Provider Alert! UPDATE ALERT #3 –Telehealth Services – PT/OT/ST; FQHC/RHC Providers and COVID-19

Provider Alert! UPDATE ALERT #3 –Telehealth Services – PT/OT/ST; FQHC/RHC Providers and COVID-19

Attention: All Providers
Effective Date: March 31, 2020

Providers should monitor the Texas Children’s Health Plan Provider Portal regularly for alerts and updates associated to the COVID-19 event.  TCHP reserves the right to update and/or change this information without prior notice due to the evolving nature of the COVID-19 event.

Call to action: Texas Children’s Health Plan (TCHP) supports the delivery of telehealth (non-physician-delivered) distant site services to its members, and we have implemented special waiver provisions for its use during this disaster declaration.

  • Telehealth for Physical, Occupational, and Speech Therapies:

The Health and Human Services Commission (HHSC) has given certain latitude to Medicaid Managed Care Organizations (MCOs) related to the flexibility they have to allow for remote delivery of medically necessary and appropriate covered services. These are stated in the HHSC notice to MCOs titled “Implementation of S.B. 670 to Impact Medicaid MCOs” (originally released Aug. 22, 2019, and re-released March 9, 2020).

In accordance with this guidance, TCHP extends its telehealth services policy at this time to Occupational, Speech and Physical Therapy providers under certain conditions defined below. Providers may provide covered, medically necessary services in a synchronous audio-video format so long as the telehealth services are provided within the scope, practice and limitations of the practitioner’s license.  Services must be provided in accordance with the Texas Medicaid Program benefit rules as stated in the Texas Medicaid Provider Procedures Manual (TMPPM).  TCHP will update providers as to how long this waiver will be in place in future communications.

Physical, Occupational & Speech Therapy services provided via Telehealth may be done under the following conditions due to the COVID-19 event:

  • Providers are to clearly document in the Member’s medical record the format of the interaction and all appropriate record content of the visit.
  • The provider must also specify in their visit note the appropriateness of remote delivery for the member.
  • Telehealth may be provided via synchronous audio-visual format only.
  • Audio-only visits are not permitted for speech, occupational and physical therapy services.
  • For members under 13 years of age or with a diagnosis of intellectual and developmental disabilities, the entire Telehealth visit must be attended, supervised and supported by an approved caregiver, a parent, guardian or Legal Authorized Representative (LAR).
  • Initial evaluation and re-evaluations must be done face-to-face (F2F) with an appropriate practitioner.
  • Telehealth is applicable to existing, authorized service plans or extended care plans only. Providers with existing authorizations do not need an additional authorization to provide the eligible service via telehealth unless as stated otherwise in this Alert.
  • Provider Reimbursement for Telehealth services

TCHP will reimburse providers for appropriately billed Telehealth services (see the Texas Medicaid Provider Procedures Manual (TMPPM)) at an equivalent rate of a face-to-face visit.

  • Telehealth provided by Federally Qualified Health Centers (FQHC) & Rural Health Care Centers (RHC)

TCHP will reimburse FQHCs and RHCs as telehealth providers effective immediately. FQHCs and RHCs should bill for telehealth services using the encounter and informational procedure codes outlined in the Texas Medicaid Provider Procedures Manual, Clinic and Other Outpatient Facility Services Handbook, (FQHC – Section 4.1.2 and RHC – Section 7.2). FQHCs and RHCs may continue to bill for telehealth services rendered by affiliates, although an affiliate agreement is not required for an FQHC or RHC to be reimbursed as a telehealth distant site provider.

To indicate that remote delivery occurred, FQHCs and RHCs should use the 95 modifier and Place of Service 02 when submitting claims and encounters. The telehealth service must also meet applicable state statutory and rule scope-of-practice requirements.


TCHP follows the Medical Policy for Telemedicine and Telehealth Services as written in the current Texas Medicaid Provider Procedures Manual – Telecommunication Services Handbook. Please reference for additional information. Providers should verify that correct billing processes are in place including proper coding.

Next steps for providers:

Providers are reminded to use appropriate coding as defined by Medicaid, or in the above specified guidance for billing of Telehealth services. 

If you have any questions, please email Provider Network Management at:

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