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Telehealth COVID-19 and Unwinding Alerts and Updates Resources for Providers

This page includes summaries and explanations of materials, FAQs, and resources related COVID-19, Unwinding and telehealth.

Background on Telehealth Expansion

ForwardHealth has expanded the definition of telehealth in permanent policy to mean the use of telecommunications technology by a Medicaid-enrolled provider to deliver health care services including assessment, diagnosis, consultation, treatment, or transfer of medically relevant data in a functionally equivalent manner as that of an in-person contact. Telehealth may include real-time interactive audio-only communication. Telehealth does not include communication between a provider and a member that consists solely of an email, text, or fax transmission.

“Functionally equivalent” means that when a service is provided via telehealth, the transmission must be of sufficient quality as to be the same level of service as an in-person visit. Transmission of voices, images, data, or video must be clear and understandable.

In addition to expanding the definition of telehealth, ForwardHealth added permanent coverage via telehealth for currently covered services that are functionally equivalent to an in-person visit. ForwardHealth also expanded coverage for certain synchronous (real-time) and asynchronous (“store and forward”, not real-time) services.

Temporary Versus Permanent Telehealth Policy

Temporary telehealth policy was established to ensure access to health services during the COVID-19 pandemic. Certain temporary federal public health emergency (PHE) allowances ended on May 11, 2023 (the date the PHE expired) while all other temporary policy ended on June 1, 2023 (the first day of the first month after the end of the PHE).

Permanent Telehealth Policy

(Effective June 1, 2023—The First Day of the First Month After the Public Health Emergency Ended)

Permanent telehealth policy became effective on the first day of the first month after the federal PHE related to the COVID-19 pandemic expired. Services identified under permanent policy could be billed under either temporary or permanent telehealth guidelines to aid in the transition from permanent to temporary policy.

Detailed information about permanent telehealth policy and billing guidance on the transition from temporary to permanent reimbursement is included in published ForwardHealth Updates and Alerts, which are available in the Understanding the Telehealth Alerts and Updates section of this page. Refer to the Telehealth chapter of the ForwardHealth Online Handbook for additional information on permanent telehealth policy and reimbursement requirements. Refer to the ForwardHealth Online Handbook and Temporary Policies section of this page for instructions on how to access the Telehealth chapter.

Temporary Telehealth Policy During the Federal Public Health Emergency

(Effective Until May 11, 2023—The Day That the Public Health Emergency Ended)

PHE allowances for certain temporary policies were established during the COVID-19 pandemic. These temporary allowances continued until the federal PHE related to the COVID-19 pandemic expired unless providers are notified otherwise in writing prior to that time. Temporary allowances for these services expired on the day the federal PHE expired. The temporary allowances are detailed in the following ForwardHealth Alerts.

ForwardHealth Alerts Pertaining to Temporary Allowances

(Effective Until May 11, 2023—The Day That the Public Health Emergency Ended)

Alert and Release Date Affected Parties Description of Change Temporary or Permanent
ForwardHealth Alert 051, “Temporary Policy Changes for Personal Care Providers to Continue Through the Public Health Emergency” (12/21) Home Health Agencies, Personal Care Agencies, HMOs and Other Managed Care Programs Allows remote supervision of personal care workers by registered nurses (RNs) and timesheet submission guidance to continue through the PHE. Temporary
ForwardHealth Alert 052, “Continuation of HIPAA Flexibilities Through the Public Health Emergency” (12/21) All Providers, HMOs and Other Managed Care Programs Allows Health Insurance Portability and Accountability Act of 1996 (HIPAA) flexibilities related to the PHE to remain in effect. Temporary
Alert 053, “Temporary Changes to Narcotic Treatment Services to Continue Through the Public Health Emergency” (12/21) Narcotic Treatment Services Providers, HMOs and Other Managed Care Programs Allows real-time telephonic communication, which includes submitting claims for phone calls under the five-minute threshold, in lieu of face-to-face daily dosing contact by RNs or licensed practical nurses (LPNs) working in an opioid treatment program clinic to continue through the PHE. Temporary

Temporary Policy

(Effective Until June 1, 2023—The First Day of the First Month After the Public Health Emergency Ended)

Temporary telehealth policy remained in effect until the switch to permanent policy occured. ForwardHealth allowed providers to submit claims for services identified as permanent telehealth procedure codes under either the temporary or permanent telehealth billing guidelines until June 1, 2023. (Refer to ForwardHealth Update 2021-21, “Transition From Temporary to Permanent Synchronous Telehealth Coverage Policy and Billing Guidelines.”))

Detailed information about temporary telehealth policy is included in published Updates and Alerts, which are available in the Understanding the Telehealth Alerts and Updates section of this page.

Providers are reminded that they can submit claims within 365 days from the date of service to receive reimbursement.

Additional Information

For additional information about telehealth expansion, visit the Wisconsin Department of Health Services (DHS) Medicaid Telehealth Expansion webpage.

Understanding the Telehealth Alerts and Updates

The policy communications described below are part of a series of ForwardHealth Updates and Alerts related to telehealth expansion. Some have been issued in response to the Wisconsin PHE for COVID-19, pursuant to Wis. Stat. § 49.45(61), and were temporary measures, while others are permanent policy updates. As a reminder, permanent policies are effective June 1, 2023. Temporary policies were effective until the switch to permanent policy occured.

ForwardHealth Updates Pertaining to Telehealth

Update and Release Date Affected Parties Description of Policy Change Temporary or Permanent
Update 2023-02, “Clarification of Telehealth Supervision Requirements and Delivery” (2/1/23) All Providers, HMOs and Other Managed Care Programs Clarifies telehealth policy related to supervision requirements and delivery and includes both permanent and temporary policy. Permanent and Temporary
Update 2023-01, “Expanded Coverage for Permanent Telehealth Policy” (1/6/23) All Providers, HMOs and Other Managed Care Programs Details on limited asynchronous and other telehealth services that will be reimbursable under ForwardHealth as part of permanent telehealth policy. Permanent
Update 2022-13, “Originating Site Fee Expansion for Telehealth Services” (3/24/22) All Providers, HMOs and Other Managed Care Programs Provides information related to the expansion of originating site locations eligible for the originating site fee during a telehealth visit under the permanent policy. Permanent
Update 2022-02, “Permanent Telehealth Policy for School-Based Services” (Revised 9/9/22) School-Based Services Providers, HMOs and Other Managed Care Programs Provides information related to the implementation of permanent policy for school-based services, including permanent policy requirements and includes temporary allowances that will continue through the end of the federal PHE unless providers are notified otherwise in writing. Permanent
Update 2022-01, “Permanent Teledentistry Policy” (Revised 9/9/22) Refer to the “To” list on page one of this Update for affected provider types. Provides information related to the implementation of permanent teledentistry policy, including permanent policy requirements, and includes temporary allowances that will continue through the end of the federal PHE unless providers are notified otherwise in writing. Permanent
Update 2021-50, “Permanent Telehealth Coverage Policy and Billing Guidelines” (Revised 10/20/22) All Providers, HMOs and Other Managed Care Programs Provides information related to the implementation of permanent telehealth policy, including permanent policy requirements, and includes temporary allowances that will continue through the end of the federal PHE unless providers are notified otherwise in writing. Permanent
Update 2021-21, “Transition From Temporary to Permanent Synchronous Telehealth Coverage Policy and Billing Guidelines” (Revised 9/9/22) Refer to the “To” list on page one of this Update for affected provider types. Updates to the maximum allowable fee schedule will identify which services are allowable under permanent policy. Permanent
Requires providers to bill permanent synchronous telehealth services with applicable telehealth place of service codes and modifiers when permanent policy is effective. Permanent
Allows providers to submit claims for services identified as permanent telehealth procedure codes under either temporary or permanent telehealth billing guidelines until permanent policy becomes effective. Temporary
Update 2020-36, “Temporary Policy for Interprofessional Consultations and Remote Physiologic Monitoring” (8/28/20) Refer to the “To” list on page one of this Update for affected provider types. For specific provider types, ForwardHealth covers remote physiologic monitoring and medically necessary interprofessional consultations, also known as provider-to-provider consultations, where the primary care provider requests a consultation with a specialist without the need for the specialist to see the member. (This temporary policy is replaced by the permanent policy in Update 2021-50.) Temporary
Update 2020-15, “Additional Services to be Provided Via Telehealth” (Revised 6/10/21) Refer to the “To” list on page one of this Update for affected provider types. Allows remote services utilizing interactive synchronous (real-time) technology, including audio-only phone communication, for currently covered services that can be delivered with functional equivalency to the face-to-face services. This applies to all service areas and all enrolled providers allowable under current ForwardHealth policy. Temporary
Update 2020-13, “Temporary Changes to Clinical Policy and Prior Authorization” (Revised 5/11/20) All providers, HMOs, and Other Managed Care Programs Provides changes to clinical policy and prior authorization (PA), including allowing remote supervision, waiving requirements for face-to-face visits, and extending certain PA dates for an additional 90 days. Temporary
Update 2020-12, “Temporary Changes to Telehealth Policy and Clarifications for Behavioral Health and Targeted Case Management Providers” (Revised 5/8/20) Refer to the “To” list on page one of this Update for affected provider types. Individual mental health and substance abuse practitioners who practice in a setting other than a Division of Quality Assurance-certified outpatient mental health clinic may provide telehealth services. Permanent
Clarifies that no restrictions on distant sites (provider location) exist for reimbursement of telehealth encounters delivered in the United States. Permanent
Clarifies guidance regarding federal enforcement of HIPAA regulatory requirements. Temporary
Includes several provisions (such as mental health screenings, comprehensive community services, community support program services, community recovery services, behavioral treatment services, and targeted case management) that apply specifically to behavioral health providers. Temporary
Update 2020-09, “Changes to ForwardHealth Telehealth Policies for Covered Services, Originating Sites, and Federally Qualified Health Centers” (Revised 3/25/20) Refer to the “To” list on page one of this Update for affected provider types. Removes restrictions on originating sites (location of patient at time of telehealth encounter). Permanent
Expands allowable services to inpatient consults, inpatient prolonged services, e-visits, nursing facility service assessments, and telephone evaluation and management services. Permanent
Clarifies billing guidance for tribal and non-tribal federally qualified health centers (FQHCs). Permanent

ForwardHealth Alerts Pertaining to Telehealth

Alert and Release Date Affected Parties Description of Change Temporary or Permanent
ForwardHealth Alert 019, “Opioid Treatment Programs Submitting Claims for Phone Calls Under the Five-Minute Threshold” Revised 5/15/21 Narcotic Treatment Services Providers, HMOs and Other Managed Care Programs Allows opioid treatment programs to submit claims for phone calls under the five-minute threshold. Temporary
ForwardHealth Alert 017, “Billing Clarifications for Dental Telehealth Services” Revised 5/11/20 Dentists, HMOs and Other Managed Care Programs Dental providers who can provide services via telehealth during the PHE that are functionally equivalent to the face-to-face service should review Update 2020-15 for billing guidance. ForwardHealth does not follow American Dental Association guidance for billing procedure codes D9995 and D9996. For orthodontic services, providers may request a PA amendment to extend the treatment plan timeframe. (Information in this temporary policy is replaced by the permanent policy in Update 2022-01.) Temporary
ForwardHealth Alert 013, “Enhanced Reimbursement for Therapy Provided as Part of the Birth to 3 Program Using Telehealth” Revised 5/11/20 Occupational Therapists, Physical Therapists, Rehabilitation Agencies, Speech and Hearing Clinics, Speech-Language Pathologists, Therapy Groups, HMOs and Other Managed Care Programs ForwardHealth will reimburse therapy providers supplying services as part of the Birth to 3 Program at an enhanced rate when occupational, physical, and/or speech therapy is performed using telehealth, the member is located in their natural environment and the modifier TL is included on the claims form. (Information in this temporary policy is replaced by the permanent policy in Update 2021-50.) Temporary
ForwardHealth Alert 009, “Temporary Changes for Durable Medical Equipment and Disposable Medical Supplies Face-to-Face Requirements” Revised 5/11/20 Refer to the “To” list on the Alert for a list of affected providers. Suspends face-to-face visit requirement for initial prescription of durable medical equipment or disposable medical supplies. Temporary
ForwardHealth Alert 005, “Temporary Changes to Narcotic Treatment Services” Revised 5/7/20 Narcotic Treatment Services Providers, HMOs and Other Managed Care Programs Allows real?time telephonic communication in lieu of face-to-face daily dosing contact by RNs or LPNs working in an opioid treatment program clinic. Temporary
ForwardHealth Alert 004, “Tribal and Non-Tribal Federally Qualified Health Centers Billing Guidance for Telehealth Policy Changes in ForwardHealth Update 2020-09” 3/23/20 Community Health Centers, Tribal Federally Qualified Health Centers, HMOs and Other Managed Care Programs Allows services billed with modifier GT to be considered under the Prospective Payment System reimbursement method for non-tribal FQHCs. For tribal FQHCs, telehealth service claims will count as encounters as allowed under encounter counting logic through interim reporting and cost reporting processes. (Information about this permanent policy is in Update 2021-50.) Permanent
ForwardHealth Alert 002, “Temporary Policy Changes for Personal Care Providers” Revised 5/11/20 Home Health Agencies, Personal Care Agencies Allows remote supervision for personal care services by RNs and provides timesheet guidance. Temporary

ForwardHealth Online Handbook and Temporary Policies

Temporary policy changes made by ForwardHealth in response to the COVID-19 outbreak are only found in Updates and Alerts. These temporary policy changes are not included in the ForwardHealth Online Handbook because the Online Handbook is an updated repository of current, permanent ForwardHealth policies.

Permanent policy changes made by ForwardHealth can be found in published Updates, Alerts, and the Online Handbook. Providers are encouraged to use the Online Handbook when referencing permanent policies. All published Updates and Alerts related to COVID-19 will be available on this page.

Permanent telehealth policy can be found in the Telehealth chapter of the Online Handbook.

To get to the Telehealth chapter, follow the directions below:

  1. Visit the ForwardHealth Portal home page.
  2. Click Online Handbooks under the Policy and Communication heading, located lower on the page in the center column.
  3. Click “I Accept” at the bottom of the license agreement page and then Submit Agreement.
  4. Under Select an Online Handbook on the left side of the webpage, select BadgerCare Plus and Medicaid from the Choose a program: drop-down menu.
  5. Click the Choose a service area: drop-down menu and select the appropriate service area.
  6. Under View Sections and Chapters, select the Telehealth chapter from the Covered and Noncovered Services section.
  7. Select the appropriate topic.

Frequently Asked Questions

ForwardHealth has answered FAQs (last updated 4/21/23) from providers about the telehealth policy changes.

Contacts

For policy and billing related questions, contact Provider Services at 800-947-9627.

 
 
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