Reimbursement and Billing for Telehealth Services, Page 3-4:

Telemedicine

Distant site Providers must include the modifier GT on claims for services delivered via telemedicine. Place of Service (POS), the two-digit code placed on claims used to indicate the setting, should reflect the location in which a telehealth service would have normally been provided, had interactions occurred in person. For example, if the member would have come to a private office to receive the service outside of a telehealth modality, a POS 11 would be applied. Providers should not use POS 02 on telehealth claims, even though this POS is referred to as “telehealth” for other payers. Place of service codes can be found at https://www.cms.gov/Medicare/Coding/place-of-service-codes/ Place _of_Service_Code_Set.

Comments/Feedback: All other Third Party Group Health Plans and Medicare require the place of service for Telehealth to be billed as POS 02. If DMAS requires that this be billed using the POS that the service would have normally been provided this will require a significant amount of additional system configuration and set up for Providers and Plans. This will be compounded with the multiple lines of business the MCO plans have that covered Members are enrolled in. They include DSNP, CCC Plus, MED4 and Third Party Group Health Plans. Please consider the allowance or flexibility to use the POS 02  to ensure continuity for all lines of business and plans. With the expanded services covered under the supplement I am not sure the magnitude of what this would entail is understood.

Please consider and allow the use of other modifiers, as opposed to limiting modifiers to GT and GQ. The proposed change will exclude all other telehealth modifiers that are currently being utilized. Third Party, other Group Health Plans and DNSP plans require the use of a different modifier other than GT and GQ.