Store and Forward

POLICY

“Asynchronous store-and-forward” means the transmission of a patient’s medical information from an originating site to the health care provider at a distant site.  Consultations via asynchronous electronic transmission initiated directly by patients, including through mobile phone applications, are not covered under this policy.

“E-consults” fall under the auspice of store-and-forward.  E-consults are asynchronous health record consultation services that provide an assessment and management service in which the patient’s treating health care practitioner (attending or primary) requests the opinion and/or treatment advice of another health care practitioner (consultant) with specific specialty expertise to assist in the diagnosis and/or management of the patient’s health care needs without patient face-to-face contact with the consultant.  E-consults between health care providers are designed to offer coordinated multidisciplinary case reviews, advisory opinions and recommendations of care.  E-consults are permissible only between health care providers.

“E-visits” are communications between a patient and their provider through an online patient portal.

SOURCE: CA Department of Health Care Services. Medi-Cal Part 2 General Medicine Manual. Telehealth (Jan. 2023). Pg. 1-2. (Accessed Jan. 2025).

CA Medicaid and Medi-Cal managed care plans are required to reimburse health care providers of applicable health care services delivered via video synchronous interaction, synchronous audio-only modality, or asynchronous store and forward, as applicable, at payment amounts that are not less than the amounts the provider would receive if the services were delivered via in-person, face-to-face contact, so long as the services or settings meet the applicable standard of care and meet the requirements of the service code being billed.

A health care provider shall not establish a new patient relationship with a Medi-Cal beneficiary via asynchronous store and forward, telephonic (audio-only) synchronous interaction, remote patient monitoring, or other virtual communication modalities. The department may provide for specific exceptions to this prohibition, which shall be developed in consultation with affected stakeholders and published in departmental guidance. Additional exceptions apply for audio-only in particular as well. See Email, Phone & Fax Section for audio-only exception information.

In-person, face-to-face contact between a health care provider and a patient is not required under the Medi-Cal program for covered health care services and provider types designated by the department, when provided by video synchronous interaction, asynchronous store and forward, as defined in subdivision (a) of Section 2290.5 of the Business and Professions Code, audio-only synchronous interaction, remote patient monitoring, or other permissible virtual communication modalities, when those services and settings meet the applicable standard of care and meet the requirements of the service code being billed.

Applicable health care services appropriately provided through video synchronous interaction, asynchronous store and forward, audio-only synchronous interaction, remote patient monitoring, or other permissible virtual communication modalities are subject to billing, reimbursement, and utilization management policies imposed by the department. Utilization management protocols adopted by the department pursuant to this section shall be consistent with, and no more restrictive than, those authorized for health care service plans pursuant to Section 1374.13 of the Health and Safety Code.

SOURCE: Welfare and Institutions Code 14132.725. (Accessed Jan. 2025).

Brief Virtual Communications and Check-ins

Virtual or telephonic communication includes a brief communication with an established patient not physically present (face-to-face). Medi-Cal providers may be reimbursed using HCPCS codes G2010 for brief virtual communications.

HCPCS code G2010: Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 hours, not originating from a related evaluation and management (E/M) service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment.

SOURCE: CA Department of Health Care Services. Medi-Cal Part 2 General Medicine Manual. Telehealth (Jan. 2025). Pg. 13. (Accessed Jan. 2025).

FQHCs/RHCs 

Asynchronous store and forward means the transmission of a patient’s medical information from an originating site to the billable provider at a distant site.

Medi-Cal benefits or services being provided are clinically appropriate and meet the procedural and billing requirements that would have applied if the applicable services were delivered via a face-to-face encounter.

A patient may be “established” on an asynchronous store and forward service, if all of the conditions of the “New Patient” requirements in this manual section are met.

Only one visit or store and forward service may be billed at the PPS rate when there is a service payment contract with a non-FQHC/RHC, contractor, or another FQHC or RHC. Conversely, the non-FQHC/RHC or contractor may request fee-for-service reimbursement for a visit or store and forward service directly from the appropriate managed care plan or the Medi-Cal Fiscal Intermediary if no service payment contract exists with the FQHC or RHC.

FQHCs and RHCs must use the appropriate telehealth modifier when billing for the covered service.

RHCs and FQHCs cannot use billing codes G2010 and G2017, which are for Fee-For-Service (FFS) providers. Likewise, effective the end of the COVID-19 public health emergency, code G0071 may not be billed to Medi-Cal.

An e-consult, e-visit, or remote patient monitoring is not a reimbursable telehealth service for FQHCs or RHCs.

SOURCE: CA Department of Health Care Services (DHCS). Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHC) Outpatient Services Manual. Mar. 2024. Pg. 15-17. (Accessed Jan. 2025).

Visits shall also include an encounter between an FQHC or RHC patient and a physician, physician assistant, nurse practitioner, certified nurse-midwife, clinical psychologist, licensed clinical social worker, visiting nurse, comprehensive perinatal services program practitioner, dental hygienist, dental hygienist in alternative practice, or marriage and family therapist using an asynchronous store and forward modality, when services delivered through that modality meet the applicable standard of care. A visit described in this clause shall be reimbursed at the applicable FQHC’s or RHC’s per-visit PPS rate to the extent the department determines that the FQHC or RHC has met all billing requirements that would have applied if the applicable services were delivered via a face-to-face encounter.

An FQHC or RHC is not precluded from establishing a new patient relationship through an asynchronous store and forward modality, as defined in subdivision (a) of Section 2290.5 of the Business and Professions Code, if the visit meets all of the following conditions:

• The patient is physically present at the FQHC or RHC, or at an intermittent site of the FQHC or RHC, at the time the service is performed.
• The individual who creates the patient records at the originating site is an employee or contractor of the FQHC or RHC, or other person lawfully authorized by the FQHC or RHC to create a patient record.
• The FQHC or RHC determines that the billing provider is able to meet the applicable standard of care.
• An FQHC patient who receives telehealth services shall otherwise be eligible to receive in-person services from that FQHC pursuant to HRSA requirements.

SOURCE: Welfare and Institutions Code 14132.100. (Accessed Jan. 2025).

Family PACT

Family PACT telehealth policy mirrors the fee-for-service policy.

SOURCE: CA Department of Health Care Services. Family Planning, Access, Care and Treatment Program. Benefits Manual. May 2024, Pg. 7-11. (Accessed Jan. 2025).

Managed Care

To ensure proper payment and record of Covered Services provided via Telehealth, all Providers must use the modifiers defined in the Medi-Cal Provider Manual with the appropriate CPT-4 or HCPCS codes when coding for services delivered through both synchronous interactions and asynchronous store and forward telecommunications. Regarding the rate of reimbursement, unless otherwise agreed to by the MCP and Provider, MCPs must reimburse Network Providers at the same rate, whether a Covered Service is provided in-person or through Telehealth, if the service is the same regardless of the modality of delivery, as determined by the Provider’s description of the service on the claim.

SOURCE: CA Department of Health Care Services (DHCS). All Plan Letter 23-007: Telehealth Services Policy. Apr. 10, 2023, Pg. 5. (Accessed Jan. 2025).

Indian Health Services, Memorandum of Understanding Agreement (IHS-MOA)

A patient may not be “established” on an asynchronous store and forward service with the exception of a homeless patient. Reimbursement is permitted for an established patient by a billable provider at the distant site.

SOURCE: CA Department of Health Care Services (DHCS). Indian Health Services, Memorandum of Agreement (MOA) 638, Clinics Manual. May 2023. Pg. 9. (Accessed Jan. 2025).

Local Education Agency

For purposes of LEA policy, the telehealth definition only includes synchronous, real-time interactions between a patient and a health care provider located at a distant site.

SOURCE: CA Department of Health Care Services (DHCS). Local Education Agency (LEA) Telehealth. Jun. 2023. Pg. 1. (Accessed Jan. 2025).

Dental Services

The Department of Health Care Services has opted to permit the use of teledentistry (includes store-and-forward) as an alternative modality for the provision of select dental services.  See manual for codes and requirements.

DHCS has expanded its teledentistry policy to allow Medi-Cal dental Fee-for-Service (FFS) and Dental Managed Care (DMC) providers the ability to establish new patient relationships through an asynchronous store and forward modality, consistent with Federally Qualified Health Center/Rural health Clinic (FQHC/RHC) providers.

A patient who receives teledentistry services under these provisions shall also have the ability to receive in-person services from the dentist or dental practice or assistance in arranging a referral for in-person services.

A member receiving teledentistry services by store and forward may also request to have real-time communication with the distant dentist at the time of the consultation or within 30 days of the original consultation.

SOURCE: CA Department of Health Care Services (DHCS). Medi-Cal Dental Provider Handbook. 2024. Pg. 4-22 – 4-24. (Accessed Jan. 2025).

ELIGIBLE SERVICES/SPECIALTIES

Modifier GQ must be used for Medi-Cal covered benefits or services, including, but not limited to, teleophthalmology, teledermatology, teledentistry and teleradiology, delivered via asynchronous store and forward telecommunications systems, including e-consults. Only the service(s) rendered from the distant site must be billed with modifier GQ.

The use of modifier GQ does not alter reimbursement for the CPT or HCPCS code billed. For additional information about policy and billing requirements relating to teledentistry, providers may refer to “Teledentistry” in the Medi-Cal Dental Provider Handbook.

For billing purposes, health care providers must ensure that the documentation, typically images, sent via store and forward be specific to the patient’s condition and adequate for meeting the procedural definition and components of the CPT or HCPCS code that is billed. In addition, all services billed via store and forward, including e-consult, are subject to all existing Medi-Cal coverage and reimbursement policies.

E-Consults

A health care provider at the originating site, for example, a treating/referring provider, may bill for an e-consult with the CPT code listed below when the benefits or services delivered meet the procedural definition and components of the CPT code as defined by the AMA as well as any requirements described in this section of the Medi-Cal provider manual.

A health care provider at the distant site, for example, a consultative provider, may bill for an e-consult with the CPT code listed below when the benefits or services delivered meet the procedural definition and components of the CPT code as defined by the AMA as well as any requirements described in this section of the Medi-Cal provider manual.

When billing for e-consults, health care providers at the originating and distant sites must clearly document the following information relating to previous and/or pertinent health care services, maintain this information in the patient’s medical record and make it available to DHCS upon request:

• A health care provider at the originating site (treating/referring provider) must create and maintain the following: A record that the e-consult is the result of patient care that has occurred or will occur and relates to ongoing patient management; and A record of a request for an e-consult by the health care provider at the originating site.
• In order to bill for e-consults, the health care provider at the distant site (consultative provider) must create and maintain the following: A record of the review and analysis of the transmitted medical information with written documentation of date of service and time spent; and A written report of case findings and recommendations with conveyance to the originating site.

The health care provider at the distant site (consultant) may use CPT code 99451 to bill for e-consults in conjunction with modifier GQ. The health care provider at the originating site (treating/referring) may use CPT code 99452 to bill for e-consults in conjunction with modifier GQ. See manual for additional requirements specific to each code.

E-consults are not applicable for FQHCs, RHCs, or IHS-MOA clinics.

See Telehealth Modifier Reference Sheet- Organized by Delivery System​​ ​for more information on modifiers.

SOURCE: CA Department of Health Care Services.  Medi-Cal Part 2 General Medicine Manual. Telehealth (Oct. 2024), Pg. 10-12. (Accessed Jan. 2025).

Managed Care

All Providers, with the exception of Federally Qualified Health Centers (FQHCs), Rural Health Clinics (RHCs), and Tribal Health Providers (THPs), are allowed to be reimbursed for consultations provided via a Telehealth modality. These electronic consultations (e-consults) are permissible using the appropriate CPT-4 code, modifier(s), and Medical Record documentation defined in the Medi-Cal Provider Manual. Members cannot initiate e-consults as they are interprofessional interactions, and therefore only permissible between Providers. Providers are permitted to be reimbursed for brief virtual communications that consist of a brief communication with a Member who is not physically present (face-to-face) at the FFS rate. Virtual communications reimbursement for FQHCs, RHCs, and THPs is no longer allowed consistent with the end of the COVID-19 Public Health Emergency on May 11, 2023.

SOURCE: CA Department of Health Care Services (DHCS). All Plan Letter 23-007: Telehealth Services Policy. Apr. 10, 2023. Pg. 3. (Accessed Jan. 2025).

Indian Health Services, Memorandum of Understanding Agreement (IHS-MOA)/Tribal FQHCs

A patient may not be “established” on an asynchronous store and forward service with the exception of a homeless patient. Reimbursement is permitted for an established patient by a billable provider at the distant site.

SOURCE: CA Department of Health Care Services (DHCS). Indian Health Services, Memorandum of Agreement (MOA) 638, Clinics Manual. May 2023. Pg. 9; CA Department of Health Care Services (DHCS) Tribal FQHC Manual. May 2023, p. 13. (Accessed Jan. 2025).

Vision Care

Teleophthalmology and by store and forward means an asynchronous transmission of medical information to be reviewed at a later time by a physician or optometrist at a distant site, where the physician or optometrist at the distant site reviews the medical information without the patient being present in real-time. If the reviewing optometrist identifies a disease or condition requiring consultation or referral pursuant to Section 3041 of the Business and Professions Code, a referral must be made with an appropriate physician and surgeon or ophthalmologist, as required. Teleophthalmology services by store and forward must be billed with modifier GQ (service rendered by store and forward telecommunications system). Only the portion(s) rendered from the distant site (hub) are billed with modifier GQ. The use of modifier GQ does not alter reimbursement for the CPT or HCPCS code billed.

Asynchronous telecommunications system (store and forward telehealth) in single media format does not include telephone calls, images transmitted via facsimile machine, and text messages without visualization of the patient (electronic mail). Audio clips, video clips, still images and photographs must be specific to the patient’s condition and adequate for rendering or confirming a diagnosis and/or treatment plan.

SOURCE: CA Department of Health Care Services, Vision Care: Professional Services Manual. (Dec. 2022), Pg. 5-6. (Accessed Jan. 2025).

Dental Services

For teledentistry services or benefits delivered via asynchronous store and forward, providers must also meet the requirements in state statute (Welfare and Institutions Code [WIC] Section 14132.725[b]).

A member receiving teledentistry services by store and forward may also request to have real-time communication with the distant dentist at the time of the consultation or within 30 days of the original consultation.

Specific teledentistry codes via store-and-forward (see manual) are reimbursed.

Limited Medi-Cal dental services may be rendered via asynchronous store-and-forward using Current Dental Terminology (CDT) code D9996 (Teledentistry – Asynchronous; Information stored and forwarded to dentist for subsequent review), which identifies the services as teledentistry. CDT code D9996 is not reimbursable; instead, the billing dental provider would be reimbursed based upon the applicable CDT procedure code to be paid according to the Schedule of Maximum Allowance (SMA).

SOURCE: CA Department of Health Care Services (DHCS). Medi-Cal Dental Provider Handbook. 2024. Pg. 4-22 – 4-24. (Accessed Jan. 2025).

Opioid Use Disorder Treatment Services

Outpatient treatment services for opioid use disorder (OUD), which include management, care coordination, psychotherapy and counseling are reimbursable using HCPCS codes G2086, G2087 and G2088. At least one psychotherapy service must be furnished in order to bill for HCPCS codes G2086 thru G2088. Although the descriptions for these codes refer to “office-based treatment,” these services may be delivered via telehealth when they meet Medi-Cal requirements. See Medi-Cal Telehealth Provider Manual.

HCPCS codes G2086 thru G2088 are not reimbursable for treatment in state-licensed Opioid Treatment Programs as defined in Health and Safety Code Section 11875. HCPCS codes G2086 and G2087 each have a frequency limit of once per calendar month, per recipient, any provider and G2088 has a frequency limit of two per calendar month, per recipient, any provider. Only one provider can be reimbursed for HCPCS code G2086, G2087 or G2088 per calendar month.

SOURCE: Department of Health Care Services. Evaluation & Management Manual. Page 45-46. Jan. 2025. (Accessed Jan. 2025).

GEOGRAPHIC LIMITS

No Reference Found

TRANSMISSION FEE

SOURCE: CA Department of Health Care Services. Medi-Cal Part 2 General Medicine Manual. Telehealth. (Jan. 2025), Pg. 13. (Accessed Jan. 2025).

FQHC & RHC/Tribal FQHCs/IHS-MOA

These sites are not eligible for the facility or transmission fee.

SOURCE: CA Department of Health Care Services (DHCS).  Indian Health Services, Memorandum of Agreement (MOA) 638, Clinics Manual. Jan. 2023. Pg. 8 & Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHC) Outpatient Services Manual. Mar. 2024. Pg. 13, Tribal FQHC May 2023, p. 13. (Accessed Jan. 2025).

Vision Care

The facility fee is reimbursable to the originating site when billed with HCPCS code Q3014. Transmission costs incurred from providing telehealth services via audio/video communication is also reimbursable for the original site and the consulting provider when billed with HCPCS code T1014. Expenses involving telehealth equipment and telecommunications and transmission costs by Internet service providers will not be reimbursed by Medi-Cal.

SOURCE: CA Department of Health Care Services, Vision Care: Professional Services Manual. (Oct. 2022), Pg. 5. (Accessed Jan. 2025).

Dental Care

Transmission costs associated with store and forward are not payable.

SOURCE: CA Department of Health Care Services (DHCS). Denti-Cal Manual. 2024. Pg. 4-23. (Accessed Jan. 2025).