Telehealth services in workers’ compensation - Dec. 20 2020

The Colorado Division of Workers’ Compensation (DOWC) has incorporated telehealth services into Rule
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The Colorado Division of Workers’ Compensation (DOWC) has incorporated telehealth services into Rule 18, the Medical Fee Schedule.

“Telehealth” describes health care services provided through real-time interactive audio and video telecommunications systems. This includes information in electronic format using communication technologies. It facilitates the assessment, diagnosis, consultation, treatment, education, care management and/or self-management of an injured worker’s health care while the worker is located at an originating site and the provider is located at a distant site.

Telehealth includes live interactions between two or more parties and “store-and-forward transfers” which collect information such as images or lab reports and send it electronically to another location for evaluation or interpretation. It does not include services provided by facsimile machines, emails or telephones with only audio capability.

All services provided through telehealth or telemedicine shall comply with the applicable requirements found in the Colorado Medical Practice Act, the Colorado Mental Health Practice Act, and the rules and policies adopted by the Colorado Medical Board and the Colorado Board of Psychologist Examiners.

The Office of Civil Rights is relaxing the HIPAA privacy and electronic security standards to accommodate care options to all patients. The originating site is responsible for establishing and verifying the injured worker and provider identity.

Documentation requirements

Telehealth services require additional documentation beyond the treatment services. The added documentation must include all of the following:

  • How the services were rendered (such as secured video, etc.)
  • Where the physician located
  • Where the patient is located
  • Time of the services, even if the billed code is not timed

Telehealth documentation example

“This session took place by secure video call. The clinician provided services from their [home office/office/location, city, state]. The patient/client was located [at their home/location in city, state] OR [at name of physician name/office, address, city, state].”

Coding Guidelines

The CPT codes contained in Appendix P of the AMA CPT Professional Edition and applicable DOWC Z codes maybe billed as telehealth services. In addition, the following CPT codes can be provided by telemedicine: 97110, 97112, 97116, 97129, 97130, 97150, 97530, 97535, 97542, 97750, 97555, 97760, 97761 and 97763. Additional services may be provided by telemedicine with prior authorization.

Pinnacol is temporarily relaxing some restrictions associated with service delivery and billing and implementing emergency provisions to help address acute needs for injured workers including telehealth when appropriate. For physical and occupational therapists, the DOWC has waived the prior authorization requirements for initial and follow-up telehealth-based services. Modifier -95 is appended to the code and the location service code 02 is billed. Payment will be based on the non-facility RVUs, but the $5 transmission fee will not be paid.

When the documentation indicates the patient is located at an authorized originating site (hospital, rural health clinic, etc.) the originating site may bill for code Q3014, the originating site fee. The originating site fee is billed in 15-minute increments.

Authorized originating sites include:

  • A hospital (inpatient or outpatient)
  • A critical access hospital
  • A rural health clinic
  • A federally qualified health center
  • A hospital based renal dialysis center (including satellites)
  • A skilled nursing facility
  • A community mental health center

With appropriate safeguards in place, telehealth services can be an effective way to facilitate treatment when face-to-face interactions are not feasible. Understanding the documentation requirements will allow providers to be reimbursed for these remote services.

Questions? Please contact us at or 303-361-4940.

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