Pennsylvania

Disclaimer

PLEASE NOTE: CCHP is providing the following for informational purposes only. We are not providing legal advice or interpretation of the laws and regulations and policies. CCHP encourages you to check with the appropriate state agency for further information and direction. This information should not be construed as legal counsel. Consult with an attorney if you are seeking a legal opinion.

At A Glance
1 / 4

MEDICAID REIMBURSEMENT

  • Live Video: Yes
  • Store-and-Forward: No
  • Remote Patient Monitoring: No
  • Audio Only: Yes

PRIVATE PAYER LAW

  • Law Exists: No
  • Payment Parity: No

PROFESSIONAL REQUIREMENTS

  • Licensure Compacts: EMS, IMLC, NLC, PSY, PTC
  • Consent Requirements: Yes

STATE RESOURCES

  1. Medicaid Program: Pennsylvania Medical Assistance Program (MA)
  2. Administrator: Pennsylvania Department of Public Welfare
  3. Regional Telehealth Resource Center: Mid-Atlantic Telehealth Resource Center
Disclaimer

PLEASE NOTE: CCHP is providing the following for informational purposes only. We are not providing legal advice or interpretation of the laws and regulations and policies. CCHP encourages you to check with the appropriate state agency for further information and direction. This information should not be construed as legal counsel. Consult with an attorney if you are seeking a legal opinion.

Last updated 09/11/2023

Definitions

No Reference Found

Last updated 09/11/2023

Parity

SERVICE PARITY

No Reference Found


PAYMENT PARITY

No Reference Found

Last updated 09/11/2023

Requirements

Will commercial insurers be required to reimburse for telemedicine services and to  reimburse at the same rate as in person services after October 31, 2022?

Coverage for, and reimbursement of, services delivered via telemedicine will be dependent on each commercial insurer’s coverage and operational policies, as well as the terms of any applicable provider contracts.  This includes payment rates, as there are no insurance laws or regulations requiring payment parity.  The Pennsylvania Insurance Department (PID) surveyed the commercial insurers for updated information following the end of the COVID-19 Public Health Emergency (PHE). While the services covered by insurers have not been reduced, insurers across the board have reinstated cost-sharing for telehealth appointments following the end of the PHE. Reimbursement rates vary dependent upon the insurance company’s provider contracts and member’s plan. Insurers noted that they will continue to review their policies in terms of any state/federal guidance moving forward.

I provide school-based physical health and behavioral health services and continue to provide care via telemedicine. Will I be allowed to continue to provide services using telemedicine after October 31, 2022?

Coverage for, and reimbursement of, services delivered via telemedicine will continue to be dependent on each commercial insurer’s coverage and operational policies, as well as the terms of any applicable provider contracts. Insurers may have policy limitations that prohibit coverage for school-based services.  However, state law currently requires all fully insured health plans to cover certain autism services regardless of whether they are provided in a school setting.

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQs. (Accessed Sept. 2023).

Last updated 09/11/2023

Definitions

Historically, “telemedicine” for purposes of Medicaid payment was the use of two-way, real time interactive telecommunication equipment that included, at a minimum, audio and video equipment, as a mode of delivering healthcare services. However, the term “telehealth” has emerged as the umbrella term that encompasses the full range of services furnished remotely. In response to this shift, the Department will now refer to the remote delivery of services as telehealth.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, p. 2. Aug. 2, 2023.  (Accessed Sept. 2023).

Teledentistry is two-way, real time interactive communication between the patient and dentist. Teledentistry may be provided by any means that allows for two-way, real time interactive audio-video communication, such as through conferencing hosted by a secure mobile application. Audio only technology may be utilized for two procedure codes as described below.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Teledentistry Guidelines and Dental Fee Schedule Updates (May 2, 2022). (Accessed Sept. 2023).

Last updated 09/11/2023

Email, Phone & Fax

The Department will continue to allow providers to utilize audio-only telecommunication when the beneficiary does not have access to video capability or for an urgent medical situation. The use of audio-only telecommunication technology is to be consistent with state and federal requirements, including guidance by CMS with respect to Medicaid payment and to compliance with Health Insurance Portability and Accountability Act (HIPAA).

Services rendered via telehealth, including those delivered using audio-only telecommunication technology, must use technology that is two-way, real-time, and interactive between beneficiary and provider.

If the service was rendered using audio-only technology, providers are to document that the services were rendered using audio-only technology and the reason audio/video technology could not be used.

Audio-only telecommunications technology may be used when the beneficiary does not have video capability or for an urgent medical situation, if consistent with state and federal law.

Providers are to indicate in the beneficiary’s medical record when telehealth services are rendered via audio-only.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 2-4.  (Accessed Sept. 2023).

OMHSAS shall issue a bulletin providing additional detail about the use of audio-only services. Audio-only services can only be provided when clinically appropriate and the individual served does not have access to video capability or for an urgent medical situation. The use of audio-only service delivery must be consistent with Pennsylvania regulations and federal requirements

SOURCE: Mental Health and Substance Abuse Services, Interim Telehealth Guidance, March 30, 2023, (Accessed Sept. 2023).

The Department is opening the PT/Spec/POS combination 31/339 (Psychiatry)/02 to the following procedure codes and modifier combination, as the Department determined it is appropriate for this provider to perform these services. These procedure codes include the modifier FQ (audio only).

SOURCE: PA Department of Human Services, 2023 Evaluation and Management Fee Adjustments and Code Updates , Medical Assistance Bulletin 99-23-06, June 1, 2023 (Accessed Sept. 2023).

Audio-only refers to the delivery of behavioral health services at a distance using real-time, two-way interactive audio only transmission. Audio-only does not include text messaging, electronic mail messaging or facsimile (fax) transmissions. Providers may utilize audio-only when the individual served does not have access to video capability or for an urgent medical situation, provided that the use of audio-only is consistent with Pennsylvania regulations and federal requirements, including guidance by the Centers for Medicare & Medicaid Services with respect to Medicaid payment and the US Department of Health and Human Services Office of Civil Rights enforcement of HIPAA compliance.

Audio-only and text messages may also continue to be utilized for non-service activities, such as scheduling appointments.

SOURCE: PA Dept. of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 7, July 1, 2022.  (Accessed Sept. 2023).

Outpatient Drug and Alcohol Clinic Services
Payment will not be made for the following types of services regardless of where or to whom they are provided:
  • Clinic visits, psychotherapy, diagnostic psychological evaluations, psychiatric evaluations and comprehensive medical evaluations conducted over the telephone, that is, any clinic service conducted over the telephone.

SOURCE:  PA 55 Code 1223.14 (Accessed Sept. 2023).

Payment will not be made for the following types of services regardless of where or to whom they are provided:
  • A covered psychiatric outpatient clinic, MMHT or partial hospitalization outpatient service conducted over the telephone.

SOURCE: PA 55 Code 1153.14. (Accessed Sept. 2023).

School-Based ACCESS Program Provider Handbook Mid-Year Update

The provider services log must indicate whether the service type is Direct: Telemedicine or Direct: In Person when documenting the service and how it was provided. The “Description of Service” section of the provider service paper log should be used to record details about the service provided, including verification consent was obtained prior to the start of any telemedicine session, whether any service disruptions or connectivity issues occurred during the service delivery and whether the service was delivered using telephone-only.

SOURCE:  PA Department of Human Services, School-Based ACCESS Program Provider Handbook Mid-Year Update, May 2, 2022, (Accessed Sept. 2023).

Certified Nurse Midwife

Certain services can be performed via audio-only (FQ modifier).

SOURCE:  PA Department of Human Services, Nurse Mid-Wife, 99-23-06, Jun. 1, 2023, (Accessed Sept. 2023).

Last updated 09/11/2023

Live Video

POLICY

Services rendered via telehealth, including those delivered using audio-only telecommunication technology, must use technology that is two-way, real-time, and interactive between beneficiary and provider.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 3.  (Accessed Sept. 2023).

Behavioral Health

Services delivered in the MA FFS delivery system through telehealth will be paid the same rate as if the services were delivered in-person.

MA providers in the MA FFS delivery system that provide services via telehealth should bill for services with a Place of Service (POS) 02 for telehealth provided in a location other than the home of the individual being served and (POS) 10 for telehealth provided in the home of the individual being served, unless instructed otherwise for specific services. Please consult the MA Fee Schedule for procedure codes that have the POS 02 or 10. For services delivered through audio-only, informational modifier code FQ should be used. Providers in the MA HC program must follow the billing instructions of the BH-MCO.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 8, July 1, 2022, (Accessed Sept 2023).


ELIGIBLE SERVICES/SPECIALTIES

MA services in the FFS delivery system rendered via telehealth will be paid the same rate as if the services were rendered in person. MA managed care organizations (MCO) may, but are not required to, allow for the use of telehealth. MA MCOs may negotiate payment for services rendered via telehealth.  The MA Program will continue to pay for MA covered services rendered to beneficiaries via telehealth when clinically appropriate. Services rendered via telehealth must be provided according to the same standard of care as if delivered in-person.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 3.  (Accessed Sept. 2023).

For FQHCs & RHCs

Telepsychiatry Services – Only applicable to Behavioral Health Managed Care delivery system claims and not fee-for-service delivery. Mental health services are provided through the use of approved electronic communication and information technologies to provide or support clinical psychiatric care at a distance. Qualifying telepsych services utilize real-time, two-way interactive audio-video transmission, and do not include a telephone conversation, electronic mail message, or facsimile transmission between a health care practitioner and a service recipient, or a consultation between two healthcare practitioners, although these activities may support the delivery of telepsych services. Telepsych services require service providers to have a service description approved by the Office of Mental Health and Substance Abuse Services (OMHSAS) and deliverable through the managed care option.

SOURCE: PA PROMISe, 837 Professional/CMS-1500 Claim Form, Provider Handbook, Appendix E – FQHC/RHC. p. 10 (Apr. 22, 2014). (Accessed Sept. 2023).

Limited English Proficiency

All recipients of federal funding, including the MA Program, must offer and make available interpretation services to beneficiaries with limited English proficiency, visual limitations, and/or auditory limitations. Providers who elect to render services through telehealth (telemedicine) must have policies in place to make language assistance services, such as oral interpretation, including sign language interpretation, and written translation, available to beneficiaries being served via telemedicine.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 3-4.   & PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 6, July 1, 2022, (Accessed Sept. 2023).

Some behavioral health services may be appropriate to be provided primarily through telehealth, while other services will require ongoing in-person delivery for a significant portion of or all of the services. Providers and practitioners should carefully consider the clinical appropriateness of telehealth delivery for such services, including, but not limited to: Partial Hospitalization, Intensive Behavioral Health Services (IBHS), Family Based Mental Health, Assertive Community Treatment (ACT), or for beneficiaries in a residential facility or inpatient setting.

Providers in the MA HC program must follow the billing instructions of the BH-MCO.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 5, & 8, July 1, 2022, (Accessed Sept. 2023).

Teledentistry may be used by dentists, FQHCs, and RHCs to provide dental services to MA beneficiaries. The provider must be licensed in Pennsylvania and enrolled in the MA Program.

FQHCs and RHCs are to continue billing procedure code T1015 with the U9 modifier to indicate dental visits/encounters rendered via teledentistry to patients. FQHCs and RHCs should no longer use the GT modifier, as previously directed in Provider Quick Tip # 237, “Teledentistry Guidelines Related to COVID-19 for Dentists, Federally Qualified Health Centers and Rural Health Clinics” (https://www.dhs.pa.gov/providers/Quick­ Tips/Documents/PROMISeQuickTip237.pdf), and must begin using POS 02 as of May 2, 2022.

Teledentistry visits must be provided according to the same standard of care as if delivered in-person.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Teledentistry Guidelines and Dental Fee Schedule Updates (May 2, 2022), p. 2-3. (Accessed Sept. 2023).

Additionally, vaccine counseling only visits may be provided via telemedicine with the use of Place of Service 02. For further information on MA Program guidelines for telemedicine see MA Bulletin 99-21-06, titled, “Guidelines for the Delivery of Physical Health Services via Telemedicine”

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Vaccine Counseling Only Visits for Beneficiaries Under 21 (May 30, 2023). (Accessed Sept. 2023).

I am a licensed Medical Assistance enrolled provider – will I continue to be reimbursed for physical health and behavioral health services delivered via telemedicine after October 31, 2022, when the suspended regulations expire?

The MA program will continue to reimburse both physical health and behavioral services delivered via telemedicine after October 31, 2022

Act 98 of 2022 permanently abrogated the two DHS regulations that prohibited payment specifically for audio-only telehealth service delivery—outpatient psychiatric clinics (which includes Mobile Mental Health Treatment and Partial Hospitalization Outpatient Services) under 55 Pa. Code § 1153.14(1), and Outpatient Drug & Alcohol Clinic Services under 55 Pa. Code § 1223.14(2).

Will there be a change in MA reimbursements for physical health or behavioral health services provided via telemedicine after May 11, 2023, or will I continue to be reimbursed at the same level for services provided regardless of how they are delivered?

DHS will continue to reimburse services delivered via telemedicine at the same rates as in-person delivered services for the MA Fee-for-Service (FFS) Program.

MA MCOs may negotiate payment for services rendered via telemedicine in the MA HealthChoices managed care program. To date, all MCOs are reimbursing for services delivered via telemedicine.  DHS cannot require the MCOs to have payment parity for services delivered via telemedicine without a CMS approved directed payment, as MCOs are allowed to negotiate rates.

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQs. (Accessed Sept. 2023).

School-Based ACCESS Program Provider Handbook Mid-Year Update

Delivery Method: While DHS has historically expressed its intent for MA services to be rendered to MA beneficiaries in person, some services may be delivered using telemedicine. Telemedicine is the use of telecommunications technologies to deliver services when the provider and the student are not in the same place at the same time. As outlined within this section by provider type, services rendered via telemedicine must be provided according to the same standard of care as if delivered in person. MA coverage and payment for services provided via telemedicine is separate and apart from authorization to engage in telemedicine from a licensing standpoint. All providers using telemedicine are advised to remain informed on all federal and state statutes, regulations and guidance regarding telemedicine.

SOURCE:  PA Department of Human Services, School-Based ACCESS Program Provider Handbook Mid-Year Update, May 2, 2022, (Accessed Sept. 2023).


ELIGIBLE PROVIDERS

Does the Department of Human Services allow Medical Assistance enrolled providers to bill for services delivered suing telemedicine?

Yes. The Department of Human Services (DHS) has allowed services to be provided via telemedicine since 2007 and has allowed MA-enrolled providers to bill MA for these services. MA-enrolled providers should consult the Office of Medical Assistance Programs (OMAP) and Office of Mental Health and Substance Abuse Services (OMHSAS) telemedicine bulletins for more information on service delivery and billing (see question 7 below). DHS will continue allowing physical health and behavioral health services to be provided via telemedicine delivery and will continue to reimburse at the same rate as services delivered in person in the fee-for-service program. Managed Care Organizations (MCOs) may, but are not required to, allow for the use of telemedicine. MA MCOs may negotiate payment for services rendered via telemedicine.

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQs. (Accessed Sept. 2023).

Licensed Practitioners

Licensed practitioners may provide behavioral health services through telehealth that are within their scope of practice. Practitioners should exercise sound clinical judgement and should not provide services through telehealth when it is clinically not appropriate to do so. Services delivered using telehealth must comply with all service specific and payment requirements for the service.

Provider Agencies

Provider agencies using behavioral health staff who are unlicensed, including, but not limited to, unlicensed master’s level therapists, mental health targeted case managers, mental health certified peer support specialists, certified recovery specialists, and drug and alcohol counselors (as defined in 28 Pa. Code §704.7(b)), and licensed practitioners may provide services using telehealth. Provider agencies should establish and enforce policies for assessing when it is clinically appropriate to deliver services through telehealth. Services delivered using telehealth must comply with all service specific and payment requirements for the service.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 3, July 1, 2022, (Accessed Sept. 2023).

The Department is opening Provider Type (PT)/Specialty (Spec) combination 08 (Clinic)/110 (Psychiatric Outpatient Clinic) in Place of Service (POS) 02 (Telemedicine), 10 (Telehealth provided in the home of the individual being served) and 49 (Independent Clinic) and PT/Spec combination 08/184 (Outpatient Drug and Alcohol Clinic) in POS 02, 10, 12 (Home) and 57 (Non-Residential Substance Abuse Treatment Facility) for the following outpatient and other office evaluation and management procedure codes as a result of clinical review.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Addition of Behavioral Health Providers to Certain Procedure Codes and other Procedure Code Changes (Aug. 2, 2022). (Accessed Sept. 2023).

Telepsych services delivered in FQHCs and RHCs require providers to have a service description approved by the Office of Mental Health and Substance Abuse Services and the service must be deliverable through the managed care option. Telepsych services are limited to psychologists and psychiatrists.

SOURCE:  PA PROMISe, 837 Professional/CMS-1500 Claim Form, Provider Handbook, Appendix E – FQHC/RHC. p. 10 (Apr. 22, 2014). (Accessed Sept. 2023).

Teledentistry may be used by dentists, FQHCs, and RHCs to provide dental services to MA beneficiaries. The provider must be licensed in Pennsylvania and enrolled in the MA Program.

FQHCs and RHCs are to continue billing procedure code T1015 with the U9 modifier to indicate dental visits/encounters rendered via teledentistry to patients. FQHCs and RHCs should no longer use the GT modifier, as previously directed in Provider Quick Tip # 237, “Teledentistry Guidelines Related to COVID-19 for Dentists, Federally Qualified Health Centers and Rural Health Clinics” (https://www.dhs.pa.gov/providers/Quick­ Tips/Documents/PROMISeQuickTip237.pdf), and must begin using POS 02 as of May 2, 2022.

Teledentistry visits must be provided according to the same standard of care as if delivered in-person.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Teledentistry Guidelines and Dental Fee Schedule Updates (May 2, 2022). (Accessed Sept. 2023).

School-Based ACCESS Program Provider Handbook Mid-Year Update

The provider services log must indicate whether the service type is Direct: Telemedicine or Direct: In Person when documenting the service and how it was provided. The “Description of Service” section of the provider service paper log should be used to record details about the service provided, including verification consent was obtained prior to the start of any telemedicine session, whether any service disruptions or connectivity issues occurred during the service delivery and whether the service was delivered using telephone-only.

SOURCE:  PA Department of Human Services, School-Based ACCESS Program Provider Handbook Mid-Year Update, May 2, 2022, (Accessed Sept. 2023).


ELIGIBLE SITES

The originating site is where the beneficiary is located at the time the MA covered service is rendered to them via telehealth. The originating site can be, but is not limited to, the beneficiary’s home, a provider’s office, clinic, nursing facility, or other medical facility site. When the originating site is a provider’s office, clinic, nursing facility or other medical facility, staff at the originating site should be trained to assist beneficiaries with the use of the telehealth equipment and available to provide in-person clinical intervention, if needed. Providers should obtain the location of the beneficiary at the time each service is rendered via telehealth should there be a need for emergency medical services.

Providers are to use POS 02 when billing for services provided via telehealth technology to beneficiaries located in a location other than their home. Providers are to use POS 10 to identify when services via telehealth technology are provided in the home of the individual being served.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 4-5.  (Accessed Sept. 2023).

The originating site is the setting at which an individual receives behavioral health services using telehealth delivery. When telehealth is being used to deliver services to an individual who is at a clinic, residential treatment setting, or facility setting, the originating site must have staff trained in telehealth equipment and protocols to provide operating support. In addition, the clinic or facility must have staff trained and available to provide clinical intervention in-person, if a need arises.

Services delivered through telehealth may also be provided outside of a clinic, residential treatment setting or facility setting. With the consent of the individual served and when clinically appropriate, licensed practitioners and provider agencies may deliver services through telehealth to individuals in community settings, such as to an individual located in their home. The licensed practitioner or provider agency must have policies in place to address emergency situations, such as a risk of harm to self or others.

Prior to delivering services through telehealth, providers or practitioners should provide information to the individual receiving services that supports the delivery of quality services. At a minimum, information should address the importance of the individual being in a private location, preventing interruptions and distractions such as from children or other family members, visitors in the household and from other communication or bandwidth reducing devices. When services are being provided to a child, youth or young adult, consideration should also be given to how much caregiver involvement will be needed during the appointment.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 4, & 7, July 1, 2022, (Accessed Sept. 2023).

The Department is opening Provider Type (PT)/Specialty (Spec) combination 08 (Clinic)/110 (Psychiatric Outpatient Clinic) in Place of Service (POS) 02 (Telemedicine), 10 (Telehealth provided in the home of the individual being served) and 49 (Independent Clinic) and PT/Spec combination 08/184 (Outpatient Drug and Alcohol Clinic) in POS 02, 10, 12 (Home) and 57 (Non-Residential Substance Abuse Treatment Facility) for the following outpatient and other office evaluation and management procedure codes as a result of clinical review.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Addition of Behavioral Health Providers to Certain Procedure Codes and other Procedure Code Changes (Aug. 2, 2022). (Accessed Sept. 2023).

Additionally, vaccine counseling only visits may be provided via telemedicine with the use of Place of Service 02. For further information on MA Program guidelines for telemedicine see MA Bulletin 99-21-06, titled, “Guidelines for the Delivery of Physical Health Services via Telemedicine”

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Vaccine Counseling Only Visits for Beneficiaries Under 21 (May 30, 2023). (Accessed Sept. 2023).

Teledentistry may be used by dentists, FQHCs, and RHCs to provide dental services to MA beneficiaries. The provider must be licensed in Pennsylvania and enrolled in the MA Program.

FQHCs and RHCs are to continue billing procedure code T1015 with the U9 modifier to indicate dental visits/encounters rendered via teledentistry to patients. FQHCs and RHCs should no longer use the GT modifier, as previously directed in Provider Quick Tip # 237, “Teledentistry Guidelines Related to COVID-19 for Dentists, Federally Qualified Health Centers and Rural Health Clinics” (https://www.dhs.pa.gov/providers/Quick­ Tips/Documents/PROMISeQuickTip237.pdf), and must begin using POS 02 as of May 2, 2022.

Teledentistry visits must be provided according to the same standard of care as if delivered in-person.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Teledentistry Guidelines and Dental Fee Schedule Updates (May 2, 2022). (Accessed Sept. 2023).

POS Code 02 (Telemedicine) and 10 (telehealth at home) is listed as reimbursable for specific CPT/HCPCS codes in several bulletins, including a bulletin for behavioral health providers,

School-Based ACCESS Program Provider Handbook Mid-Year Update

POS 02 is to be used when services are rendered via telemedicine for certain services (see bulletin).

Nursing Services/Personal Care Services: Services delivered through telemedicine are NOT compensable.

SOURCE:  PA Department of Human Services, School-Based ACCESS Program Provider Handbook Mid-Year Update, May 2, 2022, (Accessed Sept. 2023).


GEOGRAPHIC LIMITS

Services may be provided using telehealth to Pennsylvania residents who are temporarily out of the state as long as the individual continues to meet eligibility for the Pennsylvania MA Program, and the provider or licensed practitioner has received authorization to practice in the state or territory where the individual will be temporarily located.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 5.  (Accessed Sept. 2023).

Access to Services Delivered In-Person

In the managed care delivery system, the HealthChoices Primary Contractor must ensure that provider agencies and licensed practitioners who deliver services through telehealth within their service area can arrange for services to be delivered in-person as clinically appropriate or requested by the individual served. HealthChoices Primary Contractors must ensure that each contracted provider agency and licensed practitioner meets one of the two following criteria:

  • The provider agency or licensed practitioner maintains a physical location in Pennsylvania within 60 minutes or 45 miles (whichever is greater) of the area served with appropriate licensure for all services provided through telehealth; or
  • The provider agency or licensed practitioner maintains a physical location in a state bordering Pennsylvania, located within 60 minutes or 45 miles (whichever is greater) of the area served in Pennsylvania, maintains licensure in the state where they are physically located for all services provided through telehealth and is enrolled with the Pennsylvania MA program.

The HealthChoices Primary Contractor may apply for an exception to allow licensed practitioners and/or provider agencies beyond the 60 minute/45 mile restriction to deliver services through telehealth in their service area when supporting additional access to services or in circumstances when the licensed practitioner and/or provider agency is needed to meet the cultural, racial/ethnic, sexual/affectional or linguistic needs of individual(s) served or in instances when the licensed practitioner serves less than 5 individuals. An exception request can be submitted to the OMHSAS Telehealth Resource Account using the form in Attachment B.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, July 1, 2022, (Accessed Sept. 2023).


FACILITY/TRANSMISSION FEE

When the beneficiary accesses services at an enrolled originating site, the provider serving as the originating site may bill for the technology service using the telehealth originating site procedure code Q3014 only. The MA fee for Q3014 is $15.72. MA Providers may not bill procedure code Q3014 if another MA covered service is provided at the originating site. Providers may access the online version of the MA Program Fee Schedule at the Department’s website at: https://www.dhs.pa.gov/providers/Providers/Pages/Health%20Care%20for%20Providers/MAFee-Schedule.aspx.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, July 1, 2022, (Accessed Sept. 2023).

Last updated 09/11/2023

Miscellaneous

Technology Requirements:

Technology used for telehealth, whether fixed or mobile, should be capable of presenting sound and image in real-time and without delay. Telehealth equipment should clearly display the practitioners’ and participants’ faces to facilitate clinical interactions. The telehealth equipment must meet all state and federal requirements for the transmission or security of health information and comply with the Health Insurance Portability and Accountability Act (HIPAA).

Delivery of Services:

The medical record for the individual served must indicate each time a service is provided using telehealth including the receipt of informed consent prior to the start of the session, start time of service and end time of service. Additionally, if the individual served or their legal guardian, as applicable, consents to the recording of a telehealth service, documentation of consent must be included in the medical record.

Provider Policies:

  • Providers using telehealth must maintain written policies for the operation and use of telehealth equipment. Policies must include the provision of periodic staff training to ensure telehealth is provided in accordance with the guidance in this bulletin as well as the provider’s established patient care standards.
  • Providers must maintain a written policy detailing a contingency plan for transmission failure or other technical difficulties that render the behavioral health service undeliverable. Contingency plans should describe how the plan will be communicated to individuals receiving services.
  • Prior to delivering services through telehealth, providers or practitioners should provide information to the individual receiving services that supports the delivery of quality services. At a minimum, information should address the importance of the individual being in a private location, preventing interruptions and distractions such as from children or other family members, visitors in the household and from other communication or bandwidth reducing devices. When services are being provided to a child, youth or young adult, consideration should also be given to how much caregiver involvement will be needed during the appointment.

Determining Appropriateness for Telehealth Delivery of Services

Licensed practitioners and provider agencies delivering services through telehealth must have policies that ensure that services are delivered using telehealth only when it is clinically appropriate to do so and that licensed practitioners are complying with standards of practice set by their licensing board for telehealth where applicable.

Factors to consider include, but are not limited to:

  • The preference of the individual served and/or the preference of parents/guardians
  • Whether there is an established relationship with the service provider and the length of time the individual has been in treatment
  • Level of acuity needed for care
  • Risk of harm to self or others
  • Age of a minor child
  • Ability of the individual served to communicate, either independently or with accommodation such as an interpreter or electronic communication device
  • Any barriers to in-person service delivery for the individual
  • Access to technology of the individual served
  • Whether privacy for the individual served could be maintained if services are delivered using telehealth
  • Whether the service relies on social cueing and fluency

The preference of the individual served and their legal guardian(s), as applicable, should be given high priority when making determinations of the appropriateness of the telehealth delivery. However, no service should be provided through telehealth when, in the best clinical judgement of the licensed practitioner, it is not clinically appropriate. When the use of telehealth is not clinically appropriate, the licensed practitioner or provider agency must offer the services in-person. If the individual disagrees with the clinical determination, the licensed practitioner or provider agency may refer the individual to other in-network providers or the managed care organization.

Guidance specific to delivering children’s services through telehealth is included in Attachment A.

SOURCE:  PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, pgs. 4-5 & 7-8, July 1, 2022, (Accessed Sept. 2023).

Pennsylvania Residents Temporarily Out-of-State

Behavioral Health Services may be provided using telehealth to meet the behavioral healthcare needs of Pennsylvania residents who are temporarily out of the state as long as the delivery of services out-of-state is consistent with the authorization for services and treatment plan, the individual continues to meet eligibility for the Pennsylvania MA Program, and the Pennsylvania provider agency or licensed practitioner has received authorization to practice in the state or territory where the individual will be temporarily located.

SOURCE:  PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, July 1, 2022, (Accessed Sept. 2023).

Technology Requirements

Providers should fully document the services rendered and the telecommunication technology used to render the service in the MA beneficiary’s medical record. If the service was rendered using audio-only technology, providers are to document that the services were rendered using audio-only technology and the reason audio/video technology could not be used.

Technology used for telehealth, whether fixed or mobile, should be capable of presenting sound and image in real-time and without delay. The telehealth equipment should clearly display the rendering practitioner’s and participant’s face to facilitate clinical interactions and must meet all state and federal requirements for the transmission and security of health information, including HIPAA.

Audio-only telecommunications technology may be used when the beneficiary does not have video capability or for an urgent medical situation, if consistent with state and federal law. Providers must assure the privacy of the beneficiary receiving services and comply with HIPAA and all other federal and state laws governing confidentiality, privacy, and consent. Public facing video communication applications should not be used to render services via telehealth.

Telehealth does not include asynchronous or “store and forward” technology such as facsimile machines, electronic mail systems, or remote patient monitoring devices. While asynchronous applications are not considered telemedicine in the MA Program, they may be utilized as part of a MA covered service, such as a laboratory service, x-ray service or physician service. Telehealth also does not include text messages, although text messages and telephone may continue to be utilized for non-service activities, such as scheduling appointments.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, Aug. 2, 2023, p. 3-4, (Accessed Sept. 2023).

Guidelines for Telehealth Service Delivery for Children and Youth

The following guidelines are recommended best practices. When delivering services through telehealth, licensed practitioners and provider agencies should ensure that, regardless of age, each child or youth has sufficient caregiver support to engage effectively in services.

  • When services are being delivered through telehealth to children 3 to 5 years old, each child should have a caregiver participate during the provision of services.
  • When services are being delivered through telehealth to children 6 to 9 years old, a caregiver should observe each child during provision of services.
  • When services are being delivered through telehealth to children ages 10 to 13 years old, any child that may need a caregiver during the provision of services should have a caregiver available.
  • When services are being delivered through telehealth to youth 14 years old to 18 years old, any youth that may need a caregiver during the provision of services should have a caregiver available.
  • All children or youth that participate in services through telehealth delivery should have the ability to communicate, either independently or with accommodation such as an interpreter or electronic communication device.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Bulletin, OMHSAS 22-02, Attachment A Guidelines for Telehealth Service Delivery for Children and Youth. (Accessed Sept. 2023).

Last updated 09/11/2023

Out of State Providers

Out-of-state licensed practitioners who provide treatment through telehealth to individuals in Pennsylvania through the MA program must meet the licensing requirements established by the Pennsylvania Department of State. In order to receive payment for services to beneficiaries in the FFS delivery system, practitioners must be enrolled in the MA Program. Practitioners seeking to provide services to beneficiaries in the managed care delivery system should contact the appropriate Managed Care Organization for its enrollment processes. Practitioners are also advised to consult with their professional liability insurance carrier regarding provision of services in other jurisdictions.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 3, July 1, 2022, (Accessed Sept. 2023).

Out-of-state licensed practitioners who render services via telehealth to individuals in Pennsylvania through the MA Program must meet the licensing requirements established by the Pennsylvania Department of State. In order to receive payment for services to beneficiaries in the FFS delivery system, practitioners must be enrolled in the MA Program.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, p. 5, (Aug. 2, 2023) (Accessed Sept. 2023).

See Miscellaneous section for residence temporarily out-of-state.

Last updated 09/11/2023

Overview

Under bulletins from the Office of Mental Health and Substance Abuse Services and PA Medical Assistance, they now offer live video reimbursement to a wide range of licensed providers, and patient locations, and audio-only in situations when the beneficiary does not have video capability or an urgent medical situation.   PA Medicaid does not consider store-and-forward or remote patient monitoring to fall under the definition of telemedicine.

Last updated 09/11/2023

Remote Patient Monitoring

POLICY

Telehealth, for purposes of MA Program payment, does not include asynchronous or store and forward technology or facsimile machines, electronic mail systems or remote patient monitoring devices. However, these technologies may be utilized as a part of the provision of a MAcovered service.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, p. 2-3, Aug. 2, 2023 (Accessed Sept. 2023).


CONDITIONS

No Reference Found


PROVIDER LIMITATIONS

No Reference Found


OTHER RESTRICTIONS

No Reference Found

Last updated 09/11/2023

Store and Forward

POLICY

Telehealth does not include asynchronous or store and forward technology such as facsimile machines, electronic mail systems, or remote patient monitoring devices. While asynchronous applications are not considered telehealth in the MA Program, they may be utilized as part of a MA covered service, such as a laboratory service, x-ray service or physician service. Telehealth also does not include text messages, although text messages and telephone may continue to be utilized for non-service activities, such as scheduling appointments.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, p. 4, Aug. 2, 2023 (Accessed Sept. 2023).


ELIGIBLE SERVICES/SPECIALTIES

No Reference Found


GEOGRAPHIC LIMITS

No Reference Found


TRANSMISSION FEE

No Reference Found

Last updated 09/11/2023

Cross State Licensing

Pennsylvania issues extraterritorial licenses that allow practice in Pennsylvania to physicians residing or practicing with unrestricted licenses in an adjoining state, near the Pennsylvania boundary, and whose practice extends into Pennsylvania.

Pennsylvania bases the granting of this license on the availability of medical care in the area involved, and whether the adjoining state extends similar privileges to Pennsylvania physicians.

SOURCE: PA Statutes Annotated, Title 63 Sec. 422.34(a) and (c)(2). (Accessed Sept. 2023).

How will the use of telemedicine by out-of-state practitioners be impact?

As was the case prior to the pandemic, practitioners wishing to provide services to individuals in Pennsylvania need to be licensed in Pennsylvania in order to practice in Pennsylvania. This holds true whether the provision of services occurs in person or via an electronic interaction such as a telehealth consultation. Practitioners who are not licensed in Pennsylvania and wish to provide services to individuals in Pennsylvania via telemedicine or otherwise may apply for licensure here:  https://www.pals.pa.gov

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQ.  (Accessed Mar. 2023).

Last updated 09/11/2023

Definitions

Telemedicine is a way to provide health services virtually, such as through video conferencing or over the phone. In Pennsylvania, Medical Assistance (MA) enrolled providers have been permitted to provide certain physical health and behavioral health services virtually since 2007 and 2011, respectively, but the option was not widely used until many providers shifted to deliver services via telemedicine during the COVID-19 pandemic. Similarly, commercial health insurance plans may have had individual policies allowing for reimbursement for services provided via telemedicine but there is no statute in Pennsylvania that explicitly authorizes or prohibits the use or disallowance of telemedicine in Pennsylvania.

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQs. (Accessed Sept. 2023).

Last updated 09/11/2023

Licensure Compacts

Member of the Interstate Medical Licensure Compact.

SOURCE: The IMLC. Interstate Medical Licensure Compact. (Accessed Sept. 2023).

Member of Interjurisdictional Psychology Compact.

SOURCE: PSYPACT, Map, (Accessed Sept. 2023).

Member of Nurses Licensure Compact.

SOURCE:  NCSBN, Nurse Licensure Compact, (Accessed Sept. 2023).

Member of Physical Therapy Compact.

SOURCE:  PT Compact, Compact Map, (Accessed Sept. 2023).

Member of the Emergency Medical Services Compact.

SOURCE: EMS Compact. (Accessed Sept. 2023).

* See Compact websites for implementation and license issuing status and other related requirements.

Last updated 09/11/2023

Miscellaneous

No Reference Found

Last updated 09/11/2023

Online Prescribing

Medical Marijuana

Except as provided in subsection (b), a dispensary shall ensure that a physician or a pharmacist is available, either in person or by synchronous interaction, to verify patient certifications and to consult with patients and caregivers at all times during the hours the facility is open to dispense or to offer to dispense medical marijuana products to patients and caregivers.

If a dispensary is authorized to operate more than one facility under its permit, a physician assistant or a certified registered nurse practitioner may be available, either in person or by synchronous interaction, to verify patient certifications and to consult with patients and caregivers at each of the other locations instead of a physician or pharmacist. The physician, pharmacist, physician assistant or certified registered nurse practitioner may rotate coverage of the facilities, provided that a physician or pharmacist is always available, either in person or by synchronous interaction, at one of the facilities. Furthermore, no less than one dedicated medical professional must be present either, physically or by synchronous interaction, for each distinct dispensary facility location and shall not cover more than one dispensary facility location regardless of whether in-person coverage or synchronous interaction is used.

SOURCE: Rules and Regulations, Bulletin, Title 28, Ch. 1131, 1141, 1161a.25, (Accessed Sept. 2023).

See FAQ Number 13 on federal requirements for substance use disorder treatment and Medication Assisted Treatment.

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQs. (Accessed Sept. 2023).

Last updated 09/11/2023

Professional Board Standards

Does the Department of State allow licensed professionals to practice telemedicine in Pennsylvania?

Regarding licensed healthcare practitioners and the use of telemedicine, there is currently no statute in Pennsylvania that explicitly authorizes its use, nor one that explicitly prohibits it. This was true even before the pandemic. The purpose of the telemedicine waiver issued by the Department of State at the beginning of the COVID-19 disaster declaration was to address significant confusion and make it clear that licensees under the Department’s Bureau of Professional and Occupational Affairs (BPOA) health-licensing boards can provide services within their existing scopes of practice via telemedicine when appropriate, provided it is done according to accepted standards of care.

While providing telemedicine is permissible from a professional licensing standpoint, it is important to note that there may be additional issues to consider − such as the type of insurance coverage, insurance reimbursement policies, medical appropriateness, and the intersection of telemedicine services with existing facility licensing requirements that must be met by hospitals or other licensed health care facilities.

These additional considerations are not within the purview of the Department of State.  Rather, such issues fall within the jurisdiction of other federal and state agencies, such as the United States Department of Health and Human Services (HHS), the Centers for Medicare and Medicaid Services (CMS), the Pennsylvania Department of Human Services (DHS), the Pennsylvania Insurance Department, the Pennsylvania Department of Drug and Alcohol Programs (DDAP), and the Pennsylvania Department of Health (DOH).

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQs. (Accessed Sept. 2023).