NOTICE: Freestanding Clinics
On July 15th, 2024, MDH released clarifying guidance about services rendered via telehealth at freestanding clinics since the end of the COVID-19 public health emergency. The Federal four walls rule does not allow Medicaid to reimburse a freestanding clinic if neither the practitioner nor patient is physically onsite at the clinic. This includes provider types:
- Clinic, Local Health Department - PT 35
- Clinic, General, PT 38
- Clinic, Family Planning - PT 33
This does not apply to FQHCs or FQHC-sponsored School-Based Health Centers.
MDH submitted an §1115 waiver amendment for an exemption to the four walls requirement. Pending approval, it would allow clinics to bill telehealth services regardless of whether practitioner or patient is physically onsite at the clinic.
UPDATE (Effective 6/1/2025): On May 19, 2025, the state received CMS approval to update the Maryland State Plan to waive the Four Walls requirement for Outpatient Mental Health Centers (OMHCs) (Provider Type MC). Maryland Medicaid participating OMHCs may now submit claims for services rendered via telehealth when both the practitioner and patient are offsite at clinic rates The Department is still pursuing §1115 Waiver Amendment authority for local health departments.
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