CurrentDistrict of Columbia Department of Health Care FinancePolicy N/A

Medicaid-Reimbursable Telemedicine Services

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This rule governs eligibility standards for District of Columbia Medicaid beneficiaries receiving health care through telemedicine and participation requirements for providers delivering those services. It applies to Medicaid fee-for-service and managed care program requirements and establishes eligible originating sites, distant site providers, technology responsibilities, and related reimbursement limitations.

Policy Summary

PayerDistrict of Columbia Department of Health Care Finance

PolicyMedicaid-Reimbursable Telemedicine Services

Policy CodePolicy N/A

Change TypeFinal rule amendments

Effective DateN/A

Next Review DateN/A

Key ActionWhen the beneficiary's home is the originating site, the distant site provider must ensure that the technology meets the applicable minimum requirements.

SourceLink

POLICY UPDATE CHANGES

Eligible originating sites expanded to include the beneficiary's home.

Fee-for-service-only language was removed to clarify applicability to Medicaid managed care.

Distant site providers are responsible for minimum technology requirements when the beneficiary's home is the originating site.

Remote provider staff and additional eligible Medicaid provider categories were clarified.

3Final amendments

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CurrentDistrict of Columbia Department of Health Care FinancePolicy N/A

Medicaid-Reimbursable Telemedicine Services

Customize your policy alerts

Sign up for all District of Columbia Department of Health Care Finance policy alerts

Know when District of Columbia Department of Health Care Finance releases new policies or updates existing guidance.

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Receive email alerts as soon as relevant payer policies are published or updated.

Policy Summary

PayerDistrict of Columbia Department of Health Care Finance

PolicyMedicaid-Reimbursable Telemedicine Services

Policy CodePolicy N/A

Change TypeFinal rule amendments

Effective DateN/A

Next Review DateN/A

Key ActionWhen the beneficiary's home is the originating site, the distant site provider must ensure that the technology meets the applicable minimum requirements.

SourceLink

POLICY UPDATE CHANGES

Eligible originating sites expanded to include the beneficiary's home.

Fee-for-service-only language was removed to clarify applicability to Medicaid managed care.

Distant site providers are responsible for minimum technology requirements when the beneficiary's home is the originating site.

Remote provider staff and additional eligible Medicaid provider categories were clarified.

3Final amendments

Originating-site settings

9Distant-site settings

HomeNew originating site

ExcludedAudio-only coverage

Not adoptedRemote monitoring

Telemedicine Coverage Standards

General telemedicine reimbursement criteria

Telemedicine services may be reimbursable under the Medicaid program when all applicable requirements are met.

ALL of the following

The service is a Medicaid-covered health care service that can be delivered through telemedicine while meeting the applicable standard of care.
The originating site is an eligible provider type or setting, including a hospital, nursing facility, federally qualified health center, clinic, physician or nurse practitioner group/office, District of Columbia public or public charter school, eligible behavioral health provider, the beneficiary's home, or another setting identified in DHCF guidance.
The distant site provider is an eligible Medicaid provider, including the listed provider types and other Medicaid providers that meet applicable requirements; distant site provider staff may render services remotely.

Consent, privacy, and technology requirements

Additional safeguards apply when telemedicine is used, particularly when the beneficiary receives services at home.

ALL of the following

The beneficiary provides consent to receive telemedicine services in lieu of in-person health care.
Following the public health emergency, the provider obtains the beneficiary's written consent before delivering services via telemedicine.
Telemedicine care complies with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and other applicable laws.
When the beneficiary's home is the originating site, the distant site provider ensures that the technology in use meets the minimum requirements established for telemedicine.

Excluded or unadopted modalities

The following modalities are not covered as permanent telemedicine services under this rule.

ANY of the following

Audio-only telephone services are not permanently reimbursable telemedicine services under this rule.
Services delivered through electronic mail messages are not permanently reimbursable telemedicine services under this rule.
Services delivered through facsimile transmissions are not permanently reimbursable telemedicine services under this rule.
Remote patient monitoring coverage was not adopted and is not available under this rule.

Operational Requirements for Providers

Billing Rule

Home-Originating Technology Requirements

When the beneficiary’s home is the originating site, the distant site provider must ensure the technology used meets the minimum requirements in Subsection 910.3.

Documentation Required

Obtain Beneficiary Consent

Obtain beneficiary consent before delivering telemedicine in lieu of in-person care. Consent requirements remain applicable when the beneficiary receives services at home and may be subject to public health provisions.

Following the public health emergency, written consent is required at all times before delivering telemedicine services.
Providers may use available DHCF-approved methods to demonstrate consent when permitted by applicable guidance.

Telemedicine Terms

Originating site

DefinitionThe originating site is the location or setting where the beneficiary receives telemedicine services.

Eligible provider settingsEligible settings include hospitals, nursing facilities, FQHCs, clinics, physician groups or offices, nurse practitioner groups or offices, DC Public Schools, DC Public Charter Schools, and qualifying behavioral health providers.

Beneficiary’s homeEffective March 12, 2020, the beneficiary’s home and other settings identified in guidance published on the DHCF website are eligible originating sites.

Distant site provider

DefinitionThe distant site provider is the provider location or provider staff responsible for delivering telemedicine services to the beneficiary.

Eligible provider settings

Policy Summary

PayerDistrict of Columbia Department of Health Care Finance

PolicyMedicaid-Reimbursable Telemedicine Services

Policy CodePolicy N/A

Change TypeFinal rule amendments

Effective DateN/A

Next Review DateN/A

Key ActionWhen the beneficiary's home is the originating site, the distant site provider must ensure that the technology meets the applicable minimum requirements.

SourceLink

On This Page

Denial Risk

Maintain Privacy and Legal Compliance

Deliver telemedicine services in compliance with HIPAA and all other applicable laws. The addition of the beneficiary’s home as an originating site does not change these privacy and legal-compliance requirements.

DHCF may issue additional telemedicine HIPAA guidance through its website.

Billing Rule

Permit Compliant Remote Rendering Staff

Distant site provider staff may render telemedicine services remotely when permitted by the rendering provider and when all other requirements in the telemedicine rule are met.

Billing Rule

Meet Provider Eligibility and Standard-of-Care Requirements

Other Medicaid providers may be reimbursed for covered services delivered through telemedicine when the services can be provided through that modality and continue to meet the applicable standard of care.

The listed distant site provider types are non-exhaustive.
Eligibility remains subject to the District Medicaid State Plan or waiver and other applicable requirements.

Denial Risk

Apply Audio-Only Service Limitation

Do not treat telephone audio-only, electronic mail, or facsimile engagements as permanently reimbursable telemedicine services under this rule. These modalities are explicitly excluded by the authorizing legislation.

DHCF temporarily waived the exclusion during the public health emergency under emergency authority.
Permanent reimbursement for audio-only telemedicine would require a legislative amendment; this rulemaking did not adopt such a change.

Denial Risk

Remote Patient Monitoring Not Adopted

Remote patient monitoring coverage was not adopted under this rule and is not covered through this telemedicine rule because it would require additional changes to the District Medicaid State Plan.

Distant site providers include, but are not limited to, hospitals, nursing facilities, FQHCs, clinics, physician groups or offices, nurse practitioner groups or offices, DC Public Schools, DC Public Charter Schools, and qualifying behavioral health providers.

Remote staffDistant site provider staff rendering telemedicine services remotely are included, provided the applicable telemedicine requirements are met.

Home-originating servicesWhen the beneficiary’s home is the originating site, the distant site provider must ensure that the technology meets the minimum requirements in Subsection 910.13.

Audio-only services

Included modalitiesAudio-only services are telemedicine engagements conducted through telephone audio only, electronic mail messages, or facsimile transmissions.

Permanent coverage statusCoverage of services provided via audio-only telephones, electronic mail messages, or facsimile transmissions is explicitly excluded under the authorizing legislation.

Public health emergency exceptionDHCF reimbursed audio-only telemedicine services during the public health emergency under emergency authority, but did not adopt permanent coverage through this rulemaking.

Consent requirementFollowing the public health emergency, providers must receive written beneficiary consent at all times before delivering services via telemedicine.