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Temporary Expansion of Medicaid Telehealth Coverage — Guidance for Coverage during COVID-19 Public Health Emergency
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Defines Alaska Medicaid temporary expansions to telehealth coverage, authorized provider types, permissible modes (live interactive, telephone, online digital), billing codes and modifiers, and service-specific guidance while the federal public health emergency (PHE) is in effect. Affects Alaska Medicaid providers and enrolled service types.
When Telephone and Online Digital E/M Are Reimbursable
Telephone and Online Digital Service Reimbursement Conditions
Covered when ALL of the following are met:
ALL of the following
- Patient is an established patient.
- Service is not related to an E/M service provided within the previous 7 days.
- Service does not lead to or result in an E/M service within 24 hours or the soonest available appointment.
- For audio-only CPT codes billed for dates of service on or after 2022-03-01, modifier FQ must be appended (applies to physician-level CPT 99441-99443 and non-physician CPT 98966-98968); failure to include modifier FQ for dates of service on or after 3/1/2022 will result in denial of payment for audio-only services.
Vision and Direct-Entry Midwife / ESRD Telehealth Exclusion Effective 11/01/2021
Services no longer allowed via telehealth effective November 1, 2021:
ANY of the following
- Direct-entry midwife services may not be performed via telehealth (effective 11/01/2021).
- End-stage renal disease (ESRD) services may not be performed via telehealth (effective 11/01/2021).
- Vision services, including services performed by optometrists and ophthalmologists, may not be performed via telehealth (effective 11/01/2021).
Applicable CPT / Modifier Guidance
| 99441 | Telephone E/M 5-10 minutes |
| 99442 | Telephone E/M 11-20 minutes |
| 99443 | Telephone E/M 21-30 minutes |
| 98966 | Telephone assessment and management, 5-10 minutes (non-physician) |
| 98967 | Telephone assessment and management, 11-20 minutes (non-physician) |
| 98968 | Telephone assessment and management, 21-30 minutes (non-physician) |
| 98970 | Online digital service, 5-10 minutes (non-physician) |
| 98971 | Online digital service, 11-20 minutes (non-physician) |
| 98972 | Online digital service, 21-30 minutes (non-physician) |
| 92002 | Ophthalmological services: intermediate examination, new patient (limited coverage via live interactive during 2020-12-16 through 2021-10-31) |
| 92004 | Ophthalmological services: complete examination, new patient (limited coverage via live interactive during 2020-12-16 through 2021-10-31) |
| 92012 | Ophthalmological services: intermediate examination, established patient (limited coverage via live interactive during 2020-12-16 through 2021-10-31) |
| 92014 | Ophthalmological services: complete examination, established patient (limited coverage via live interactive during 2020-12-16 through 2021-10-31) |
| G2012 | Brief communication technology-based service; Medicare crossover covered |
| G0071 | G0071 — Medicare related; crossover covered |
| FQ | Modifier required for audio-only services (effective 2022-03-01) for specified CPT codes; omission leads to denial |
| GT | Telehealth modifier for live interactive services |
| GQ | Telehealth modifier for asynchronous (store-and-forward) services |
| 95 | Synchronous telemedicine service |
| 02 | Place of service: telehealth |
| 10 | Place of service: unspecified facility (documented guidance uses 10 in case management billing) |
Billing, Documentation, and Operational Requirements
Modifier FQ requirement for audio-only services
For dates of service on or after 2022-03-01, providers must append modifier FQ when billing the specified audio-only CPT codes (99441–99443 and 98966–98968). Failure to include modifier FQ for audio-only services with DOS on/after 2022-03-01 will result in denial of payment.
Rationale required for audio-only FQHC services
Audio-only delivery in FQHCs should be used only when other modalities (including audio/video) are not available; documentation must clearly indicate the rationale for utilizing audio-only. This requirement specifically applies to services provided by psychologists and LCSWs in FQHCs.
- Applicable provider types: psychologists; licensed clinical social workers (LCSWs)
FQHC/RHC reimbursement
Federally Qualified Health Centers and Rural Health Clinics may be reimbursed at their encounter rate for telehealth services when those services are provided by a rendering provider included in the policy. Billing at the encounter rate applies instead of per-procedure billing for included rendering providers.
Use of telehealth modifiers/place of service for case management
When billing case management services provided via telehealth, use the applicable case management procedure codes together with place of service 02 or 10 and include an applicable telehealth modifier. Use one of the telehealth modifiers GT, GQ, FQ, or 95 as appropriate.
- Allowed telehealth modifiers: GT, GQ, FQ, 95
- Allowed place of service codes: 02, 10
Audio-only service timing exclusions
Telephone and online digital services are not reimbursable if a related evaluation/management (E/M) service was provided during the previous 7 days, or if the telephone/online digital service leads to or results in an E/M within 24 hours or the soonest available appointment. Document the timing of the telephone/online digital contact and its relationship to other E/M services (including cumulative online digital time up to 7 days).
- Online digital cumulative time window: up to 7 days per episode
- Do not bill if related E/M in previous 7 days
- Do not bill if it leads to an E/M within 24 hours or the soonest available appointment
Mode of delivery allowed and examples
Live interactive applications such as Zoom, Skype, and FaceTime are allowable for telehealth. Member and provider locations are unrestricted for live interactive, telephone, and online digital modes; document the mode of delivery used and the member and provider locations as appropriate.
- Examples of live interactive apps: Zoom, Skype, FaceTime
- Member and provider locations: unrestricted
Policy Purpose and Scope
This guidance describes Alaska Medicaid’s temporary expansion of telehealth coverage for the duration of the U.S. HHS Secretary’s public health emergency. The expansion authorizes additional provider types (including Autism services providers, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs), home health and hospice providers, and others listed in the policy) to deliver services via telehealth modes. Effective November 1, 2021, direct-entry midwife, ESRD, and vision services (including services performed by optometrists and ophthalmologists) are excluded from telehealth delivery. For dual-eligible members, Medicare crossover codes G2012 and G0071 are covered and applicable copays/deductibles will be reimbursed to the provider.
Permissible modes of delivery include live interactive synchronous audio-video technologies (examples provided: Zoom, Skype, FaceTime), telephone/audio-only services, and online digital patient-initiated communications (such as EHR portal messages or email). Member and provider locations are unrestricted for live interactive, telephone, and online digital modes, allowing services to be provided from home or facility settings. FQHCs and RHCs may be reimbursed at their encounter rate for telehealth services provided by rendering providers included in the policy.
Telephone (audio-only) services are described as evaluation/assessment and management services for an established patient lasting in the 5–30 minute range and are represented by CPT codes 99441–99443 (physician-level) and the alternate non-physician codes 98966–98968. Telephone services are not reimbursable if a related E/M was provided in the previous 7 days or if the telephone service leads to or results in an E/M within 24 hours or the soonest available appointment. Effective for dates of service on or after 2022-03-01, providers must append modifier FQ when billing the specified audio-only CPT codes (99441–99443 and 98966–98968) or claims for audio-only services will be denied.
Online digital evaluation and management services are patient-initiated digital communications with an established patient and may be billed for up to 7 days cumulative per episode using CPT codes 99421–99423 (physician-level) or the non-physician online digital codes 98970–98972. These services are subject to the same timing exclusions as telephone services: not reimbursable if related E/M occurred in the prior 7 days or if the digital service leads to an E/M within 24 hours or the next available appointment.
Service-specific guidance: case management services may be performed via telephone, online digital, or live interactive modes — bill using the applicable case management procedure codes with place of service 02 or 10 and an applicable telehealth modifier (GT, GQ, FQ, or 95). Physical, occupational, and speech therapy are permitted via live interactive modes using standard therapy procedure codes with a GT or 95 modifier. Federally Qualified Health Centers may bill audio-only behavioral health services (e.g., psychiatric diagnostic interviews, individual psychotherapy) using the telephone CPT codes when other modalities are unavailable; documentation must explain the rationale for audio-only delivery.
Billing and modifier notes: use the specified CPT codes for telephone, online digital, vision (temporary window), and other telehealth services per the temporary fee schedule. For audio-only services billed on or after 2022-03-01, failure to include modifier FQ will result in denial of payment. Live interactive services may use common telehealth modifiers and the guidance above for place-of-service and encounter-rate billing for FQHCs/RHCs.
Behavioral health: Alaska Medicaid indicates behavioral health guidance will be published separately by the Division of Behavioral Health; providers should consult the DBH materials and the Telehealth Services Temporary Fee Schedule for rates and additional behavioral-health-specific telehealth details.
Defined Terms
Time Windows and Duration Bands
Policy Update Changes
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