Vermont

Last updated 07/02/2024

Consent Requirements

Qualified telemedicine and store and forward providers shall: …

Provide appropriate informed consent, in a language that the beneficiary understands, consistent with 18 VSA § 936l(c)(l) to include:

• Identifying the beneficiary, the provider, and the provider’s credentials,
• The types of services permitted using telemedicine technologies,
• A statement that the provider determines whether the conditions being diagnosed and/or treated are appropriate for a telemedicine encounter,
• Details on security measures taken with the use of telemedicine technologies,
• Disclosure to the beneficiary that information may be lost due to technical failures,
• A statement that the provider will follow all applicable federal and state legal requirements of medical and health information privacy, and
• Circumstances under which consent is not required.

SOURCE: VT Health Care Administrative Rules 13.174.003 (3.101.5), Telehealth, (Accessed Jul. 2024).

A health care provider delivering health care services or dental services through telemedicine shall obtain and document a patient’s oral or written informed consent for the use of telemedicine technology prior to delivering services to the patient.

See law for special informed consent instructions third-party vendors, emergency situations, a psychiatrist’s examination and a patient receiving by store-and-forward means

SOURCE: VT Statutes Annotated, Title 18 Sec. 9361 (Accessed Jul. 2024).

Audio-Only Telephone

A health care provider delivering health care services by audio-only telephone shall obtain and document a patient’s oral or written informed consent for the use of audio-only telephone prior to the appointment or at the start of the appointment but prior to delivering any billable service.

The informed consent for audio-only telephone services shall be provided in accordance with Vermont and national policies and guidelines on the appropriate use of telephone services within the provider’s profession and shall include, in language that patients can easily understand:

• that the patient is entitled to choose to receive services by audio-only telephone, in person, or through telemedicine, to the extent clinically appropriate;

• that receiving services by audio-only telephone does not preclude the patient from receiving services in person or through telemedicine at a later date;

• an explanation of the opportunities and limitations of delivering and receiving health care services using audio-only telephone;

• informing the patient of the presence of any other individual who will be participating in or listening to the patient’s consultation with the provider and obtaining the patient’s permission for the participation or observation;

• whether the services will be billed to the patient’s health insurance plan if delivered by audio-only telephone and what this may mean for the patient’s financial responsibility for co-payments, coinsurance, and deductibles; and

• informing the patient that not all audio-only health care services are covered by all health plans.

For services delivered by audio-only telephone on an ongoing basis, the health care provider shall be required to obtain consent only at the first episode of care.

If the patient provides oral informed consent, the provider shall offer to provide the patient with a written copy of the informed consent.

Notwithstanding any provision of this subsection to the contrary, a health care provider shall not be required to obtain a patient’s informed consent for the use of audio-only telephone services in the case of a medical emergency.

A health care provider may use a single informed consent form to address all telehealth modalities, including telemedicine, store and forward, and audio-only telephone, as long as the form complies with the provisions of section 9361 of this chapter and this section.

SOURCE: 18 Vermont Statute Annotated Ch. 219, Sec. 9362, (Accessed Jul. 2024).

Last updated 07/02/2024

Definitions

“Telemedicine” means the delivery of health care services, including dental services, such as diagnosis, consultation, or treatment through the use of live interactive audio and video over a secure connection that complies with the requirements of the Health Insurance Portability and Accountability Act of 1996, Pub. L. No. 104-191.

SOURCE: VT Statutes Annotated, Title 8 Sec. 4100k(h)(7), (Accessed Jul. 2024).

“Telehealth” means methods for health care service delivery using telecommunications technologies. Telehealth includes telemedicine, store and forward, and telemonitoring.

“Telemedicine” means health care delivery by a provider who is located at a distant site to a beneficiary at an originating site for purposes of evaluation, diagnosis, consultation, or treatment, using telecommunications technology via two-way, real-time, audio and video interactive communication, through a secure connection that complies with HIPAA.

SOURCE:  VT Health Care Administrative Rules 13.174.003 (3.101), Telehealth, (Accessed Jul. 2024).

Telehealth means methods for healthcare service delivery using telecommunications technologies. Telehealth includes telemedicine, store and forward, and telemonitoring.

The term telehealth is also often used more generally to describe electronic information and telecommunications technologies to support long-distance clinical healthcare, as well as patient and professional health-related education, public health and health administration.

Telemedicine means health care delivered by a provider who is located at a distant site to a beneficiary at an originating site for purposes of evaluation, diagnosis, consultation, or treatment using telecommunications technology via two-way, real-time, audio and video interactive communication, through a secure connection that complies with HIPAA.

The term “telemedicine” is sometimes used interchangeably with “telehealth.” Telehealth encompasses the following:

• Real-time, audio-video communication tools that connect providers and patients in different locations. Tools can include interactive videoconferencing or videoconferencing using mobile health (mHealth) applications (apps) that are used on a computer or hand-held mobile device.
• Store-and-forward technologies that collect images and data to be transmitted and interpreted later, which may also involve the use of mHealth apps.
• Remote patient-monitoring tools such as home blood pressure monitors, Bluetooth-enabled digital scales and other devices that can communicate biometric data for review, which may also involve the use of mHealth apps.

SOURCE: Department of Vermont Health Access. Agency of Human Services. Telehealth: Methods for healthcare service delivery using telecommunications technologies. (Accessed Jul. 2024).

Last updated 07/02/2024

Email, Phone & Fax

“Audio-Only” means real-time health care delivery by a provider who is located at a distant site to a beneficiary at an originating site for purposes of evaluation, diagnosis, consultation, or treatment, using audio-only telecommunications technology.

Audio-Only: To be covered, services shall be:

• Clinically appropriate for delivery through audio-only, and
• Medically necessary.

SOURCE: VT Health Care Administrative Rules 13.174.003 (3.101.7), Telehealth, (Accessed Jul. 2024).

Effective 1/1/24, Telehealth coding for place of service and modifier guidance given during the Public Health Emergency (PHE) period no longer applies. Vermont Medicaid updated the following changes to telehealth coding: Place of Service code 10 – Telehealth Provided in Patient’s Home and Place of Service code 02 – Telehealth Provided Other than in Patient’s Home. Current Procedural Terminology (CPT) Code Modifier 93 for Telemedicine services delivered via audio-only telecommunications should be billed for clinically appropriate services delivered via telephone. Modifier 93 replaces the use of modifier V3. A list of allowable audio-only service codes can be found on the DVHA website. VT Medicaid follows Medicare place of service guidelines, CPT, and Healthcare Common Procedure Coding System (HCPCS) modifiers as indicated in the VT Medicaid General Billing and Forms Manual.

SOURCE: Department of VT Health Access, Banner Notice, Feb. 9, 2024, Telehealth Guidance (Accessed Jul. 2024).

Audio-Only Telephone

Subject to the limitations of the license under which the individual is practicing and, for Medicaid patients, to the extent permitted by the Centers for Medicare and Medicaid Services, a health care provider may deliver health care services to a patient using audio-only telephone if the patient elects to receive the services in this manner and it is clinically appropriate to do so. A health care provider shall comply with any training requirements imposed by the provider’s licensing board on the appropriate use of audio-only telephone in health care delivery.

A health care provider delivering health care services using audio-only telephone shall include or document in the patient’s medical record:

• The patient’s informed consent for receiving services using audio-only telephone in accordance with subsection (c) of this section; and
• The reason or reasons that the provider determined that it was clinically appropriate to deliver health care services to the patient by audio-only telephone.

A health care provider shall not require a patient to receive health care services by audio-only telephone if the patient does not wish to receive services in this manner.

A health care provider shall deliver care that is timely and complies with contractual requirements and shall not delay care unnecessarily if a patient elects to receive services through an in-person visit or telemedicine instead of by audio-only telephone.

Neither a health care provider nor a patient shall create or cause to be created a recording of a provider’s telephone consultation with a patient.

Audio-only telephone services shall not be used in the following circumstances:

• For the second certification of an emergency examination determining whether an individual is a person in need of treatment pursuant to section 7508 of this title; or
• For a psychiatrist’s examination to determine whether an individual is in need of inpatient hospitalization pursuant to 13 V.S.A. § 4815(g)(3).

SOURCE: VT Statute 18 VSA Sec. 9362, (Accessed Jul. 2024).

See list of covered audio-only telehealth service codes.

SOURCE:  Department of VT Health Access, VT Medicaid Audio Only Telehealth Services 10.1.23, (Accessed Jul. 2024).

Is audio-only (telephone) a covered service under Vermont Medicaid?

Yes – Vermont Medicaid will provide reimbursement at the same rate for medically necessary, clinically appropriate services delivered by telephone. Reimbursement will be at the same rate as currently established for Medicaid-covered services provided through telemedicine/face-to-face as long as the claim is submitted to Vermont Medicaid with a 93 modifier (to indicate “service delivered via telephone, i.e., audio-only”). The V3 modifier used during the Public Health Emergency is no longer accepted as of January 1, 2024.

SOURCE: Department of Vermont Health Access. Agency of Human Services. Telehealth: Methods for healthcare service delivery using telecommunications technologies. (Accessed Jul. 2024).

Effective immediately, Vermont Medicaid has added Naturopathic Physicians to the list of providers allowed to bill Current Procedural Terminology (CPT) codes 99441, 99442, and 99443. Refer to the Fee Schedule for coverage criteria https://vtmedicaid.com/#/feeSchedule. A list of audio-only covered codes can be found on the Department of Vermont Health Access website: https://dvha.vermont.gov/providers/telehealth.

SOURCE: Department of VT Health Access, Banner Notice, May 31, 2024, Telephone Evaluation and Management Services by Naturopathic Physicians, (Accessed Jul. 2024).

Effective 7/1/2023, Vermont Medicaid added Healthcare Common Procedure Coding System (HCPCS) code H2019 Therapeutic Behavioral Services, per 15 minutes to the list of Audio-Only covered codes. Refer to the Fee Schedule for coverage criteria https://vtmedicaid.com/#/feeSchedule. Current Procedural Terminology (CPT) Code Modifier 93 should be billed for clinically appropriate services delivered via telephone. A list of audio-only covered codes can be found on the Department of Vermont Health Access website: https://dvha.vermont.gov/providers/telehealth.

SOURCE: Department of VT Health Access, Banner Notice, April 5, 2024, H2019 Audio-Only List Addition, (Accessed Jul. 2024).

See the Miscellaneous section of the Professional Regulation category for additional requirements.

Last updated 07/02/2024

Live Video

POLICY

All health insurance plans in this State shall provide coverage for health care services and dental services delivered through telemedicine by a health care provider at a distant site to a patient at an originating site to the same extent that the plan would cover the services if they were provided through in-person consultation.

[Subdivision (a)(2) repealed effective January 1, 2026.]

A health insurance plan shall provide the same reimbursement rate for services billed using equivalent procedure codes and modifiers, subject to the terms of the health insurance plan and provider contract, regardless of whether the service was provided through an in-person visit with the health care provider or through telemedicine.

The provisions of subdivision (A) of this subdivision (2) shall not apply:

• to services provided pursuant to the health insurance plan’s contract with a third-party telemedicine vendor to provide health care or dental services; or
• in the event that a health insurer and health care provider enter into a value-based contract for health care services that include care delivered through telemedicine or by store-and-forward means.

A health insurance plan may charge a deductible, co-payment, or coinsurance for a health care service or dental service provided through telemedicine as long as it does not exceed the deductible, co-payment, or coinsurance applicable to an in-person consultation.

A health insurance plan may limit coverage to health care providers in the plan’s network. A health insurance plan shall not impose limitations on the number of telemedicine consultations a covered person may receive that exceed limitations otherwise placed on in-person covered services.

Nothing in this section shall be construed to prohibit a health insurance plan from providing coverage for only those services that are medically necessary and are clinically appropriate for delivery through telemedicine, subject to the terms and conditions of the covered person’s policy.

SOURCE: VT Statutes Annotated, Title 8 Sec. 4100k (Accessed Jul. 2024).

To be covered, services shall be:

• Clinically appropriate for delivery through telemedicine, and
• Be medically necessary.

SOURCE:  VT Health Care Administrative Rules 13.174.003 (3.101.2), Telehealth, (Accessed Jul. 2024).

Health Care Administrative Rule 3.101 Telehealth can be found on the Agency of Human Services website at: https://humanservices.vermont.gov/rules-policies/health-care-rules. Providers use of telehealth practices are subject to the requirements of administrative rule. Information contained in rule will not be repeated in the provider manuals.

Billing Rules for Telemedicine:

• All providers are required to follow correct coding rules, including application of modifiers, and only bill for services within their scope of practice that can be done via telemedicine.
• All professional claims (CMS-1500 form) with services billed for telemedicine must have POS 02. Modifier GT should not be used on professional services.
• All facility claims (UB-04 form) must include modifier GT on any telemedicine services delivered via interactive audio and/or video.
• Originating facility site providers (patient site) may be reimbursed a facility fee (Q3014)
• Facility fees will not be reimbursed if the provider is employed by the same entity as the originating site
• GT modifier should not be used on Q301.
• DVHA will not reimburse for teleophthalmology or teledermatology by store and forward means.

Revenue code 780, Telemedicine – is reimbursable at the facility rate.

Partial Hospitalization Programs (PHP) and Intensive Outpatient Programs (IOP) Billing Guidance:  Providers billing for PHP/IOP services in an office-based setting may not separately bill for professional services. This applies to PHP/IOP services provided in-person or via telehealth.

SOURCE: VT Agency of Human Services. General Billing and Forms Manual. Sec. 5.3.52 & 4.14 (Jun. 7, 2024). (Accessed Jul. 2024).

FAQ – Is telemedicine a covered service under Vermont Medicaid?

Yes – this type of service is reimbursable through Vermont Medicaid as long as it is clinically appropriate and within the provider’s licensed scope of practice. This includes the provision of mental health and substance use disorder treatment. Telehealth services should include the appropriate Place of Service codes: Place of Service Code 10 for Telehealth Provided in Patient’s Home or Place of Service Code 02 Telehealth Provided Other Than in Patient’s Home.

SOURCE: Department of Vermont Health Access. Agency of Human Services. Telehealth: Methods for healthcare service delivery using telecommunications technologies. (Accessed Jul. 2024).

Effective 1/1/24, Telehealth coding for place of service and modifier guidance given during the Public Health Emergency (PHE) period no longer applies. Vermont Medicaid updated the following changes to telehealth coding: Place of Service code 10 – Telehealth Provided in Patient’s Home and Place of Service code 02 – Telehealth Provided Other than in Patient’s Home. Current Procedural Terminology (CPT) Code Modifier 93 for Telemedicine services delivered via audio-only telecommunications should be billed for clinically appropriate services delivered via telephone. Modifier 93 replaces the use of modifier V3. A list of allowable audio-only service codes can be found on the DVHA website. VT Medicaid follows Medicare place of service guidelines, CPT, and Healthcare Common Procedure Coding System (HCPCS) modifiers as indicated in the VT Medicaid General Billing and Forms Manual.

SOURCE: Department of VT Health Access, Banner Notice, Feb. 9, 2024, Telehealth Guidance (Accessed Jul. 2024).

ELIGIBLE SERVICES/SPECIALTIES

Services delivered shall:

• Include any service that a provider would typically provide to a beneficiary in a face-to-face setting, and
• Adhere to the same program restrictions, limitations, and coverage that exist for the service when not provided through telemedicine.

Services provided through telehealth are subject to the same prior authorization requirements that exist for the service when not provided through telehealth.

Non-Covered Services

• Services and procedures that are not covered in a face-to-face setting under Vermont Medicaid are not covered under telemedicine or audio-only.
• Services delivered via facsimile, text communication, or electronic mail messages are not considered telehealth and are not covered.

SOURCE:  VT Health Care Administrative Rules 13.174.003 (3.101.2), Telehealth, (Accessed Jul. 2023).

All providers are required to follow correct coding rules, including application of modifiers, and only bill for services within their scope of practice that can be done via telemedicine.

All professional claims (CMS-1500 form) with services billed for telemedicine must have POS 02. Modifier GT should not be used on professional services.

All facility claims (UB-04 form) must include modifier GT on any telemedicine services delivered via interactive audio and/or video.

SOURCE: VT Agency of Human Services. General Billing and Forms Manual. Sec. 5.3.52, p. 88, (Jun. 6, 2024). (Accessed Jul. 2024).

Substance Use Disorder

In order to facilitate the use of telemedicine in treating substance use disorder, when the originating site is a health care facility, health insurers and the Department of Vermont Health Access shall ensure that the health care provider at the distant site and the health care facility at the originating site are both reimbursed for the services rendered, unless the health care providers at both the distant and originating sites are employed by the same entity.

SOURCE: VT Statutes Annotated, Title 8 Sec. 4100k(h), (Accessed Jul. 2023).

Re/Habilitative Therapy

Telehealth services are a covered benefit. Best practice allows for the type of physical examination, tests, and measures which result in establishment of the diagnosis, management plan, and outcome measures. It includes a plan to allow for in-person visits if required, and the ability to monitor patient safety. There may be circumstances where an evaluation is done via telehealth when necessary to prevent delays in essential care. If the testing required to complete a thorough evaluation requires physical contact with the patient, telehealth-only service is not indicated. If the management plan requires the use of physical agents such as ultrasound, electrical stimulation, or light, or manual therapies such as joint mobilization, telehealth-only services are not indicated.

SOURCE: VT Agency of Human Services, PT/OT/SLP Supplement, Sec. 2, (Jan. 12, 2024), (Accessed Jul. 2024).

ELIGIBLE PROVIDERS

“Distant site” means the location of the health care provider delivering services through telemedicine at the time the services are provided.

SOURCE: VT Statutes Annotated, Title 8 Sec. 4100k.(Accessed Jul. 2024).

“Distant site” means the site where the provider is located, and the beneficiary is not located, when telemedicine, audio-only, or store and forward services are provided.

SOURCE:  VT Health Care Administrative Rules 13.174.003 (3.101.1(f)), Telehealth, (Accessed Jul. 2024).

Telehealth services must be provided by a provider who is working within the scope of his or her practice and enrolled in Vermont Medicaid.

Qualified telemedicine and store and forward providers shall:

• Meet or exceed applicable federal and state legal requirements of medical and health information privacy, including compliance with HIPAA.
• Provide appropriate informed consent, in a language that the beneficiary understands, consistent with 18 VSA § 936l(c)(l) (see code for details)
• Take appropriate steps to establish the provider-patient relationship and conduct all appropriate evaluations and history of the beneficiary consistent with traditional standards of care.
• Maintain medical records for all beneficiaries receiving health care services through telemedicine that are consistent with established laws and regulations governing patient health care records.
• Establish an emergency protocol when care indicates that acute or emergency treatment is necessary for the safety of the beneficiary.
• Address needs for continuity of care for beneficiaries (e.g., informing beneficiary or designee how to contact provider or designee and/or providing beneficiary or identified providers timely access to medical records).
• If prescriptions are contemplated, follow traditional standards of care to ensure beneficiary safety in the absence of a traditional physical examination.

SOURCE:  VT Health Care Administrative Rules 13.174.003 (3.101.3), Telehealth, (Accessed Jul. 2024).

Dentists

Vermont Medicaid is encouraging Medicaid-participating providers, including dentists, to utilize telemedicine for delivery of medically necessary and clinically appropriate services to Medicaid members when possible. For more information, see the DVHA website at: https://dvha.vermont.gov/sites/dvha/files/documents/News/DVHA%20Telemedicine%20%26%20Emergency%20Telephonic%20Coverage_Dental%20Providers%2004.10.2020.pdf

SOURCE: Department of Vermont Health Access, Dental Supplement, pg. 13, (Apr. 26, 2024), (Accessed Jul. 2024).

Substance Use Disorder

In order to facilitate the use of telemedicine in treating substance use disorder, when the originating site is a health care facility, health insurers and the Department of Vermont Health Access shall ensure that the health care provider at the distant site and the health care facility at the originating site are both reimbursed for the services rendered, unless the health care providers at both the distant and originating sites are employed by the same entity.

SOURCE: VT Statutes Annotated, Title 8 Sec. 4100k(h), (Accessed Jul. 2024).

ELIGIBLE SITES

Effective 1/1/24, Telehealth coding for place of service and modifier guidance given during the Public Health Emergency (PHE) period no longer applies. Vermont Medicaid updated the following changes to telehealth coding: Place of Service code 10 – Telehealth Provided in Patient’s Home and Place of Service code 02 – Telehealth Provided Other than in Patient’s Home. Current Procedural Terminology (CPT) Code Modifier 93 for Telemedicine services delivered via audio-only telecommunications should be billed for clinically appropriate services delivered via telephone. Modifier 93 replaces the use of modifier V3. A list of allowable audio-only service codes can be found on the DVHA website. VT Medicaid follows Medicare place of service guidelines, CPT, and Healthcare Common Procedure Coding System (HCPCS) modifiers as indicated in the VT Medicaid General Billing and Forms Manual.

SOURCE: Department of VT Health Access, Banner Notice, Feb. 9, 2024, Telehealth Guidance (Accessed Jul. 2024).

Telehealth services are reimbursed at the same rate as in person visits. A system error was discovered for telehealth services billed with place of service 10. POS 10 is defined as – patient is located in their home (which is a location other than a hospital or other facility). The system has been corrected and claims will be adjusted and reprocessed by Gainwell, retroactive to 1/1/2023.

SOURCE: Department of VT Health Access, Banner Notice, Dec. 15, 2023, Place of Service 10 (Accessed Jul. 2024).

“Originating site” means the location of the patient, whether or not accompanied by a health care provider, at the time services are provided by a health care provider through telemedicine, including a health care provider’s office, a hospital, or a health care facility, or the patient’s home or another nonmedical environment such as a school-based health center, a university-based health center, or the patient’s workplace.

SOURCE: VT Statutes Annotated, Title 8 Sec. 4100k (Accessed Jul. 2024).

“Originating site” means the site where the beneficiary is located, whether or not accompanied by a health care provider, when telemedicine, or audio-only services are provided. The originating site may include the beneficiary’s home or another nonmedical setting (e.g., school, workplace), a health care provider’s office, a facility, or a hospital.

SOURCE:  VT Health Care Administrative Rules 13.174.003 (3.101.1), Telehealth, (Accessed Jul. 2024).

Substance Use Disorder

In order to facilitate the use of telemedicine in treating substance use disorder, when the originating site is a health care facility, health insurers and the Department of Vermont Health Access shall ensure that the health care provider at the distant site and the health care facility at the originating site are both reimbursed for the services rendered, unless the health care providers at both the distant and originating sites are employed by the same entity.

SOURCE: VT Statutes Annotated, Title 8 Sec. 4100k(h), (Accessed Jul. 2024).

GEOGRAPHIC LIMITS

No Reference Found

FACILITY/TRANSMISSION FEE

Originating facility site providers (patient site) may be reimbursed a facility fee (Q3014).

Facility fees will not be reimbursed if the provider is employed by the same entity as the originating site.

GT modifier should not be used on Q3014.

SOURCE: VT Agency of Human Services. General Billing and Forms Manual. Sec. 5.3.52, p. 88, (Jun 7, 2024). (Accessed Jul. 2024).

Substance Use Disorder

In order to facilitate the use of telemedicine in treating substance use disorder, when the originating site is a health care facility, health insurers and the Department of Vermont Health Access shall ensure that the health care provider at the distant site and the health care facility at the originating site are both reimbursed for the services rendered, unless the health care providers at both the distant and originating sites are employed by the same entity.

SOURCE: VT Statutes Annotated, Title 8 Sec. 4100k(h), (Accessed Jul. 2023).

Last updated 07/02/2024

Miscellaneous

Qualified telemedicine and store and forward providers shall:

• Meet or exceed applicable federal and state legal requirements of medical and health information privacy, including compliance with HIPAA.
• Provide appropriate informed consent, in a language that the beneficiary understands, consistent with 18 VSA § 936l(c)(l) (see code for details)
• Take appropriate steps to establish the provider-patient relationship and conduct all appropriate evaluations and history of the beneficiary consistent with traditional standards of care.
• Maintain medical records for all beneficiaries receiving health care services through telemedicine that are consistent with established laws and regulations governing patient health care records.
• Establish an emergency protocol when care indicates that acute or emergency treatment is necessary for the safety of the beneficiary.
• Address needs for continuity of care for beneficiaries (e.g., informing beneficiary or designee how to contact provider or designee and/or providing beneficiary or identified providers timely access to medical records).
• If prescriptions are contemplated, follow traditional standards of care to ensure beneficiary safety in the absence of a traditional physical examination.

SOURCE:  VT Health Care Administrative Rules 13.174.003 (3.101.3), Telehealth, (Accessed Jul. 2024).

Last updated 07/02/2024

Out of State Providers

If you hold an active out-of-state license which is in good standing in a healthcare profession, you may practice in Vermont under certain circumstances. Visit the Office of Professional Regulation (OPR) for Updates to Telehealth Registrations and Licensing.

SOURCE: Department of Vermont Health Access. Agency of Human Services. Telehealth: Methods for healthcare service delivery using telecommunications technologies. (Accessed Jul. 2024).

Last updated 07/02/2024

Overview

Vermont Medicaid reimburses for live video under certain circumstances. Store-and-forward is covered when it is clinically appropriate and medically necessary. DVHA will not reimburse for teleophthalmology or teledermatology by store-and-forward means.  Home health monitoring is considered a Medicaid benefit and is available under certain conditions.  Additionally, audio-only telephone is also required to be reimbursed under certain circumstances.  The Medicaid program has updated their regulations to include reimbursement of audio-only services when clinically appropriate and medically necessary.

Last updated 07/02/2024

Remote Patient Monitoring

POLICY

See Health Care Administrative Rule 3.101 on Telehealth for requirements of telemonitoring.

Home Telemonitoring is a health service that allows and requires scheduled remote monitoring of data related to an individual’s health, and transmission of the data from the individual’s home to a licensed home health agency. Scheduled periodic reporting of the individual’s data to a licensed physician is required, even when there have been no readings outside the parameters established in the physician’s orders. In the event of a measurement outside of the established individual’s parameters, the provider shall use the health care professionals noted above to be responsible for reporting the data to a physician.

SOURCE: VT Agency of Human Services. Home Health Agency, Assistive Community Care and Enhanced Residential Care Supplement.  Sec. 1.3.11 Telemonitoring, p. 7 (May 30, 2024), (Accessed Jul. 2024).

“Remote Patient Monitoring” means a health service that enables remote monitoring of a beneficiary’s physiological health-related data by a home health agency done outside of a conventional clinical setting and in conjunction with a plan of care ordered by a physician, nurse practitioner, clinical nurse specialist, or physician assistant.

To be covered, services shall be:

• Clinically appropriate for delivery through telemonitoring, and
• Medically necessary, and
• Limited to a Congestive Heart Failure, Hypertension, or Diabetes diagnosis.

SOURCE: VT Health Care Administrative Rule 3.101  (Accessed Jul. 2024).

VT Medicaid is required to cover home telemonitoring services performed by home health agencies or other qualified providers for beneficiaries who have serious or chronic medical conditions that can result in frequent or recurrent hospitalizations and emergency room admissions.

“Home telemonitoring service” means a health service that requires scheduled remote monitoring of data related to a patient’s health, in conjunction with a home health plan of care, and access to the data by a home health agency or other qualified provider as defined by the Agency of Human Services.

SOURCE: VT Statutes Annotated Title 33 Sec. 1901g. (Accessed Jul. 2024).

CONDITIONS

The Agency shall provide coverage for home telemonitoring for one or more conditions or risk factors for which it determines, using reliable data, that home telemonitoring services are appropriate and that coverage will be budget-neutral. The Agency may expand coverage to include additional conditions or risk factors identified using evidence-based best practices if the expanded coverage will remain budget-neutral or as funds become available.

SOURCE: VT Statutes Annotated Title 33 Sec. 1901g(a). (Accessed Jul. 2024).

To be covered, services shall be:

• Clinically appropriate for delivery through telemonitoring,
• Medically necessary, and
• Be limited to a Congestive Heart Failure, hypertension or diabetes diagnosis.

For telemonitoring services, beneficiaries shall:

• Have Medicaid as their primary insurance or Medicaid and dually enrolled in Medicare with a non-homebound status,
• Have a Congestive Heart Failure diagnosis,
• Be clinically eligible for home health services, and
• Have a physician’s plan of care with an order for home telemonitoring services.

SOURCE:  VT Health Care Administrative Rules 13.174.003  (3.101.2) & (3.101.4), Telehealth, (Accessed Jul. 2024).

PROVIDER LIMITATIONS

The Agency of Human Services shall provide Medicaid coverage for home telemonitoring services performed by home health agencies or other qualified providers as defined by the Agency of Human Services for Medicaid beneficiaries who have serious or chronic medical conditions that can result in frequent or recurrent hospitalizations and emergency room admissions.

A home health agency or other qualified provider shall ensure that clinical information gathered by the home health agency or other qualified provider while providing home telemonitoring services is shared with the patient’s treating health care professionals. The Agency of Human Services may impose other reasonable requirements on the use of home telemonitoring services.

SOURCE: VT Statutes Annotated Title 33 Sec. 1901g. (Accessed Jul. 2024).

Telehealth services must be provided by a provider who is working within the scope of his or her practice and enrolled in Vermont Medicaid.

Qualified telemonitoring providers shall:

• Use the following licensed health care professionals to review data:
  • Registered nurse (RN)
  • Nurse Practitioner (NP)
  • Clinical nurse specialist (CNS)
  • Licensed practical nurse (LPN) under the supervision of a RN or physician assistant (PA), and
• Follow data parameters established by a plan of care, and
• Meet or exceed applicable federal and state legal requirements of medical and health information privacy, including compliance with HIPAA.

SOURCE:  VT Health Care Administrative Rules 13.174.003 (3.101.5), Telehealth, (Accessed Jul. 2024).

When Telemonitoring services are provided to clinically eligible Vermont Medicaid patients, qualified providers may bill CPT code 99091 for the collection and interpretation of physiologic data (e.g., ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified health care professional, qualified by education, training, licensure/regulation (when applicable) requiring a minimum of 30 minutes of time, each 30 days. Additionally, providers should use 99453: Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment and 99454: Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days, with revenue code 0780.

SOURCE: VT Agency of Human Services. Home Health Agency, Assistive Community Care and Enhanced Residential Care Supplement.  Sec. 1.3.11 Telemonitoring, p. 7 (May 30, 2024). (Accessed Jul. 2024).

OTHER RESTRICTIONS

No Reference Found

Last updated 07/02/2024

Store and Forward

POLICY

“Store and forward” means an asynchronous transmission of a beneficiary’s medical information from a health care professional to a provider at a distant site, through a secure connection that complies with HIPAA, without the beneficiary present in real time.

Qualified telemedicine and store and forward providers shall:

• Meet or exceed applicable federal and state legal requirements of medical and health information privacy, including compliance with HIPAA.
• Provide appropriate informed consent, in a language that the beneficiary understands, consistent with 18 VSA § 936l(c)(l) (see code for details)
• Take appropriate steps to establish the provider-patient relationship and conduct all appropriate evaluations and history of the beneficiary consistent with traditional standards of care.
• Maintain medical records for all beneficiaries receiving health care services through telemedicine that are consistent with established laws and regulations governing patient health care records.
• Establish an emergency protocol when care indicates that acute or emergency treatment is necessary for the safety of the beneficiary.
• Address needs for continuity of care for beneficiaries (e.g., informing beneficiary or designee how to contact provider or designee and/or providing beneficiary or identified providers timely access to medical records).
• If prescriptions are contemplated, follow traditional standards of care to ensure beneficiary safety in the absence of a traditional physical examination.

Services provided through telehealth are subject to the same prior authorization requirements that exist for the service when not provided through telehealth.

SOURCE:  VT Health Care Administrative Rules 13.174.003 (3.101.1) & (3.101.5-6), Telehealth, (Accessed Jul. 2024).

“Store and forward” means an asynchronous transmission of medical information, such as one or more video clips, audio clips, still images, x-rays, magnetic resonance imaging scans, electrocardiograms, electroencephalograms, or laboratory results, sent over a secure connection that complies with the requirements of the Health Insurance Portability and Accountability Act of 1996, Pub. L. No. 104-191 to be reviewed at a later date by a health care provider at a distant site who is trained in the relevant specialty. In store and forward, the health care provider at the distant site reviews the medical information without the patient present in real time and communicates a care plan or treatment recommendation back to the patient or referring provider, or both.

A health insurance plan (including Medicaid) shall reimburse for health care services and dental services delivered by store-and-forward means.

A health insurance plan shall not impose more than one cost-sharing requirement on a patient for receipt of health care services or dental services delivered by store-and-forward means. If the services would require cost sharing under the terms of the patient’s health insurance plan, the plan may impose the cost sharing requirement on the services of the originating site health care provider or of the distant site health care provider, but not both.

A health insurer shall not construe a patient’s receipt of services delivered through telemedicine or by store-and-forward means as limiting in any way the patient’s ability to receive additional covered in-person services from the same or a different health care provider for diagnosis or treatment of the same condition.

SOURCE: VT Statutes Annotated, Title 8 Sec. 4100k. (Accessed Jul. 2024).

ELIGIBLE SERVICES/SPECIALTIES

DVHA will not reimburse for teleophthalmology or teledermatology by store-and-forward means.

SOURCE: VT Agency of Human Services. General Billing and Forms Manual. Sec. 5.3.52, p. 88, (Jun. 7, 2024). (Accessed Jul. 2024).

To be covered, services shall:

• Be clinically appropriate for delivery through store and forward
• Be medically necessary

SOURCE:  VT Health Care Administrative Rules 13.174.003 (3.101.2), Telehealth, (Accessed Jul. 2024).

GEOGRAPHIC LIMITS

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TRANSMISSION FEE

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