Fairfax- Falls Church Community Board Services agrees and supports all the comments to date below:

1. Member Choice and Education, Page 6:

If a Provider, whether at the originating site or distant site, maintains a consent agreement that specifically mentions use of telehealth as an acceptable modality for delivery of services including the information noted above, this shall meet DMAS’s required documentation of patient consent.

• Requesting clarification on Member Choice and Education, Page 6:

Please provide clarity and additional information around when an in-person visit is deemed clinically appropriate. Clarification regarding when telehealth is deemed not clinically appropriate in addition is needed.

2. 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.

Store-and-Forward

Distant site Providers must include the modifier GQ. Place of Service (POS), the two-digit code placed on claims used to indicate the setting, should reflect the location where the distant site provider is located at the time that the service is rendered.

Originating Site Fee

Telemedicine In the event it is medically necessary for a Provider to be present at the originating site at the time a synchronous telehealth service is delivered, said Provider may bill an originating site fee (via procedure code Q3014) when both of the following conditions are met:

· The Medicaid member is located at a provider office or other location where services can be received (this does not include the member’s residence); and                                                                     

· The Provider (or the Provider’s designee), is affiliated with the provider office or other location where the Medicaid member is located and attends the encounter with the member. The Provider or designee may be present to assist with initiation of the visit but the presence of the Provider or designee in the actual visit shall be determined by a balance of clinical need and member preference or desire for confidentiality.

• Comments/feedback: Please consider and allow the use of other modifiers for services provided via telemedicine and distance site providers, as opposed to limiting modifiers to GT and GQ. The proposed change will exclude all other telehealth modifiers that are currently being utilized.

• Requesting clarification-Reimbursement and Billing for Telehealth Services, Page 3-4: Additional clarity and distinction around Telemedicine Distant site Providers, Store-and-forward Distant site providers, and Originating site is needed.