California’s New Medi-Cal Telehealth Reimbursement Policies Released with Major Changes

Original Source: Center for Connected Health Policy

In mid-August, the California Department of Health Care Services (DHCS) released its finalized telehealth policy update for the following:

  • Medi-Cal (California’s Medicaid Program) fee-for-service program
  • An All Plan Letter (APL) for Managed Care
  • Indian Health Services, Memorandum of Agreement (IHS-MOAs)
  • Family Plan, Access, Care and Treatment (Family PACT)
  • Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs)
  • Local Education Agency (LEA)
  • Vision Care

The policies were effective as of July 1, 2019 though only just released in their final form this month.  For more information regarding how the new fee-for-service policy differs from the previous policy as well as the proposed policy, see CCHP’s comparison cross walk chart.

The provider manual updates sought to increase flexibility, and place the decision with the provider as to the services that are appropriate to deliver via telehealth.

Some highlights from the fee-for-service policy include:

  • Providers decide what modality, live video or store-and-forward, will be used to deliver eligible services to a Medi-Cal enrollee as long as the service is covered by Medi-Cal and meets all other Medi-Cal guidelines and policies, can be properly provided via telehealth and meets the procedural and definition components of the appropriate CPT or HCPCS code.  Additional requirements apply for FQHCs/RHCs and IHS-MOAs.
  • What constitutes as an originating site includes the home and there is no requirement that a provider be with the patient at the time of the telehealth interaction.
  • Addition of e-consult as a subset of store-and-forward and reimbursement for one specific code.
  • Provider must be licensed in CA, enrolled as a Medi-Cal rendering provider or non-physician medical practitioner (NMP) and affiliated with an enrolled Medi-Cal provider group. The enrolled Medi-Cal provider group for which the health care provider renders services via telehealth must meet all Medi-Cal program enrollment requirements and must be located in California or a border community.

The program specific policies (Family PACT, IHS-MOAs, and FQHCs/RHCs) refer providers to the fee-for-service telehealth policy for their basic policy, however IHS-MOAs and FQHCs/RHCs, do have additional restrictions.  For example, e-consult is not separately reimbursable for these entities, and asynchronous store-and-forward can only be utilized for established patients, unless the patient is homeless (or homebound for FQHC/RHCs).  Specific requirements also apply for teleophthalmology and telehealth used by speech-language pathologists under the LEA manual.  An All Plan Letter (APL) addressed to managed care plans on Medi-Cal’s revised telehealth policies also refers its recipients to Medi-Cal’s fee-for-service policy, and states that existing Medi-Cal covered services may be provided via a telehealth modality.  For managed care, telehealth may also be used for purposes of meeting network adequacy requirements, according to the APL.

CCHP has created a comparison chart between the programs that outlines the various changes to the revised Medi-Cal policies, view it here.

CCHP has also created a fact sheet summarizing in more detail the different sections of the updated policy, view it here.


To learn more, visit the DHCS webpage on telehealth where all of the new policy documents can be accessed.