Jan. 2023.

Medicaid: Interprofessional Consultations and Remote Physiologic Monitoring

STATUS: Likely expired due to adoption of additional guidance.

Medicaid: Temporary Changes to Telehealth Policy and Clarifications for Behavioral Health and Targeted Case Management Providers

STATUS: Some policies active until ForwardHealth announces otherwise’ some policies permanent.  May be superseded by permanent policies listed below starting Jan. 1, 2022.

Medicaid: Transition from Temporary to Permanent Synchronous Telehealth Coverage Policy and Billing Guidelines

STATUS: Expired Dec. 31, 2021. Some policies may have been extended until end of federal public health emergency. See link above.

Medicaid: Changes to ForwardHealth Telehealth Policies for Covered Services, Originating Sites, and Federally Qualified Health Centers

STATUS: Permanent

Medicaid: Additional Services to be Provided Via Telehealth

STATUS: Active, until rescinded or modified when emergency orders issued by the state and federal governments expire

Medicaid:  Temporary Changes to Clinical Policy and Prior Authorization

STATUS: Active, until further notice

Medicaid:  Dental Telehealth Services

STATUS: Active, until Medicaid: Additional Services Update expires

Medicaid: Therapy Provided as Part of the Birth to 3 Program

STATUS: Active, until further notice

Medicaid: Changes to Narcotic Treatment Services

STATUS: Active, until further notice

Medicaid: FAQs about Telehealth Policy Changes

STATUS: Active

Medicaid 1915(c) Waiver: Appendix K – Children’s Long Term Support Waiver Program

STATUS:  Extended to no later than six months after the expiration of the national public health emergency, see below.

Medicaid 1915(c) Waiver: Appendix K Extension – Children’s Long Term Support Waiver Program

STATUS: Active, no later than six months after the expiration of the national public health emergency

Medicaid 1915(c) Waiver: Appendix K –Family Care Waiver Renewal 2020

STATUS: Extended to no later than six months after the expiration of the national public health emergency, see below.

Medicaid 1915(c) Waiver: Appendix K Extension – Family Care Waiver Renewal 2020

STATUS: Active, no later than six months after the expiration of the national public health emergency

Medicaid 1915(c) Waiver: Appendix K – Self-Directed Support Waiver, Intellectual/developmental Disability and Aged/Physical Disability

STATUS: Extended to no later than six months after the expiration of the national public health emergency, see below.

Medicaid 1915(c) Waiver: Appendix K Extension – Self-Directed Support Waiver, Intellectual/developmental Disability and Aged/Physical Disability

STATUS: Active, no later than six months after the expiration of the national public health emergency

PERMANENT TELEHEALTH COVERAGE POLICY AND BILLING GUIDELINES

*Only synchronous (two-way, real-time, interactive communications) and remote physiological monitoring services identified under permanent policy may be reimbursed when provided via telehealth effective on the first day of the first month after the federal public health emergency related to the COVID-19 pandemic expires.

Temporary telehealth policy will remain in effect until the switch to permanent policy occurs when ForwardHealth will require providers to follow permanent billing guidelines for synchronous telehealth and remote physiological monitoring services. Telehealth-related updates to the ForwardHealth Online Handbook will be available following the implementation of permanent policy.

PERMANENT TELEDENTISTRY POLICY

*ForwardHealth will transition to permanent telehealth coverage policy and billing guidelines for synchronous (two-way, real-time, interactive communications) telehealth services effective on the first day of the first month after the public health emergency related to the COVID-19 pandemic expires.

This telehealth coverage policy will include coverage for synchronous teledentistry services. Asynchronous teledentistry policy is still in development and will be published in a future ForwardHealth Update. Temporary public health emergency allowances, including Health Insurance Portability and Accountability Act of 1996 flexibilities, will continue through the end of the federal health public emergency unless providers are notified otherwise in writing prior to that time.

Last updated 11/21/2022

Definitions

No Reference Found

Last updated 11/21/2022

Parity

SERVICE PARITY

No Reference Found


PAYMENT PARITY

No Reference Found

Last updated 11/21/2022

Requirements

No Reference Found

Last updated 11/21/2022

Definitions

Telehealth enables a provider who is located at a distant site to render the service remotely to a member located at an originating site using a combination of interactive video, audio, and externally acquired images through a networking environment.

“Telehealth” means the use of telecommunications technology by a Medicaid-enrolled provider to deliver functionally equivalent health care services including: assessment, diagnosis, consultation, treatment, and transfer of medically relevant data. Telehealth may include real-time interactive audio-only communication. Telehealth does not include communication between a certified provider and a member that consists solely of an email, text, or fax transmission.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth. (Accessed Nov. 2022).

“Telehealth” means a practice of health care delivery, diagnosis, consultation, treatment, or transfer of medically relevant data by means of audio, video, or data communications that are used either during a patient visit or a consultation or are used to transfer medically relevant data about a patient. “Telehealth” does not include communications delivered solely by audio-only telephone, facsimile machine, or electronic mail unless the department specifies otherwise by rule.

“Asynchronous telehealth service” is telehealth that is used to transmit medical data about a patient to a provider when the transmission is not a 2-way, real-time, interactive communication.

“Interactive telehealth” means telehealth delivered using multimedia communication technology that permits 2-way, real-time, interactive communications between a certified provider of Medical Assistance at a distant site and the Medical Assistance recipient or the recipient’s provider.

SOURCE: WI Statute Sec. 49.45 (61).  (Accessed Nov. 2022).

“Telehealth” means the use of telecommunications technology by a Medicaid-enrolled provider to deliver health care services including assessment, diagnosis, consultation, treatment, and transfer of medically relevant data in a functionally equivalent manner as that of an in-person contact. Telehealth may include real-time interactive audio-only communication. Telehealth does not include communication between a certified provider and a member that consists solely of an email, text, or fax transmission.

SOURCE: ForwardHealth Update Dec. 2021, No. 2021-50. (Accessed Nov. 2022). 

“Telehealth” means the use of telecommunications technology by a Medicaid-enrolled provider to deliver health care services including assessment, diagnosis, consultation, treatment, or transfer of medically relevant data in a functionally equivalent manner as that of an in-person contact:

  • Telehealth may include real-time interactive audio-only communication.
  • Telehealth does not include communication between a certified provider and a member (for example, a child) that consists solely of an email, text,or fax transmission.
  • School documentation may use a different term to represent telehealth such as, but not limited to, teleservice, virtual learning platform, or virtual services. ForwardHealth will accept the Individual Education Program (IEP) team’s chosen term for telehealth used in documentation.

SOURCE: ForwardHealth Update, No. 2022-02, January 2022. (Accessed Nov. 2022). 

Last updated 11/21/2022

Email, Phone & Fax

The Department may promulgate rules specifying any telehealth service that is provided solely by audio-only telephone, facsimile machine or electronic mail as reimbursable under Medical Assistance.

SOURCE: WI Statute Sec. 49.45 (61). (Accessed Nov. 2022).

School-Based Services 

The FQ or 93 modifiers should be used for any service performed via audio-only telehealth. The GT modifier should only be used to indicate services that were performed using audio-visual technology.

When possible, telehealth services should include both an audio and visual component. In circumstances where audio-visual telehealth is not possible due to member preference or technology limitations, telehealth may include real- time interactive audio-only communication if the provider feels the service is functionally equivalent to the in-person service and there are no face-to-face or in-person restrictions listed in the procedural definition of the service.

Documentation should include that the service was provided via interactive synchronous audio-only telehealth.

SOURCE: ForwardHealth Update, No. 2022-02, January 2022. (Accessed Nov. 2022). 

When possible, telehealth services should include both an audio and visual component. In circumstances where audio-visual telehealth is not possible due to member preference or technology limitations, telehealth may include real-time interactive audio-only communication if the provider feels the service is functionally equivalent to the in-person service and there are no face-to-face or in-person restrictions listed in the procedural definition of the service.

Documentation should include that the service was provided via interactive synchronous audio-only telehealth.

Modifier 93 should be used for any service performed via audio-only telehealth. Modifier 93 is effective for dates of service on and after January 1, 2022.

Behavioral Health Services

Effective January 1, 2022, the FQ modifier should be used for audio-only behavioral health services and modifier FR should be used for behavioral health services where the supervising provider is present through audio-visual means and the patient and supervised provider are in-person.

For instances where the patient, supervising/billing provider, and supervised/ rendering provider are all interacting through audio-visual means, providers should use modifier 95 GT.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth & ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 

Teledentistry

Modifier 93 should be used for any service performed via audio-only telehealth. The GT modifier should only be used to indicate services performed using audio-visual technology.

When possible, telehealth services should include both an audio and visual component. In circumstances where audio-visual telehealth is not possible due to member preference or technology limitations, telehealth may include real-time interactive audio-only communication if the provider feels the service is functionally equivalent to the in-person service and there are no face-to-face or in-person restrictions listed in the procedural definition of the service.

Documentation should include that the service was provided via interactive synchronous audio-only telehealth.

SOURCE: ForwardHealth Update, Jan. 2022, No. 2022-01. (Accessed Nov. 2022).

Interprofessional Consultations (E-Consults)

An interprofessional consultation or e-consult is an assessment and management service in which a member’s treating provider requests the opinion and/or treatment advice of a provider with specific expertise (the consultant) to assist the treating provider in the diagnosis and/or management of the member’s condition without requiring the member to have face-to-face contact with the consultant. Both the treating and consulting providers may be reimbursed for the e-consult as described below.

Policy Requirements and Limitations

Consulting Providers

Consulting providers must be physicians enrolled in Wisconsin Medicaid as an eligible rendering provider. Consulting providers may bill CPT procedure codes 99446–99449 and 99451 under the following limitations:

  • Services are not covered if the consultation leads to a transfer of care orother face-to-face service within the next 14 days or next available date of the consultant. Additionally, if the sole purpose of the consultation is to arrange a transfer of care or other face-to-face service, these procedure codes should not be submitted.
  • Consulting services are covered once in a seven-day period.

Treating Providers

Treating providers may be a physician, nurse practitioner, physician assistant, or podiatrist enrolled in Wisconsin Medicaid as an eligible rendering provider. Treating providers may bill CPT procedure code 99452 as a covered service once in a 14-day period.

Both the consulting and treating providers must be enrolled in Wisconsin Medicaid to receive reimbursement for the e-consult and the consultation must be medically necessary.

Providers are expected to follow CPT guidelines including that the CPT procedure codes should not be submitted if the consulting provider saw the member in a face-to-face encounter within the previous 14 days.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth & ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 

 

Last updated 11/21/2022

Live Video

POLICY

The department shall provide reimbursement under the Medical Assistance program for any benefit that is a covered benefit under s. 49.46 (2) and that is delivered by a certified provider for Medical Assistance through interactive telehealth.

SOURCE:  WI Statute 49.45(61), (Accessed Nov. 2022).

Only synchronous (two-way, real-time, interactive communications) services identified under permanent policy may be reimbursed when provided via telehealth (also known as “telemedicine”). ForwardHealth will require providers to follow permanent billing guidelines for synchronous telehealth services.

ForwardHealth reimburses the service rendered by distant site providers at the same rate as when the service is provided face-to-face.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth (Accessed Nov. 2022).

Only synchronous (two-way, real-time, interactive communications) and remote physiological monitoring services identified under permanent policy may be reimbursed when provided via telehealth effective on the first day of the first month after the federal public health emergency related to the COVID-19 pandemic expires. For example, if the public health emergency ends on April 12, 2022, permanent policy would become effective for dates of service on and after May 1, 2022. Temporary telehealth policy will remain in effect until the switch to permanent policy occurs when ForwardHealth will require providers
to follow permanent billing guidelines for synchronous telehealth and remote physiological monitoring services. Telehealth-related updates
to the ForwardHealth Online Handbook will be available following the implementation of permanent policy.

SOURCE: ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 


ELIGIBLE SERVICES/SPECIALTIES

On July 1, 2021, the fee schedule was updated to allow providers to identify services allowable under permanent telehealth policy. Procedure codes for services allowed under permanent telehealth policy have place of service (POS) code 02 (Telehealth) listed as an allowable POS.

Effective January 1, 2022, if POS code 02 is not listed as an allowable POS for a procedure code, the service will not be reimbursed under permanent telehealth policy.

SOURCE: ForwardHealth Update 2021-21, Jul. 1, 2021, (Accessed Nov. 2022).

Providers should refer to the Max Fee Schedules page for a complete list of services allowed under permanent telehealth policy. Effective for dates of service on and after April 1, 2022, procedure codes for services allowed under permanent telehealth policy have POS codes 02 and 10 listed as an allowable POS in the fee schedule. Complete descriptions are as follows:

  • POS code 02: Telehealth Provided Other Than in Patient’s Home–The location where health services and health related services are provided or received through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.
  • POS code 10: Telehealth Provided in Patient’s Home–The location where health services and health related services are provided or received through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.

Claims for telehealth services must include all modifiers required by coverage policy, in addition to POS code 02 or 10 and the GT, FQ, or 93 modifier, in order to reimburse the claim correctly.

County-administered programs, school-based services, and any other programs that utilize cost reporting must include required modifiers, such as renderer credentials and group versus individual services, as well as correct details for cost reporting to ensure correct reimbursement.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth (Accessed Nov. 2022).

Statute requires reimbursement for any benefit that delivered via interactive telehealth that is a covered benefit under Medicaid.

Reimbursement must be provided for a consultation pertaining to a Medicaid recipient conducted through interactive telehealth between a certified provider of Medical Assistance and the recipient’s treating provider that is certified under medical assistance, except as provided by the Department by Rule.

Except as provided by the department by rule, Medicaid must cover all Medicare covered services.  However, the Department may not cover or provide reimbursement for services that are first covered under the Medicare program after July 1, 2019 until the date that is one year after the date the service is covered under the Medicare program or the date the secretary explicitly approves the service as a Medical Assistance covered service, whichever is earlier.

The Department shall provide reimbursement under the Medical Assistance program for the following:  Except as provided by the department by rule, services that are covered under the Medicare program under 42 USC 1395 et seq. for which the federal department of health and human services provides Medical Assistance federal financial participation and that are any of the following:

  • Telehealth services;
  • Remote physiologic monitoring,
  • Remote evaluation of prerecorded patient information,
  • Brief communication technology-based services,
  • Care management services delivered through telehealth;
  • Any other telehealth or communication technology-based services.

Any service not specified can be eligible if specified by the Department.  The Department is required to promulgate rules specifying any services that are reimbursable.  They may also exclude services from reimbursement.

SOURCE: WI Statute Sec. 49.45 (61). (Accessed Nov. 2022).

The following requirements apply to the use of telehealth:

  • Both the member and the provider of the health care service must agree in order for a service to be performed via telehealth. If either the member or provider decline the use of telehealth for any reason, the service should be performed in-person.
  • The member retains the option to refuse the delivery of health care services via telehealth at any time without affecting their right to future care or treatment and without risking the loss or withdrawal of any program benefits to which they would otherwise be entitled.
  • Medicaid-enrolled providers must be able and willing to refer members to another provider if necessary, such as when telehealth services are not appropriate or cannot be functionally equivalent or if the member declines a telehealth visit.
  • Title VI of the Civil Rights Act of 1964 requires recipients of federal financial assistance to take reasonable steps to make their programs, services, and activities accessible by eligible persons with limited English proficiency.
  • The Americans with Disabilities Act requires that health care entities provide full and equal access for people with disabilities.

Providers should refer to the maximum allowable fee schedule for a complete list of services allowed under permanent telehealth policy. Procedure codes for services allowed under permanent telehealth policy have place of service (POS) codes 02 and 10 listed as an allowable POS in the fee schedule. Refer to the Telehealth topic (#510) for general claim submission requirements.

Certain types of benefits or services that are not appropriately delivered via telehealth include:

  • Services that are not covered when provided in-person.
  • Services that do not meet applicable laws, regulations, licensure requirements, or procedure code definitions if delivered via telehealth.
  • Services where a provider is required to physically touch or examine the recipient and delegation is not appropriate.
  • Services the provider declines to deliver via telehealth.
  • Services the recipient declines to receive via telehealth.
  • Transportation services.
  • Services provided by personal care workers, home health aides, private duty nurses, or school-based service care attendants.

The health care provider at the distant site must determine the following:

  • The service delivered via telehealth meets the procedural definition and components of the CPT or HCPCS procedure code, as defined by the American Medical Association, or the Current Dental Terminology procedure code, as defined by the American Dental Association.
  • The service is functionally equivalent to an in-person service for the individual member and circumstances.  Reimbursement is not available for services that cannot be provided via telehealth due to technical or equipment limitations.

Additional privacy considerations apply to members participating in group treatment via telehealth.

SOURCE: ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 

Telestroke Services

ForwardHealth allows providers to be reimbursed for telestroke services. Telestroke services typically consist of the member and emergency providers at an originating site consulting with a specialist located at a distant site.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth (Accessed Nov. 2022).

School-Based Services 

Allowable Services Via Telehealth Under School-Based Services:  ForwardHealth will reimburse assessments, individual services, and group services delivered by telehealth when the service is documented in the child’s IEP as an identified service and the mode of delivery is clearly described in documentation as telehealth (using the IEP team’s chosen term for telehealth delivery) and all other coverage requirements are met for the following services:

  • Audiology
  • Counseling service
  • Nursing
  • Occupational therapy
  • Physical therapy
  • Psychological service
  • Social work service
  • Speech and language therapy

The following services do not meet the definition of functionally equivalent and are not covered as a telehealth service:

  • Attendant care
  • Transportation

SOURCE: ForwardHealth Update, No. 2022-02, January 2022. (Accessed Nov. 2022). 

Teledentistry

The use of teledentistry services should be evaluated on an individual basis based on the member’s individual situation and will not be required by ForwardHealth.  Providers should report code D9995 along with the applicable allowable oral evaluation procedure codes to indicate the service was delivered via synchronous teledentistry.

All telehealth services must follow the guidelines for functional equivalency.

“Functionally equivalent” means that when a service is provided via telehealth, the transmission of information must be of sufficient quality as to be the
same level of service as an in-person visit. Transmission of voices, images, data, or video must be clear and understandable.

SOURCE:  ForwardHealth Update No. 2022-01, Jan. 2022, (Accessed Nov. 2022).

Behavioral Health Services

The FQ modifier should be used for audio-only behavioral health services. The FR modifier should be used for behavioral health services where the supervising provider is present through audio-visual means and the patient and supervised provider are in-person.

For instances where the patient, supervising/billing provider, and supervised/ rendering provider are all interacting through audio-visual means, providers should use modifier GT.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth (Accessed Nov. 2022).


ELIGIBLE PROVIDERS

There is no restriction on the location of a distant site provider. In addition, there are no limitations on what provider types may be reimbursed for telehealth services.

Ancillary Providers

Claims for services provided via telehealth by distant site ancillary providers should continue to be submitted under the supervising physician’s NPI using the lowest appropriate level office or outpatient visit procedure code or other appropriate CPT code for the service performed. These services must be provided under the direct on-site supervision of a physician who is located at the same physical site as the ancillary provider and must be documented in the same manner as services that are provided face to face.

Pediatric and Health Professional Shortage Area-Eligible Services

Claims for services provided via telehealth by distant site providers may additionally qualify for pediatric (services for members 18 years of age and under) or HPSA-enhanced reimbursement. Pediatric and HPSA-eligible providers are required to indicate POS code 02 or 10, along with modifier GT, FQ, or 93 and the applicable pediatric or HPSA modifier, when submitting claims that qualify for enhanced reimbursement.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth (Accessed Nov. 2022)

Ancillary providers have specific requirements when providing care via telehealth. These providers are health care professionals that are not enrolled in Wisconsin Medicaid, such as staff nurses, dietician counselors, nutritionists, health educators, genetic counselors, and some nurse practitioners who practice under the direct supervision of a physician and bill under the supervising physician’s National Provider Identifier. (Nurse practitioners, nurse midwives, and anesthetists who are Medicaid-enrolled should refer to their service-specific area of the Online Handbook for billing information.)

See bulletin for additional supervision requirements.

SOURCE: ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 

Birth to 3 Program

ForwardHealth will reimburse therapy providers supplying services as part of the Birth to 3 Program at an enhanced rate when occupational therapy, physical therapy, and/or speech therapy is performed using telehealth and the member is located in their natural environment.

SOURCE: ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 

FQHCs and RHCs

For the purpose of this Online Handbook topic, FQHC refers to Tribal and Out-of-State FQHCs. This topic does not apply to Community Health Centers subject to PPS reimbursement.

They may serve as originating site and distant site providers for telehealth services.  See manual for details.

FQHCs and RHCs may report services provided via telehealth on the cost settlement report when the FQHC or RHC served as the distant site and the member is an established patient of the tribal FQHC or RHC at the time of the telehealth service.

Services billed with modifier GT, FQ, or 93 will be considered under the PPS reimbursement method for non-tribal FQHCs. Billing HCPCS procedure code T1015 (Clinic visit/encounter, all-inclusive) with a telehealth procedure code will result in a PPS rate for fee-for-service encounters.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth (Accessed Nov. 2022).

The following are clarifications for federally qualified health centers:

  • For currently covered services, services that are considered direct when provided in-person will be considered direct when provided via telehealth.
  • Although federally qualified health centers are not directly reimbursed an originating site fee, HCPCS procedure code Q3014 should be billed for tracking purposes and for consideration in any potential future changes in scope.
  • Fee-for-service claims must include HCPCS procedure code T1015 (Clinic visit/encounter, all-inclusive) when services are provided via telehealth in order for proper reimbursement.
  • Refer to the Federally Qualified Health Centers and Rural Health Clinics section of the Telehealth topic (#510) for additional guidance.

SOURCE: ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 

Community Health Centers

Services billed with modifier GT, FQ, or 93 will be considered under the PPS reimbursement. Billing HCPCS procedure codes T1015 (Clinic visit/encounter, all-inclusive) with a telehealth procedure code will result in a PPS for an allowable encounter.

SOURCE: Telehealth for Community Health Centers (Accessed Nov. 2022).

Telestroke Services

ForwardHealth allows providers to be reimbursed for telestroke services. Telestroke services typically consist of the member and emergency providers at an originating site consulting with a specialist located at a distant site.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth (Accessed Nov. 2022).

School-Based Services

Supervision of Certified Occupational Therapy and Physical Therapy Assistants

ForwardHealth accepts supervision of certified occupational therapy assistants and physical therapist assistants in schools conducted via audio-visual telehealth.

Refer to the Delegation of Physical Therapy Services topic (#1463) and the Delegation of Occupational Therapy Services topic (#1464) of the ForwardHealth Online Handbook for additional information.

SOURCE: ForwardHealth Update, No. 2022-02, January 2022. &WI ForwardHealthOnline Handbook. Topic #1463 and #1464. (Accessed Nov. 2022). 

ForwardHealth confirms that occupational therapy, physical therapy, and speech and language therapy services rendered through telehealth may be reimbursed when a parent or caregiver is needed to assist the child during the therapy session. As a reminder, ForwardHealth only reimburses for services when the child is present.

SOURCE: ForwardHealth Update, No. 2022-02, January 2022. (Accessed Nov. 2022).

Teledentistry

To maintain functional equivalency, a facilitator may be needed to assist with the teledentistry visit.  Facilitators may include dental hygienists and other appropriately trained medical or dental professionals within their scope of practice. Facilitators are allowed for teledentistry when appropriate but are not separately reimbursed.

Dental hygienists can perform and bill for an assessment (D0191) of a member via teledentistry if the service is delivered with functional equivalency and the dental hygienist is individually enrolled in Wisconsin Medicaid.

SOURCE:  ForwardHealth Update No. 2022-01, Jan. 2022, (Accessed Nov. 2022).


ELIGIBLE SITES

ForwardHealth allows coverage of telehealth for any originating site. However, only the following originating sites are eligible for a facility fee reimbursement:

  • Hospitals, including emergency departments
  • Office/clinic
  • Skilled nursing facility

The following entities are also listed as allowable originating sites specifically:

  • Federally Qualified Health Centers (FQHC)
  • Rural Health Clinics (RHC)

FQHCs and RHCs

For the purpose of this Online Handbook topic, FQHC refers to Tribal and Out-of-State FQHCs. This topic does not apply to Community Health Centers subject to PPS reimbursement.

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

The originating site facility fee is not a FQHC or RHC reportable encounter on the cost report. Any reimbursement for the originating site facility fee must be reported as a deductive value on the cost report.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth, (Accessed Nov. 2022).

Community Health Centers

ForwardHealth will not separately reimburse the CHC for originating site services because all costs for providing originating site services have already been incorporated into the PPS rates for CHCs. However, claims billed by CHCs for originating site services may be used for future rate setting purposes, and CHC costs associated with telehealth services may be reported for change in scope adjustment consideration.

SOURCE: Telehealth for Community Health Centers (Accessed Nov. 2022).

The department may not limit coverage or reimbursement of a service provided under par. (b) or (c) based on the location of the Medical Assistance recipient when the service is provided.

SOURCE: WI Statute Sec. 49.45 (61). (Accessed Nov. 2022).

Telestroke Services

ForwardHealth allows providers to be reimbursed for telestroke services. Telestroke services typically consist of the member and emergency providers at an originating site consulting with a specialist located at a distant site.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth (Accessed Nov. 2022).

The originating site is where the member is located during a telehealth visit. Only the provider at the originating site can bill for an originating site fee for hosting the member. The originating site should not use telehealth modifiers on the claims since all services are provided in-person.

  • Office or clinic:
    • Medical
    • Dental
    • Therapies (physical therapy, occupational therapy, speech andlanguage pathology)
    • Behavioral and mental health agencies
  • Hospital
  • Skilled nursing facility
  • Community mental health center
  • Intermediate care facility for individuals with intellectual disabilities
  • Pharmacy
  • Day treatment facility
  • Residential substance use disorder treatment facility

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth & ForwardHealth Update No. 2022-13, Mar. 2022. (Accessed Nov. 2022).

Procedure codes for services allowed under permanent telehealth policy have place of service (POS) codes 02 and 10 listed as an allowable POS in the fee schedule. To align with guidance from the Centers for Medicare & Medicaid Services, effective for dates of service on and after April 1, 2022, ForwardHealth has added POS code 10 and revised the description for POS code 02. Complete descriptions are as follows:

  • POS code 02: Telehealth Provided Other Than in Patient’s Home—The location where health services and health related services are provided or received through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.
  • POS code 10: Telehealth Provided in Patient’s Home—The location where health services and health related services are provided or received through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.

SOURCE: ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 

School-Based Services

Claims for telehealth services must include all modifiers required by coverage policy in addition to:

  • Place of service code 02 (Telehealth Provided Other Than in Patient’s Home) or 10 (Telehealth Provided in Patient’s Home)

SOURCE: ForwardHealth Update, No. 2022-02, January 2022. (Accessed Nov. 2022). 


GEOGRAPHIC LIMITS

Effective for Dates on or After Mar. 1, 2022

The originating site is where the member is located during a telehealth visit. Only the provider at the originating site can bill for an originating site fee for hosting the member. The originating site should not use telehealth modifiers on the claims since all services are provided in-person. The distant site is where the provider is located during the telehealth visit.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth & ForwardHealth Update No. 2022-13, Mar. 2022. (Accessed Nov. 2022).


FACILITY/TRANSMISSION FEE

In addition to reimbursement to the distant site provider, ForwardHealth reimburses an originating site facility fee for the staff and equipment at the originating site requisite to provide a service via telehealth. Eligible providers who serve as the originating site should bill the facility fee with HCPCS procedure code Q3014 (Telehealth originating site facility fee). Modifier GT, FQ, or 93 should not be included with procedure code Q3014.

Eligible providers who bill on a professional claim form should bill HCPCS procedure code Q3014 with a POS code that represents where the member is located during the service. The POS must be a ForwardHealth-allowable originating site for HCPCS procedure code Q3014 in order to be reimbursed for the originating site fee. Billing-only provider types must include an allowable rendering provider on the claim form. The originating site fee is reimbursed based on a maximum allowable fee.

Eligible providers who bill on an institutional claim form should bill Q3014 as a separate line item with the appropriate revenue code 0780. ForwardHealth will reimburse hospitals for the facility fee based on the standard hospital reimbursement methodology. ForwardHealth will reimburse these providers for the facility fee based on the provider’s standard reimbursement methodology.

An originating site facility fee is not a FQHC or RHC reportable encounter on the cost report. Any reimbursement for the originating site facility fee must be reported as a deductive value on the cost report.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth. (Accessed Nov. 2022).

CHCs should submit claims for originating site services on a professional claim form with HCPCS procedure code Q3014 (Telehealth originating site facility fee) and a POS code that represents where the member is located during the service. Modifier GT should not be included with procedure code Q3014 for originating site services to be considered under the PPS reimbursement method. ForwardHealth will not separately reimburse the CHC for originating site services because all costs for providing originating site services have already been incorporated into the PPS rates for CHCs. However, claims billed by CHCs for originating site services may be used for future rate setting purposes, and CHC costs associated with telehealth services may be reported for change in scope adjustment consideration.

SOURCE: WI ForwardHealth Online Handbook, Telehealth for Community Health Centers. (Accessed Nov. 2022).

Allowable Originating Site Fee Expansion

The originating site is where the member is located during a telehealth visit. Only the provider at the originating site can bill for an originating site fee for hosting the member. The originating site should not use telehealth modifiers on the claims since all services are provided in-person. The distant site is where the provider is located during the telehealth visit. The provider who is providing health care services to the member via telehealth cannot bill the originating site fee because they are not hosting the member.

Beginning March 1, 2022, the following locations are eligible for the originating site fee under permanent telehealth policy:

  • Office or clinic:
    • Medical
    • Dental
    • Therapies (physical therapy, occupational therapy, speech and
      language pathology)
    • Behavioral and mental health agencies
  • Hospital
  • Skilled nursing facility
  • Community mental health center
  • Intermediate care facility for individuals with intellectual disabilities
  • Pharmacy
  • Day treatment facility
  • Residential substance use disorder treatment facility

Although FQHCs are not directly reimbursed an originating site fee, HCPCS procedure code Q3014 should be billed for tracking purposes and for consideration in any potential future changes in scope.

To receive reimbursement, the originating site must:

  • Utilize an interactive audiovisual telecommunications system that permits real-time communication between the provider at the distant site and the member at the originating site.
  • Be in a physical location that ensures privacy
  • Provide access to broadband internet with sufficient bandwidth to transmit audio and video data.
  • Provide access to support staff to assist with technical components of the telehealth visit.
  • Be compliant with Health Insurance Portability and Accountability Act of 1996 standards.

See bulletin for additional documentation requirements.

Last updated 11/21/2022

Miscellaneous

The department may not require a certified provider of Medical Assistance that provides a reimbursable service to obtain an additional certification or meet additional requirements solely because the service was delivered through telehealth, except that the department may require, by rule, that the transmission of information through telehealth be of sufficient quality to be functionally equivalent to face-to-face contact. The department may apply any requirement that is applicable to a covered service that is not provided through telehealth to any service.

SOURCE:  WI Statute Sec. 49.45 (61)(e), (Accessed Nov. 2022).

Claims for telehealth services must include all modifiers required by coverage policy, in addition to POS code 02 or 10 and the GT, FQ, or 93 modifier, in order to reimburse the claim correctly.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth.  (Accessed Nov. 2022).

The following cannot be billed to the member:

Telehealth equipment like tablets or smart devices

  • Charges for mailing or delivery of telehealth equipment
  • Charges for shipping and handling of:
    • Diagnostic tools
    • Equipment to allow the provider to assess, diagnose, repair, or set up medical supplies online such as hearing aids, cochlear implants, power wheelchairs, or other equipment

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth. & ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 

School-Based Services

As part of the IEP team meeting, the IEP team should determine if the service delivered by telehealth meets the ForwardHealth definition of functionally equivalent to be reimbursed. The decision to utilize telehealth as a delivery mode must be documented in the IEP in the section the IEP team determines appropriate.

Documentation requirements for a telehealth service are the same as for an in-person visit and must accurately reflect the service rendered.

Documentation must identify the delivery mode of the service when provided via telehealth using the IEP team’s chosen term and document whether the service was provided via audio-visual telehealth or audio-only telehealth.

SOURCE: ForwardHealth Update, No. 2022-02, January 2022. (Accessed Nov. 2022). 

“Functionally equivalent” means that when a service is provided via telehealth, the transmission of information must be of sufficient quality as to be the same level of service as an in-person visit. Transmission of voices, images, data, or video must be clear and understandable.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth,  ForwardHealth Update No. 2022-01, Jan. 2022, & ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022).

Last updated 11/21/2022

Out of State Providers

ForwardHealth policy for services provided via telehealth by out-of-state providers is the same as ForwardHealth policy for services provided face to face by out-of-state providers. Out-of-state providers who do not have border status enrollment with Wisconsin Medicaid are required to obtain PA before providing services via telehealth to BadgerCare Plus or Medicaid members.

Note: Wisconsin Medicaid is prohibited from paying providers located outside of the United States and its territories, including the District of Columbia, Puerto Rico, the Virgin Islands, Guam, the Northern Mariana Islands, and American Samoa.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth. (Accessed Nov. 2022).

Last updated 11/21/2022

Overview

Newly passed statute requires Wisconsin’s Medicaid program to provide coverage for Telehealth services, as defined under 42 USC 1395m (m) (4) (F), remote physiologic monitoring, remote evaluation of pre-recorded patient information, brief communication technology-based services, care management services delivered through telehealth and any other telehealth or communication technology-based services.

ForwardHealth has revamped their Medicaid reimbursement policy to allow certain CPT/HCPCS codes to be reimbursable via telehealth under certain circumstances.  Audio-only is also allowed when audio-visual telehealth is not possible.  Certain remote patient monitoring reimbursement codes are also now reimbursable. Interprofessional consultations (e-consults) are reimbursable by both the treating and consulting provider under the outlined policy requirements and limitations.

Last updated 11/21/2022

Remote Patient Monitoring

POLICY

Except as provided by the department by rule, remote patient monitoring of a Medical Assistance recipient in which the medical data pertains to a Medical Assistance recipient must be reimbursed.

Except as provided by the department by rule, services that are covered under Medicare for which the federal department of health and human services provides Medical Assistance federal financial participation and that are remote physiologic monitoring shall be reimbursed.

SOURCE: WI Statute Sec. 49.45 (61).  (Accessed Nov. 2022).

Remote physiologic monitoring is the collection and interpretation of a member’s physiologic data, such as blood pressure or weight checks, that are digitally transmitted to a physician, nurse practitioner, or physician assistant for use in the treatment and management of medical conditions that require frequent monitoring. Such conditions include congestive heart failure, diabetes, chronic obstructive pulmonary disease, wound care, polypharmacy, and mental or behavioral problems. It is also used for members receiving technology-dependent care, such as continuous oxygen, ventilator care, total parenteral nutrition, or enteral feeding.

The following policy requirements apply for remote physiologic monitoring services:

  • Only physicians, nurse practitioners, and physician assistants enrolled in ForwardHealth are eligible to render and submit claims for remote physiologic services.
  • The member’s consent for remote physiologic monitoring services must be documented in the member’s medical record.
  • The provider must document how remote physiologic monitoring is tied to the member-specific needs and will assist the member to achieve the goals of treatment.
  • Services are not separately reimbursable if the services are bundled or covered by other procedure codes (for example, continuous glucose monitoring is covered under CPT procedure code 95250 and should not be submitted under CPT procedure codes 99453–99454).
  • CPT procedure codes 99453 and 99454 can be used for blood pressure remote physiologic monitoring if the device used to measure blood pressure meets remote physiologic monitoring requirements. If the member self-reports blood pressure readings, the provider must instead submit self-measured blood pressure monitoring CPT procedure codes 99473–99474.
  • CPT procedure code 99457 should be used when the physician, nurse practitioner, or physician assistant uses medical decision making based on interpreted data received from a remote physiologic monitoring device to assess the member’s clinical stability, communicate the results to the member, and oversee the management and/or coordination of services as needed.

Providers are expected to follow CPT guidelines.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth. (Accessed Nov. 2022).

Only synchronous (two-way, real-time, interactive communications) and remote physiological monitoring services identified under permanent policy may be reimbursed when provided via telehealth effective on the first day of the first month after the federal public health emergency related to the COVID-19 pandemic expires. For example, if the public health emergency ends on April 12, 2022, permanent policy would become effective for dates of service on and after May 1, 2022. Temporary telehealth policy will remain in effect until the switch to permanent policy occurs when ForwardHealth will require providers
to follow permanent billing guidelines for synchronous telehealth and remote physiological monitoring services. Telehealth-related updates
to the ForwardHealth Online Handbook will be available following the implementation of permanent policy.

Remote physiologic monitoring is the collection and interpretation of a member’s physiologic data, such as blood pressure or weight checks, that are digitally transmitted to a physician, nurse practitioner, or physician assistant for use in the treatment and management of medical conditions that require frequent monitoring.

SOURCE: ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 


CONDITIONS

Conditions include congestive heart failure, diabetes, chronic obstructive pulmonary disease, wound care, polypharmacy, and mental or behavioral problems. It is also used for members receiving technology-dependent care, such as continuous oxygen, ventilator care, total parenteral nutrition, or enteral feeding.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth. (Accessed Nov. 2022). & ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 


PROVIDER LIMITATIONS

Provided by a physician, nurse practitioner, or physician assistant.

SOURCE: ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 

Only physicians, nurse practitioners, and physician assistants enrolled in ForwardHealth are eligible to render and submit claims for remote physiologic services.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth. (Accessed Nov. 2022).


OTHER RESTRICTIONS

The device used to capture a member’s physiologic data must meet the Food and Drug Administration definition of a medical device. To submit claims for CPT procedure codes 99453–99458, the members’ physiologic data must be wirelessly synced so it can be evaluated by the physician, nurse practitioner, or physician assistant. Transmission can be synchronous or asynchronous. (Data does not have to be transmitted in real time as long as it is automatically updated on an ongoing basis for the provider to review.)

SOURCE: ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 

Last updated 11/21/2022

Store and Forward

POLICY

Except as provided by the department by rule, asynchronous telehealth services in which the medical data pertains to a Medical Assistance recipient must be reimbursed.

Except as provided by the department by rule, services that are covered under Medicare for which the federal department of health and human services provides Medical Assistance federal financial participation and that are remote evaluation of prerecorded information shall be reimbursed.

SOURCE: WI Statute Sec. 49.45 (61). (Accessed Nov. 2022).

Services that are not covered when delivered in person are not covered as telehealth services. In addition, services that are not functionally equivalent to the in-person service when provided via telehealth are not covered.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth (Accessed Nov. 2022).

Interprofessional Consultations (E-Consults)

An interprofessional consultation or e-consult is an assessment and management service in which a member’s treating provider requests the opinion and/or treatment advice of a provider with specific expertise (the consultant) to assist the treating provider in the diagnosis and/or management of the member’s condition without requiring the member to have face-to-face contact with the consultant. Both the treating and consulting providers may be reimbursed for the e-consult as described below.

Policy Requirements and Limitations

Consulting Providers

Consulting providers must be physicians enrolled in Wisconsin Medicaid as an eligible rendering provider. Consulting providers may bill CPT procedure codes 99446–99449 and 99451 under the following limitations:

  • Services are not covered if the consultation leads to a transfer of care or other face-to-face service within the next 14 days or next available date of the consultant. Additionally, if the sole purpose of the consultation is to arrange a transfer of care or other face-to-face service, these procedure codes should not be submitted.
  • Consulting services are covered once in a seven-day period.

Treating Providers

Treating providers may be a physician, nurse practitioner, physician assistant, or podiatrist enrolled in Wisconsin Medicaid as an eligible rendering provider. Treating providers may bill CPT procedure code 99452 as a covered service once in a 14-day period.

Both the consulting and treating providers must be enrolled in Wisconsin Medicaid to receive reimbursement for the e-consult and the consultation must be medically necessary.

Providers are expected to follow CPT guidelines including that the CPT procedure codes should not be submitted if the consulting provider saw the member in a face-to-face encounter within the previous 14 days.

Documentation Requirements

The following documentation requirements apply for e-consults:

  • The consulting provider’s opinion must be documented in the member’s medical record.
  • The written or verbal request for a consultation by the treating provider must be documented in the member’s medical record including the reason for the request.
  • Verbal consent for each consultation must be documented in the member’s medical record. The member’s consent must include assurance that the member is aware of any applicable cost-sharing.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth & ForwardHealth Update Dec. 2021 updated Oct. 2022, No. 2021-50. (Accessed Nov. 2022). 


ELIGIBLE SERVICES

No Reference Found


GEOGRAPHIC LIMITS

No Reference Found


TRANSMISSION FEE

No Reference Found

Last updated 11/21/2022

Cross State Licensing

WI medical license required.

SOURCE: WI Admin. Code Med Ch. 24.04 (Accessed Nov. 2022).

Last updated 11/21/2022

Definitions

Telemedicine means the practice of medicine when patient care, treatment or services are provided through the use of medical information exchanged from one site to another via electronic communications. Telemedicine does not include the provision of health care services only through an audio only telephone, email messages, text messages, facsimile transmission, mail or parcel service or any combination thereof.

SOURCE: WI Admin. Code MED Ch. 24.02 (Accessed Nov. 2022).

“Telehealth” means a practice of health care delivery, diagnosis, consultation, treatment, or transfer of medically relevant data by means of audio, video, or data communications that are used either during a patient visit or a consultation or are used to transfer medically relevant data about a patient. “Telehealth” includes asynchronous telehealth services, interactive telehealth, and remote patient monitoring.

SOURCE: WI Statutes 440.01. (Accessed Nov. 2022).

 “Telemedicine” means the remote delivery of veterinary healthcare services, such as health assessments or consultations, over the telecommunications infrastructure, allowing a veterinarian to evaluate, diagnose and treat patients without the need for an in-person visit.

SOURCE: WI Admin. Code Ch. VE 1.50 (Accessed Nov. 2022).

Last updated 11/21/2022

Licensure Compacts

Member of the Interstate Medical Licensure Compact.

SOURCE:  Interstate Licensure Compact, Compact Map, (Accessed Nov. 2022).

Member of the Nurse Licensure Compact

SOURCE: Nurse Licensure Compact (Accessed Nov. 2022).

Member of Physical Therapy Compact. (not yet issuing compact licenses)

SOURCE:  PT Compact.  (Accessed Nov. 2022). 

Member of the Psychology Interjurisdictional Compact

SOURCE: PSYPACT Compact Map (Accessed Nov. 2022).

Member of Occupational Therapy Licensure Compact

SOURCE: OT Compact Map. (Accessed Nov. 2022).

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

Last updated 11/21/2022

Miscellaneous

“Telehealth technologies” means the collection of technology tools used to remotely deliver virtual veterinary medical, health, and education services, allowing a veterinarian to deliver enhanced care and education.

SOURCE: WI Admin. Code Ch. VE 1.02 (Accessed Nov. 2022).

Last updated 11/21/2022

Online Prescribing

When a physician uses a website to communicate with a patient located in this state, the physician may not provide treatment recommendations, including issuing a prescription unless the following requirements are met:

  • The physician shall be licensed in the state;
  • The physician’s name and contact information must be made available to the patient;
  • Informed consent is required;
  • A documented patient evaluation performed;
  • A patient health care record is prepared and maintained.

Prescribing based on a static electronic questionnaire does not meet the minimum standard of competent medical practice.

SOURCE: WI Admin. Code MED Ch. 24.07 (Accessed Nov. 2022).

A physician-patient relationship may be established through telemedicine.

SOURCE: WI Admin. Code MED Ch. 24.03 (Accessed Nov. 2022).

Last updated 11/21/2022

Professional Board Regulations

Medical Examining Board

SOURCE: WI Administrative Code, Med Ch. 24, (Accessed Nov. 2022).

Veterinary Examining Board

SOURCE: WI Admin. Code Ch. VE 1 (Accessed Nov. 2022).

 

Last updated 11/21/2022

Definition of Visit

A CHC encounter is defined as a face-to-face visit on a single DOS between a member and a Medicaid-enrolled CHC provider to provide diagnosis, treatment, or preventive service(s) at the CHC HRSA-approved location including main and off-site locations.

SOURCE: WI ForwardHealth Online Handbook Community Health Center Encounters, (Accessed Nov. 2022).

For currently covered services, services that are considered direct when provided in-person will be considered direct when provided via telehealth.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth & ForwardHealth Update Dec. 2021, No. 2021-50. (Accessed Nov. 2022). 

Last updated 11/21/2022

Eligible Distant Site

For the purpose of this Online Handbook topic, FQHC refers to Tribal and Out-of-State FQHCs. This topic does not apply to Community Health Centers subject to PPS reimbursement.

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

The originating site facility fee is not a FQHC or RHC reportable encounter on the cost report. Any reimbursement for the originating site facility fee must be reported as a deductive value on the cost report.

See: WI Medicaid Live Video Distant Site

Last updated 11/21/2022

Eligible Originating Site

For the purpose of this Online Handbook topic, FQHC refers to Tribal and Out-of-State FQHCs. This topic does not apply to Community Health Centers subject to PPS reimbursement.

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

The originating site facility fee is not a FQHC or RHC reportable encounter on the cost report. Any reimbursement for the originating site facility fee must be reported as a deductive value on the cost report.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth, (Accessed Nov. 2022).

See WI Medicaid Live Video Eligible Sites.

Last updated 11/21/2022

Facility Fee

The originating site facility fee is not a FQHC or RHC reportable encounter on the cost report. Any reimbursement for the originating site facility fee must be reported as a deductive value on the cost report.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth, (Accessed Nov. 2022).

Although federally qualified health centers are not directly reimbursed an originating site fee, HCPCS procedure code Q3014 should be billed for tracking purposes and for consideration in any potential future changes in scope.

SOURCE: ForwardHealth Update Dec. 2021, No. 2021-50. (Accessed Nov. 2022). 

See: WI Medicaid Live Video Facility/Transmission Fee

Last updated 11/21/2022

Home Eligible

A service that is considered an encounter when performed in a CHC location is also considered an encounter when performed by a CHC provider in one of the following locations:

  • Mobile units
  • School visits
  • Hospitals
  • Members’ homes
  • Extended care facilities
  • Primary sites of identified contracted clinicians

SOURCE: WI ForwardHealth Online Handbook Community Health Center Encounters, (Accessed Nov. 2022).

Last updated 11/21/2022

Modalities Allowed

Live Video

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

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth, (Accessed Nov. 2022).

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.

Last updated 11/21/2022

Patient-Provider Relationship

No reference found

Last updated 11/21/2022

PPS Rate

Services billed with modifier GT, FQ, or 93 will be considered under the PPS reimbursement method for non-tribal FQHCs. Billing HCPCS procedure code T1015 (Clinic visit/encounter, all-inclusive) with a telehealth procedure code will result in a PPS rate for fee-for-service encounters. Fee-for-service claims must include HCPCS procedure code T1015 when services are provided via telehealth in order for proper reimbursement.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth, (Accessed Nov. 2022).

Last updated 11/21/2022

Same Day Encounters

ForwardHealth reimburses a CHC a maximum of one PPS rate per encounter type, per member, per DOS, unless the member, subsequent to the first encounter, suffers an illness or injury that requires additional diagnosis or treatment on the same day. A subsequent encounter is a unique situation that cannot be planned or anticipated. For example, a member sees their provider in the morning for a medical condition and later in the day has a fall and returns to the CHC. Subsequent encounters can be medical, dental, or behavioral health when the encounter satisfies the subsequent encounter requirements.

When a CHC member receives services of the same encounter type from more than one of the CHC’s locations (for example, the main clinic, an off-site clinic, and/or a contracted facility) on a single day, the CHC will be reimbursed for only one encounter type, per DOS, unless the additional encounter qualifies as a subsequent encounter.

SOURCE: WI ForwardHealth Online Handbook Community Health Center Encounter Reimbursement, (Accessed Nov. 2022).