ModifiedHawaii Department of Human ServicesPolicy N/A

Telehealth implementation — Telehealth & Remote Monitoring coverage criteria

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State guidance governing delivery, billing, provider eligibility, and documentation requirements for Hawai'i Medicaid telehealth services (includes FFS, QI plans, FQHCs, RHCs, and CCS providers).

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ModifiedHawaii Department of Human ServicesPolicy N/A

Telehealth implementation — Telehealth & Remote Monitoring coverage criteria

Customize your policy alerts

Sign up for all Hawaii Department of Human Services policy alerts

Know when Hawaii Department of Human Services releases new policies or updates existing guidance.

Monitor payer policy activity

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State guidance governing delivery, billing, provider eligibility, and documentation requirements for Hawai'i Medicaid telehealth services (includes FFS, QI plans, FQHCs, RHCs, and CCS providers).

Policy Summary

PayerHawaii Department of Human Services

PolicyTelehealth implementation — Telehealth & Remote Monitoring coverage criteria

Policy CodePolicy N/A

Change TypeMODIFIED (time-limited audio-only guidance added)

Effective DateDec 8, 2025

Last ReviewDec 8, 2025

Next Review DateN/A

Key ActionDocument the patient's reason for preferring audio-only care in the medical record and use modifier 'FQ' for qualifying audio-only mental health services.

SourceLink

POLICY UPDATE CHANGES

Audio-only real-time communication technology guidance is effective through December 31, 2027.

Updated guidance including a new 'Care Delivery and Coverage' section and shaded text indicating updates from the prior December 18, 2024 memorandum.

Dec 8, 2025memorandum effective

through 12/31/2027audio-only effective period

95, GQ, GTrequired modifiers

96116, 96121prior auth codes

Coverage Criteria

Eligible providers and services

Covered when ALL of the following are met:

Core eligibility: Provider is eligible to bill Hawai'i Medicaid and is practicing within their professional scope to deliver services appropriate for the telehealth modality

From 'ELIGIBLE PROVIDERS' section

Service appropriateness: Service must be appropriate for the telehealth modality, clinically appropriate for the patient, rendered in conformance with the full description of the procedure code, and performed by an eligible Hawai'i Medicaid provider

From 'ELIGIBLE SERVICES' section

Patient notification when in-person care unavailable: If the provider cannot provide in-person services, the provider must inform the patient at each appointment and document in the medical record that the patient was informed of their right to in-person services, the provider's inability to provide in-person care, and that the patient's QI MCO can assist in locating an in-person provider

Documentation requirement from Care Delivery and Coverage

Privacy and security: Services shall be consistent with all federal and state privacy, security, and confidentiality laws

From Care Delivery and Coverage

Distant/hub site location restriction for controlled substances

Covered only if:

Location requirement for controlled substances: Any provider prescribing controlled substances via telehealth must be physically located in the State of Hawai'i

Applies to all providers prescribing controlled substances via telehealth

Distant/hub site eligibility (non-FQHC)

Covered when ANY of the following location conditions are met:

Non-FQHC US locations: Non-FQHC distant/hub sites located within the United States and U.S. territories are eligible distant sites for delivery and payment purposes (EXCEPTION: providers prescribing controlled substances must be located in Hawai'i)

Non-FQHC distant/hub site guidance

FQHC wrap-around services and PPS reimbursement

Covered when ALL of the following are met:

FQHC controlled-substance location: If prescribing controlled substances, the FQHC provider must be located in the State of Hawai'i

FQHC-specific controlled-substance rule

Provision and documentation of wrap-around services: FQHC must ensure provision of relevant wrap-around non-billable services and must document in the patient's medical record how and when those services will be provided

Wrap-around services must be documented; may occur at patient location to ensure receipt

PPS reimbursement eligibility: An FQHC site that provides the relevant wrap-around services may be eligible for Prospective Payment System (PPS) reimbursement per applicable Hawai'i statute

Refer to HRS §346-53.64(5) for providers who may provide PPS services

Audio-only reimbursement criteria

Audio-only real-time telehealth services for diagnosis, evaluation, or treatment of a mental health disorder are reimbursable when ALL of the following are met:

Audio-only reimbursement conditions: 1) The provider has the technical capacity to furnish two-way audio-video telehealth; 2) Audio-only mode is the patient's preference; 3) The patient's medical record documents the reason for the patient's preference for audio-only (examples: inadequate broadband, AV technology unavailable, or patient inability/unwillingness to use video); 4) In-person visit requirements are met: (a) an in-person visit must have occurred within six months prior to the initial audio-only service; (b) thereafter, at least one medically necessary in-person service must be furnished within each 12-month period while telehealth continues; if no medically necessary service is required within 12 months, the next medically necessary service must be furnished in-person and the record must document the reason an in-person visit was not furnished within that 12-month period; the provider may request plan consideration for up to an additional 6 months on a case-by-case basis

From Attachment B; effective through 12/31/2027 per Act 217

FQHC telehealth coverage criteria

Covered when ALL of the following are met

FQHC eligible provider: Provider is eligible to bill Hawai'i Medicaid, practicing within scope, and delivering services appropriate for telehealth modality

FQHC eligibility requirement

State location for controlled substances: All providers prescribing controlled substances must be located in the State of Hawai'i

Applies to FQHC providers prescribing controlled substances

Wrap-around services provision and documentation: FQHCs must ensure provision of relevant wrap-around non-billable services and document how and when those services will be provided in the patient's medical record; efforts may include delivering services at the patient's location

Documentation required in patient record

Clinical appropriateness:

Patients should not receive telehealth services in public or semi-public settings unless the patient gives consent or there are exigent circumstances. The policy follows U.S. HHS OCR expectations that telehealth be delivered in private settings; providers should avoid public or semi-public originating sites and document patient consent when services are provided in such environments. Additionally, if a provider cannot offer in-person services for an appointment, the provider must inform the patient of their right to in-person care and document that the patient was informed and that the QI MCO can assist in locating an in-person provider.

All providers who prescribe controlled substances via telehealth must be physically located in the State of Hawai'i at the time of prescribing. Claims for controlled-substance prescribing delivered while the provider is located outside Hawai'i may be denied; this location requirement is explicit and applies across non-FQHC and FQHC distant/hub sites.

Clinical psychologists and clinical social workers may bill and receive payment for individual psychotherapy delivered via a telecommunications system. However, these practitioners may not seek payment for medical evaluation and management services when furnishing care via telecommunication. Providers must follow the documentation and in-person visit timing requirements in Attachment B when using audio-only interactions for mental health services.

Federally Qualified Health Center (FQHC) behavioral health providers who deliver services at a non-FQHC site within the United States or U.S. territories may continue to receive Prospective Payment System (PPS) reimbursement only as an exception while MedQUEST's State Plan Amendment is under review by CMS. FQHCs must still meet the FQHC-specific requirements in this guidance, including documentation of provision of relevant wrap-around non-billable services and adherence to the State location requirement for controlled-substance prescribers.

This inventory item is present in the planner but contains no summary or source text in the guidance; no coverage statement is available to populate this block.

Coding and Billing Codes

Modifier CodesModifierCovered

95	Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System
GQ	Telehealth service rendered via asynchronous telecommunications system
GT	Telehealth service rendered via interactive audio and video telecommunications system

Suggested Telehealth CPT/HCPCS Codes (Attachment A)mixedCovered

0378T	Visual field assessment, with concurrent real time data analysis and accessible data storage with patient-initiated data transmitted to a remote surveillance center for up to 30 days; review and interpretation with report
90791	Psychiatric diagnostic evaluation
90792	Psychiatric diagnostic evaluation with medical services
90832	Psychotherapy, 30 minutes with patient
90833	Psychotherapy, 30 minutes with patient when performed with an evaluation and management service
90834	Psychotherapy, 45 minutes with patient
90836	Psychotherapy, 45 minutes with patient when performed with an evaluation and management service
90837	Psychotherapy, 60 minutes with patient
90838	Psychotherapy, 60 minutes with patient when performed with an evaluation and management service
90845	Psychoanalysis

1–10 of 41

1/5

Suggested telehealth codes (video / general telehealth)mixed

93270	External patient auto activated electrocardiographic rhythm derived event recording up to 30 days, 24-hour attended monitoring; recording
93271	External patient event recording; transmission and analysis
93272	External patient event recording; review and interpretation by physician or qualified health care professional
93294	Interrogation device evaluation(s) (remote), up to 90 days; pacemaker system with interim analysis, reviews and reports
93295	Interrogation device evaluation(s) (remote), up to 90 days; implantable defibrillator system with analysis, review(s) and report(s)
93296	Interrogation device evaluation(s) (remote), up to 90 days; remote data acquisition(s) receipt of transmissions and technician review
93297	Interrogation device evaluation(s) (remote) up to 30 days; implantable cardiovascular monitor system analysis and report
93298	Professional interrogation device evaluation(s) (remote) up to 30 days; implantable loop recorder system analysis and report
96040	Medical genetics and genetic counseling services
96116	Neurobehavioral status exam, per hour

1–10 of 24

1/3

Attachment B suggested codes for audio-only real-time communication technology (temporary through 12/31/2027)mixedCovered

90785	Psychiatric services complicated by communication factor
90791	Psychiatric diagnostic evaluation
90792	Psychiatric diagnostic evaluation with medical services
90832-90838	Psychotherapy (30-60 minutes) and psychotherapy with E/M
90839-90840	Psychotherapy for crisis (first hour and each additional 30 minutes)
90845-90853	Psychoanalysis, family psychotherapy, group psychotherapy
96116-96139	Neurobehavioral and psychological testing and administration codes
96156-96167	Assessments and treatment of behavior impacting health (various settings)
98966-98968	Telephone medical discussion by nonphysician professional (5-30 minutes)
99406-99407	Smoking and tobacco use counseling

1–10 of 20

1/2

Suggested codes for audio-only real-time communication technologyHCPCS

G0447	Face-to-face behavioral counseling for obesity, 15 minutes
G0459	Inpatient telehealth pharmacologic management, including prescription, review of medication with no more than minimal medical psychotherapy
G0514	Prolonged preventive service(s) (beyond the typical service time of the primary)
G2086	Office-based treatment for opioid use disorder; at least 70 minutes in the first calendar month
G2087	Office-based treatment for opioid use disorder, including care coordination
G2088	Office-based treatment for opioid use disorder, including care coordination
G2211	Visit complexity inherent to E/M associated with medical care services serving as continuing focal point; prolonged office or other outpatient E/M service(s)
G2212	Prolonged office or other outpatient evaluation and management service(s)

Remote monitoring duration examples

Examples (30-day monitoring)Codes such as 92228, 93297, 93298, 93270-93272 describe remote monitoring/interrogation and event recording services with monitoring intervals up to 30 days.

Examples (90-day monitoring)Codes 93294, 93295, 93296 are described for interrogation/device evaluation with monitoring intervals up to 90 days.

Device support and technical codesCode 93268 describes technical support for connection and patient instructions for external monitoring devices (used with remote monitoring services).

In-person visit timing

Initial in-person requirementAn in-person visit must occur within six months prior to the initial audio-only service.

Provider Actions and Operational Requirements

Note

Use Attachment A suggested telehealth codes for billing (informational)

Refer to Attachment A for the list of CPT and HCPCS codes that are identified as suggested candidates for telehealth billing (Attachment A lists prime candidates though other codes may be billed).

Attachment A contains the CPT/HCPCS codes considered prime candidates for telehealth services; other codes may also be billed per attachments.

Prior Authorization

Prior authorization required for neurobehavioral testing codes

Prior authorization is required before billing for CPT codes 96116 (neurobehavioral status exam, first hour) and 96121 (each additional hour).

Do not bill 96116 or 96121 without obtaining prior authorization.

Background and Policy Scope

MedQUEST supports the medically appropriate use of telehealth to provide high-quality care in conformance with Hawai'i law and implementing statutes. Telehealth modalities covered include audio-visual real-time communications and, for certain mental health services to patients in their homes, audio-only real-time communications when the patient is unable or does not consent to video. Policy requirements emphasize provider eligibility, clinical appropriateness for the telehealth modality, privacy and security safeguards, and documentation of patient notification and in-person visit options.

Definitions

AV telehealth — audio-visual real-time telehealth definition

DefinitionAudio-visual real-time telehealth (AV telehealth) is multimedia communications equipment that includes, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner.

Reference for codesSee Attachment A for suggested telehealth codes applicable to AV telehealth (Attachment A is referenced in Additional Guidance).

Privacy expectationProviders are expected to implement HIPAA safeguards and conduct telehealth in private settings when delivering AV telehealth.

Audio-only real-time communication technology — definition and allowed uses for mental health services

DefinitionAudio-only real-time communication technology (Audio-only) is two-way, real-time audio-only communication used for diagnosis, evaluation, or treatment of a mental health disorder to a patient in their home when the patient cannot or does not consent to video, provided the distant site clinician is technically capable of AV telehealth.

Revision History

2025-12-08policy_effective_date

MedQUEST telehealth guidance (including new Care Delivery and Coverage section) issued and effective; guidance references Act 217 (SB1281, 2025).

2025-12-08audio_only_time_limited_stance_addedLatest

Audio-only real-time communication technology guidance specified as time-limited and effective through December 31, 2027.

Policy Summary

PayerHawaii Department of Human Services

PolicyTelehealth implementation — Telehealth & Remote Monitoring coverage criteria

Policy CodePolicy N/A

Change TypeMODIFIED (time-limited audio-only guidance added)

Effective DateDec 8, 2025

Last ReviewDec 8, 2025

Next Review DateN/A

Key ActionDocument the patient's reason for preferring audio-only care in the medical record and use modifier 'FQ' for qualifying audio-only mental health services.

SourceLink

On This Page

Services provided via telehealth must be clinically appropriate for the patient, rendered per the full procedure code description, and performed by an eligible Hawai'i Medicaid provider

FQHC service appropriateness

Ongoing in-person frequencyAfter the initial in-person visit, a minimum of one medically necessary in-person service must occur within 12 months and every 12 months thereafter if audio-only services continue.

Exception / plan considerationIf additional time (up to 6 months after the initial audio-only visit) is needed to meet the in-person requirement, the health plan may consider the request on a case-by-case basis.

Billing Rule

Use Attachment B suggested audio-only codes (through 12/31/2027)

Suggested audio-only codes (including listed G‑codes and specific CPT codes in Attachment B) may be used for audio-only real-time communication technology through December 31, 2027; follow Attachment B for applicability.

Attachment B lists suggested audio-only codes (temporary guidance effective through 12/31/2027).
Examples in Attachment B include 90840, 90845–90847, 90853, 96116–96131 and G0447, G0459, G0514, G2086–G2088, G2211–G2212 among others.

Documentation Required

Inform patient and document when unable to provide in‑person services; FQHC wrap‑around documentation

If you cannot provide in‑person services for an appointment, inform the patient that they have the right to in‑person services, that you are unable to provide in‑person care, and that the patient’s QI MCO can assist in finding an in‑person provider; document this information in the patient’s record. FQHCs must also document how and when required wrap‑around non‑billable services will be provided.

Document in the medical record that the patient was informed of the right to in‑person care, provider inability to furnish in‑person care, and MCO assistance.
FQHCs must document provision plans for wrap‑around non‑billable services in the patient's medical record.

Documentation Required

Document patient reason for audio‑only preference and FQHC wrap‑around plans

For audio‑only services, document the patient’s reason for preferring audio‑only (e.g., inadequate broadband, lack of video capability, patient does not wish to use video). For FQHCs, also document how and when required wrap‑around non‑billable services will be provided.

Record specific reason(s) the patient prefers audio‑only communication in the medical record.
FQHCs must record how and when wrap‑around non‑billable services will be provided to the patient.

Billing Rule

Use modifier 'FQ' when billing audio‑only mental health services

When billing for audio‑only real‑time communication technology, append modifier 'FQ' to indicate the service was audio‑only, was for diagnosis/evaluation/treatment of a mental health disorder, and met Attachment B reimbursement conditions.

Use modifier 'FQ' on claims for audio‑only services meeting Attachment B conditions.

Documentation Required

Document patient notification and FQHC wrap‑around service plans

If you are unable to offer in‑person services, inform the patient of their right to in‑person care and document that notification in the patient record; FQHCs must also document how and when wrap‑around non‑billable services will be provided.

Document the patient notification and FQHC wrap‑around service plans in the medical record.

Step Therapy

Prescriber must be located in Hawai‘i to prescribe controlled substances via telehealth

Providers who prescribe controlled substances via telehealth must be physically located in the State of Hawai‘i at the time of prescribing; failure to meet this location requirement may result in denial of reimbursement or coverage.

Ensure the prescriber is located in Hawai‘i when prescribing controlled substances via telehealth.

Denial Risk

Denial risk if audio‑only documentation or in‑person visit requirements are not met

Failure to document the patient's reason for preferring audio‑only mode, failure to meet the required prior in‑person visit timing, or not demonstrating Attachment B conditions in the record may result in nonpayment or denial.

Document reason for audio‑only preference and compliance with in‑person visit timing (initial within 6 months and then at least annually thereafter or documented exception).
Maintain records showing Attachment B conditions were met for audio‑only reimbursement.

Denial Risk

Do not bill 96116 or 96121 without prior authorization

Billing for CPT codes 96116 or 96121 without obtaining the required prior authorization risks claim denial.

Obtain prior authorization before billing 96116 or 96121.

Denial Risk

Claims may be denied if controlled‑substance prescriber is outside Hawai‘i

If a provider prescribes controlled substances while physically located outside the State of Hawaiʻi, claims may be denied; ensure prescribers are located in Hawai‘i when prescribing controlled substances by telehealth.

Verify and document provider location in Hawai‘i when prescribing controlled substances via telehealth.

Allowed usePermitted only for mental health disorder services to a patient in their home when video is unavailable or not consented to, and when the provider has capacity to furnish audio-video services.

Documentation requirementThe patient's medical record must document the reason for choosing audio-only (e.g., inadequate broadband, unavailable video, or patient inability/unwillingness to use video).

Originating/Spoke site — definition of patient location during service

DefinitionOriginating/Spoke site is the location where the patient is located at the time services are provided by telehealth (including the patient’s home, provider office, hospital, RHC, FQHC, school-based health center, or other nonmedical environments).

Residence includedThe originating site explicitly includes a patient’s residence.

Public setting cautionPatients should not receive telehealth services in public or semi-public settings absent patient consent or exigent circumstances.

Distant/Hub site — definition of provider location and HIPAA safeguard requirement

DefinitionDistant/Hub site is the location of the enrolled Hawai‘i Medicaid provider delivering Medicaid-eligible services through telehealth.

HIPAA safeguardsProviders at the distant/hub site are expected to implement HIPAA safeguards and conduct telehealth in private settings (e.g., a clinician in a clinic or office connecting to a patient at home or another clinic).

Provider location implicationFor controlled substances, providers prescribing must be located in the State of Hawai‘i (see coverage criteria).

Audio-only real-time communication technology (alternate chunk) — definition when distant clinician is capable

Definition (when clinician capable)Audio-only real-time communication technology is two-way, real-time audio-only communication used when the distant site clinician is technically capable of audiovisual telehealth but the patient is not able or does not consent to video.

ContextThis definition is provided in Attachment B, which sets conditions for reimbursement through December 31, 2027 per Act 217.

Provider capacity requirementThe provider must have the capacity to furnish two-way audio-video telehealth even when delivering services audio-only.

AV telehealth (attachment reference)

Attachment referenceAV telehealth guidance and suggested codes are referenced in Attachment A — see Attachment A for suggested telehealth CPT/HCPCS codes (not for audio-only).

See alsoAdditional Guidance section cross-references Attachment A for AV telehealth code guidance.

Billing noteAttachment A lists suggested telehealth codes; other codes may also be billed per Attachment A guidance.

Audio-only (attachment reference)

Attachment referenceAudio-only services and conditions for reimbursement are specified in Attachment B (real-time audio-only interactions), effective through 12/31/2027.

Modifier guidanceUse modifier 'FQ' when billing audio-only real-time communication technology to indicate the service met Attachment B conditions and was for diagnosis, evaluation, or treatment of a mental health disorder.

Documentation guidanceAttachment B requires documentation of the patient's reason for preferring audio-only mode and sets in-person visit timing requirements.