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Telehealth Expansion and Related Resources for Providers

The purpose of this page is to communicate the latest telehealth policy and provide telehealth resources for providers. It includes summaries and explanations of the recently published materials, FAQs, and resources related to 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 functionally equivalent health care services including assessment, diagnosis, consultation, treatment, or transfer of medically relevant data. Telehealth may include real-time interactive audio-only communication. Telehealth does not include communication between a certified provider and a member that consists solely of an email, text, or fax transmission.

“Functionally equivalent” means a service provided via telehealth must meet both of the following criteria:

The quality, effectiveness, and delivery mode of the service provided must be clinically appropriate to be delivered via telehealth.
The service 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 is adding permanent coverage via telehealth for currently covered services that are functionally equivalent to an in-person visit. ForwardHealth is also expanding coverage for certain synchronous (real-time) services.

Face-to-face equivalence for interactive telehealth services exists when a service is delivered from outside the physical presence of a Medicaid member by using audio, video, or telecommunication technology, and there is no reduction in quality, safety, or effectiveness. Documentation must support the service rendered.

Temporary Versus Permanent Telehealth Policy

Temporary telehealth policy established to ensure access to health services during the COVID-19 pandemic. Temporary policy will remain in place until permanent, expanded telehealth policy becomes effective.

Permanent Telehealth Policy

Synchronous (two-way, real-time, interactive communications) and remote physiological monitoring services identified under permanent policy may be reimbursed when provided via telehealth effective on the first day of the first month after the federal public health emergency related to the COVID-19 pandemic expires. For example, if the public health emergency ends on April 12, 2022, permanent policy would become effective for dates of service on and after May 1, 2022. Temporary telehealth policy will remain in effect until the switch to permanent policy occurs when ForwardHealth will require providers to follow permanent billing guidelines for synchronous telehealth and remote physiological monitoring services.

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

Continuation of Federal Public Health Emergency

Public health emergency allowances will continue to apply through the end of the federal public health emergency for certain temporary policies that were established during the COVID-19 pandemic. The temporary allowances will continue through the end of the federal health public emergency unless providers are notified otherwise in writing prior to that time. Temporary allowances for these services are detailed in the following alerts.

ForwardHealth Alerts Pertaining to Temporary Allowances

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	Allows remote supervision of personal care workers by registered nurses and timesheet submission guidance to continue through the public health emergency.	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 public health emergency to remain in effect.	Temporary
ForwardHealth 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 registered nurses or licensed practical nurses working in an opioid treatment program clinic to continue through the public health emergency.	Temporary

Temporary Policy

Temporary telehealth policy will remain in effect until the switch to permanent policy occurs. ForwardHealth is allowing providers to submit claims for services identified as permanent telehealth procedure codes under either the temporary or permanent telehealth billing guidelines until the first day of the first month after the federal public health emergency related to the COVID-19 pandemic expires.

Detailed information about temporary telehealth policy is included in published ForwardHealth 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 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 public health emergency for COVID-19, pursuant to Wis. Stat. § 49.45(61), and are temporary measures, while others are permanent policy updates.

ForwardHealth Updates Pertaining to Telehealth

Update and Release Date	Affected Parties	Description of Policy Change	Temporary or Permanent
ForwardHealth Update 2021-50, “Permanent Telehealth Coverage Policy and Billing Guidelines” (12/22/21)	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 public health emergency unless providers are notified in writing otherwise.	Permanent
ForwardHealth Update 2021-21, “Transition From Temporary to Permanent Synchronous Telehealth Coverage Policy and Billing Guidelines” (7/1/21)	See 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 place of service code 02 and the GT modifier beginning January 1, 2022.	Permanent
		Allows providers to submit claims for services identified as permanent telehealth procedure codes under either temporary or permanent telehealth billing guidelines between July 1, 2021, and December 31, 2021.	Temporary
ForwardHealth Update 2020-36, “Temporary Policy for Interprofessional Consultations and Remote Physiologic Monitoring” (8/28/20)	See 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.	Temporary
ForwardHealth Update 2020-15, “Additional Services to be Provided Via Telehealth” (Revised 5/8/20)	See 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
ForwardHealth 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
ForwardHealth Update 2020-12, “Temporary Changes to Telehealth Policy and Clarifications for Behavioral Health and Targeted Case Management Providers” (Revised 5/8/20)	See 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 the Health Insurance Portability and Accountability Act of 1996 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
ForwardHealth Update 2020-09, “Changes to ForwardHealth Telehealth Policies for Covered Services, Originating Sites, and Federally Qualified Health Centers” (03/18/20)	See 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.	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 Organizations	Dental providers who can provide services via telehealth during the public health emergency that are functionally equivalent to the face-to-face service should review ForwardHealth 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 prior authorization amendment to extend the treatment plan timeframe.	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.	Temporary
ForwardHealth Alert 009, “Temporary Changes for Durable Medical Equipment and Disposable Medical Supplies Face-to-Face Requirements” Revised 5/11/20	See the “To” list on 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 registered nurses or licensed practical nurses 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 federally qualified health centers. For tribal federally qualified health centers, telehealth service claims will count as encounters as allowed under encounter counting logic through interim reporting and cost reporting processes.	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 registered nurses 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 topic (#510) of the Online Handbook.

To get to the Telehealth topic (#510), follow the directions below:

Visit the ForwardHealth Portal home page at www.forwardhealth.wi.gov/WIPortal/.
Click Online Handbooks under the Policy and Communication heading, located lower on the page in the center column.
Click “I accept” at the bottom of the license agreement page and then Submit Agreement.
Click Advanced Search on the right side of the webpage, enter “510,” and click Search*.
Click show links to see the different service areas.
Click one of the service areas listed to be taken to the Telehealth topic of the Online Handbook.

Frequently Asked Questions

ForwardHealth has answered FAQs (last updated 7/1/21) from providers about the telehealth policy changes. Providers have submitted questions as ForwardHealth has been responding to the COVID-19 outbreak. These questions and their answers are included in the PDF. The FAQs will be updated to provide helpful answers to provider questions.

Contacts

For questions related to telehealth, send emails to DHStelehealth@dhs.wisconsin.gov.
For policy and billing related questions, contact Provider Services at 800-947-9627.

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