Billing Requirements for COVID-19 Telephonic Communications for FQHC/RHC and IHS-MOA

September 9, 2020

In response to the coronavirus disease 2019 (COVID-19) public health emergency, the Department of Health Care Services (DHCS) has instituted temporary policies and procedures which are distinct from the Medicaid State Plan.

Effective for dates of service on or after March 1, 2020, HCPCS code G0071 is reimbursable for communication technology-based services for 5 minutes or more of a virtual (nonface-to-face) communication, between a Rural Health Clinic (RHC), or Federally Qualified Health Center (FQHC) practitioner and RHC or FQHC patient, occurring in lieu of a visit that does not meet the criteria of a face-to-face visit and results in a determination that a face-to-face visit is unnecessary. The change also pertains to Indian Health Services (IHS), Memorandum of Agreement (MOA) 638, clinics (see the following exceptions**).

  • Service is only reimbursable when initiated by the patient contacting the RHC, FQHC or IHS-MOA clinic.

  • Service is only reimbursable when billed as an outpatient service on the UB-04 claim form.

  • Service is only reimbursable per patient per day.

  • A Treatment Authorization Request (TAR) is not required.

  • Clinics can bill directly to Medi-Cal for Managed Care Plan (MCP) covered beneficiaries unless telehealth or virtual communication services are otherwise agreed to between the MCP and the provider. The MCPs must reimburse Medi-Cal providers at the same rate.

  • For the Medi-Cal fee-for-service rate when billing with HCPCS code G0071, clinics should only list the HCPCS code on the “payable” claim line and should not include a corresponding CPT code.

  • Other Health Coverage (OHC) will apply.

HCPCS Code G0071 is not covered by any Service Code Grouping (SCG) authorization, including SCG 08. FQHC/RHC and IHS-MOA providers should submit a separate Service Authorization Request (SAR) and all supporting documentation when requesting G0071.

An Erroneous Payment Correction (EPC) will be implemented to reprocess affected claims.

** IHS-MOA will bill the Fiscal Intermediary (FI) for HCPCS code G0071 for Medi-Cal and MCP beneficiaries.

Additional billing instructions for HCPCS code G0071 can be found at:

Additional service requirements relative to this service may be found at:

COVID-19 related guidance is located at :