Private Payers, Managed Care, and IPAs

All health plans should be reimbursing for telehealth and telephone during the public health emergency.

The reimbursement rates should be equal to the rate for in person services.

Modifiers could be different – Some health plans use 95 and some still use GT.

POS could be 02 or 10.

Listen to your health plans, even if they want you to bill in a way that you are not used to. 

Department of Managed Health Care (DMHC) Updates

DMHC APL 20-009 from March 18, 2020 states: 

Pursuant to the authority granted in the California Emergency Services Act (Gov. Code sections 8566, et seq.), all health plans shall, effective immediately, comply with the following:

  • Health plans shall reimburse providers at the same rate, whether a service is provided in-person or through telehealth, if the service is the same regardless of the modality of delivery, as determined by the provider’s description of the service on the claim.  For example, if a health plan reimburses a mental health provider $100 for  50-minute therapy session conducted in-person, the health plan shall reimburse the provider $100 for a 50-minute therapy session done via telehealth.
  • For services provided via telehealth, a health plan may not subject enrollees to cost-sharing greater than the same cost-sharing if the service were provided in person.
  • Health plans provide the same amount of reimbursement for a service rendered via telephone as they would if the service is rendered via video, provided the modality by which the service is rendered (telephone versus video) is medically appropriate for the enrollee.

DMHC APL 20-013 from April 7, 2020 states:

A health plan may not exclude coverage for certain types of services or categories of services simply because the services are rendered via telehealth, if the enrollee’s provider, in his/her professional judgment, determines the services can be effectively delivered via telehealth. For example, a health plan may not categorically exclude coverage for Applied Behavioral Analysis services delivered via telehealth (video or telephone) during the State of Emergency.

Likewise, during the COVID-19 State of Emergency a health plan may not place limits on covered services simply because the services are provided via telehealth if such limits would not apply if the services were provided in-person. For example, if a health plan allows an enrollee to receive a particular covered service up to three times per week if the enrollee receives the service in-person, the health plan may not limit the service to only once per week if the service is delivered via telehealth.

The Department has heard from providers and enrollees that health plans are requiring their enrollees to access services through the plans’ contracted telehealth vendor (e.g., Teledoc) rather than covering telehealth services delivered by providers who have typically delivered services to the enrollees in person. During the COVID-19 State of Emergency, a health plan may not require enrollees to use the plan’s telehealth vendor, or a different provider from the one the enrollee typically sees, if the enrollee’s provider is willing to deliver services to the enrollee via telehealth and the enrollee consents to receiving services via telehealth.