Telehealth Payment Expands for Wisconsin Medicaid Patients

Wisconsin Medicaid has announced increased coverage of telehealth services in a manner similar to the recent Medicare flexibility in an effort to increase the options for Wisconsin providers to safely and effectively treat patients in the midst of the COVID-19 outbreak. Wisconsin Medicaid had previously taken measures toward this same objective, e.g., waiving patient copays until June 30, 2020; lifting restrictions on early refills of prescription drugs; and relaxing requirements for administering COVID-19 testing.

Wisconsin Medicaid has changed the regulatory structure for telehealth in two significant ways:

1. Telehealth will be reimbursed regardless of the patient's location, i.e., at all originating sites, including the patient's home. However, note that the policy on reimbursement for originating site facility fees has not changed at this time. In other words, only hospitals, offices/clinics, and skilled nursing facilities may bill the originating site facility fee.

2. Additional services are now reimbursable by telehealth, as specified in the announcement, and Wisconsin Medicaid is continuing to evaluate expanding the scope of telehealth coverage. For example:

• New codes have been established allowing reimbursement for professional fees associated with counseling and/or coordination of care with other physicians, other qualified health care professionals, or agencies to inpatients—with certain caveats
• New codes have also been established allowing reimbursement for professional fees associated with e-Visits with an established patient by qualified non-physician health care professionals for online digital evaluation and management services

Quarles & Brady's Health Law Team is continuously monitoring the ever-changing landscape of the COVID-19 pandemic. For more information please contact your Quarles & Brady attorney or:

• Sarah E. Coyne: (608) 283-2435 / sarah.coyne@quarles.com
• Jon R. Kammerzelt: (608) 283-2438 / jon.kammerzelt@quarles.com
• Rachel L. Dykema: (608) 283-2628 / rachel.dykema@quarles.com