Proposed Addition of Codes for Telehealth Reimbursement in Medi-Cal Program
Letter sent January 31, 2018 to the CA Dept of Health Care Services-Policy, Research and Special Projects Unit
On behalf of the California Telehealth Policy Coalition (Coalition), an affiliation of statewide groups and individuals, we thank you for the opportunity to provide comments on the proposal to expand Medi-Cal telehealth services. We applaud the Department’s efforts to expand the number of services that will be reimbursed when delivered via telehealth technologies, and we ask that the Department consider going further.
Of the proposed codes, the Coalition supports each one for approval. However, there are still many other services that can be appropriately provided via telehealth, but whose corresponding CPT codes are not on this proposed list or the current list of eligible codes. The Coalition suggests that the Department consider a more expansive list, including the recently added set of codes that the California Children Services (CCS) program approved in their December 22, 2017 All County Numbered Letter (NL-16-1217) and the list of approved codes in Medicare. At a minimum, the Medi-Cal and CCS programs should be consistent with respect to services and codes that are covered under both programs and to the extent possible also include what is eligible for telehealth reimbursement in Medicare.
In regards to your inquiry regarding permissible locations and whether the home should be an eligible originating site without a medical practitioner present, the Coalition supports this proposal. Many services can be done without medical personnel physically with the patient and can be done while the patient is at home. This will not only save on potential time and transportation costs, but may also encourage patients to keep their appointments if they can avoid taking time off of work or are unable to travel, such as those who may be disabled and homebound.
The Coalition is pleased to see these efforts by the Department and we believe there are more opportunities that can be explored. We encourage the Department to also consider allowing and reimbursing other modalities such as store-and-forward (beyond what is currently reimbursed) and remote patient monitoring (RPM). Current law allows the Department to expand reimbursement to services delivered via these other modalities without a legislative decree. We ask the Department also consider such actions.
Thank you for this opportunity to respond. If you have any questions, please direct them to Mei Kwong at the Center for Connected Health Policy (email@example.com or 916-285-1860). Thank you.
Adventist Health System
California Academy of Physician Assistants
California Dental Hygienists’ Association
California Hospital Association
California Association of Public Hospitals
California Commission on Aging
California Chronic Care Coalition
California Medical Association
California Primary Care Association
California Telehealth Network
California Telehealth Resource Center
Center for Connected Health Policy
The Center for Technology & Aging
Center for Autism & Related Disorders
Children’s Hospice and Palliative Care Coalition
Children’s Specialty Care Coalition
The Children’s Partnership
Clinical Informatics, Inc.
Connecting to Care
Healthcare Interpreter Network
HIMSS, Northern California Chapter
KP Public Affairs
National Multiple Sclerosis Society
Multi State Licensure for California Nurses Task Force
Pacific Center for Special Care at the University of Pacific School of Dentistry
Partnership HealthPlan of California
Planned Parenthood Affiliates of California
Providence St. Joseph Health
Public Health Institute
Stanford Health Care
University of California, San Francisco