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Comment: Medicaid-Reimbursable Telemedicine Services Rulemaking

Policy Analyst Michael Villafranca, on behalf of Children’s Law Center, submitted comments to the Department of Health Care Finance (DHCF) regarding emergency and proposed rulemaking covering Medicaid-reimbursable telemedicine services. The proposed rules would establish standards for governing eligibility for Medicaid beneficiaries receiving health services via telemedicine under the Medicaid fee-for-service program and establish conditions of participation and reimbursement policies for providers who deliver healthcare services to Medicaid beneficiaries via telemedicine.

In his comments, Michael provided the agency with recommendations aimed at ensuring the children of DC are provided with the medical care to which they are entitled, including:

  • Clarifying the definition of “consent requirements” as it relates public schools and public charter schools; and
  • Addressing privacy and confidentiality concerns by clarifying the role of the “primary support professional” and the “supervisory services” they are intended to provide.


Click below to read his full comments.