Effective Wednesday, June 11, 2025, all providers credentialed to see Kaiser Permanente (KP) clients must utilize Grow’s telehealth platform for every telehealth (virtual) session with every client, regardless of coverage. This change is due to updated KP compliance requirements and platform limitations. Providers can continue to see KP clients in person. Phone sessions with KP clients are also allowed if clinically appropriate, with some additional considerations.
Also, you will no longer be able to schedule or invoice multiple appointments on the same day with KP clients, even if their other appointment is with another provider. If you run into this issue, we will alert you during the scheduling process so you can adjust the appointment and avoid any billing issues.
To learn more about the platform requirements, please read below.
Key Points
Kaiser Permanente (KP) has increased compliance requirements, and the use of Grow Telehealth for your virtual sessions ensures these requirements are met.
Grow Telehealth cannot be used for a specific subset of your clients, so to meet the requirement, you must use the tool for all virtual appointments.
Grow provides various features to ensure this change is not only compliant but also more efficient and effective for your workflow.
In-person sessions remain permitted, and phone sessions are allowed, provided that appropriate documentation regarding the reason is added to the medical record.
To opt out of this change, you must stop seeing Kaiser Permanente (KP) clients and follow these steps.
Frequently Asked Questions
📋 Overview of the changes
What is now required?
CPT (Current Procedural Terminology) coding requires that a provider have clear documentation of the exact session start and stop time documented in a note. This information is logged and validated when using Grow Telehealth.
Kaiser Permanente (KP) has increased compliance requirements, now requiring telehealth session logs that show exact start and stop times based solely on time spent speaking directly with the client. This information is logged and validated when using Grow Telehealth.
Why is this required for all clients and not just KP members?
Our system does not support using Grow’s telehealth platform for certain clients while using a different system for others. To remain in compliance with Kaiser Permanente (KP), any provider seeing or accepting KP members will need to conduct all virtual sessions via Grow telehealth.
How does Grow assist providers in meeting these requirements?
Grow offers the following features to help you comply with these requirements:
Auto-populates the session start and stop times from the Grow telehealth platform into your notes and invoice when a session is completed.
Allow edits to the autopopulated start and stop times only when a session shifts unexpectedly, in which case, a documented reason will be required.
If you need to edit the autopopulated start and stop times on an invoice, we’ll provide a text box for you to explain why the telehealth platform logs don’t match the times in your documentation (e.g., “Session switched to telephone due to client’s limited internet connectivity”).
Note: Kaiser Permanente (KP) may audit records that have had edited start and stop times at a higher rate than those records that have not been altered.
While Grow Therapy does not control payor requirements, we are committed to making it as seamless as possible for you to meet them should you choose to accept a given payor. Providers are required to comply with payor contractual requirements. These updates are a part of Grow's commitment to supporting you in staying compliant with payor contracts and documentation standards.
How do I remain opted out of leveraging Grow Telehealth?
If you would like to remain opted out of Grow Telehealth and no longer wish to see Kaiser Permanente (KP) clients due to these updated requirements, please:
Update your profile to remove Kaiser Permanente (KP) as an accepted plan. Details of how to manage the insurance plans you accept can be found here.
Please contact our Client Navigation Team using this form. We’ll help ensure that your current clients are thoughtfully and smoothly rematched. Your clients can also use this form for rematching assistance.
If you’re considering ending your contract with Grow due to this change, please fill out this form to notify our Provider Success team.
When you request to opt out of Grow Telehealth, we will begin the client rematching process. Once complete, you will be officially de-credentialed and free to use your own telehealth platform.
🖥️ Telehealth Platform
What happens if the Grow platform is not able to support the session? Can we use our own telehealth platform and document on Grow?
If you encounter technical issues, you're permitted to use alternative methods to conduct the session. Just be sure to document the issue and the session details clearly in Grow's platform. Use Grow to finalize documentation and invoicing. You may be asked to produce a log from the alternative platform for these situations, so be sure to have that available and stored.
Why should providers use Grow Telehealth when I am used to another external platform?
Grow is actively investing in Grow Telehealth improvements. While some providers use external systems, using Grow’s platform ensures session logs are automatically generated—something required by Kaiser.
Why can’t I use another platform and just provide logs when needed?
During past audits, many providers couldn’t submit logs promptly or with sufficient information. Since session logs are required to justify time-based CPT codes (like 90837), Grow needs reliable, centralized logs as evidence of the documented time on the record so as to have audit-ready, defensible documentation.
Why is Grow Telehealth required if only Kaiser requires a log?
Although KP requires a log, it's not feasible for all providers to manually produce logs with every session or for those logs to be validated against documented times in the record. Grow’s system auto-generates the required data, ensuring compliance and minimizing administrative burden.
🔁 Opting In or Out of Grow Telehealth
Can providers opt back into Grow Telehealth if they previously opted out?
Yes. Providers who are credentialed with KP and previously opted out of the Grow Telehealth will be automatically opted back in. If you are not currently credentialed with KP but are interested in opting back into Grow Telehealth, please reach out to Provider Support.
Is the mandatory use of Grow Telehealth a violation of our 1099 status?
While 1099 contractors generally use their own equipment and tools, Grow must meet compliance standards for health plans. To satisfy these requirements and reduce audit risk, the use of Grow Telehealth is mandated for virtual Kaiser sessions, so if you choose to continue to see Kaiser clients, then you need to use Grow Telehealth for all clients. This is due to system limitations preventing different telehealth platforms from being used for each payor.
How do providers indicate that they want to continue not using Grow Telehealth?
In order not to use Grow Telehealth, you must be disenrolled from all KP plans, and your KP clients will have to be rematched. In order to kick off this process, please fill out this form indicating your desire to no longer be enrolled with KP. Your clients will be matched with a provider who uses Grow Telehealth, and the Client Navigation team can assist with the transition process.
Once your clients have been rematched, we will disenroll you from all Kaiser plans, which will remove the Grow Telehealth requirement from your account.
However, we encourage providers who plan to de-credential with Kaiser or leave Grow due to this change to utilize Grow Telehealth during this transition period to minimize the impact on client care.
🔄 Client Transition and Notification
How should providers transition clients with such short notice?
Grow encourages you to continue using our platform temporarily while you coordinate a transfer. Two days is a short window, but the Client Navigation team is available to help with client rematching transitions. Use this form to opt out of Grow Telehealth and request assistance rematching your clients.
Once client rematching is complete, you will be officially de-credentialed and free to use another telehealth platform. For the continuity of care, we ask that you continue to work with your clients until we can officially match them with a new provider.
Are clients being informed of this change by Grow, or should providers tell them?
If you are planning to continue to see your KP clients and therefore are comfortable using Grow Telehealth on a go-forward basis, clients’ appointment links will automatically be routed to Grow Telehealth, and no action is required on your part. However, discussing the change directly with your clients is encouraged for transparency.
If you fill out this form to indicate you do not want to use Grow Telehealth and therefore need your KP patients to be rematched, the Client Navigation team will communicate the reason for the change to your clients.
📚 Clinical Modalities and Session Formats
Can I still see Kaiser clients in person?
In-person visits are not required to use the Grow Telehealth platform. However, if you choose to opt out of Grow Telehealth, you will be de-credentialed with Kaiser completely and will not be able to see any Kaiser patients (in-person or virtual).
How do I conduct EMDR using Grow’s platform?
If you use an external Eye Movement Desensitization and Reprocessing (EMDR) platform (e.g., remotEMDR, EMDR.HEALTH) that is currently incompatible with the Grow platform, you may continue to use it for EMDR sessions. To do so, please contact Support via your provider portal or this form to request an “EMDR exemption” from the new platform requirement.
What about phone sessions for clients who can’t do video?
Phone sessions are allowed if clinically appropriate. You must:
Document the reason for a phone session in your notes
Be prepared to show phone logs from your carrier for session times, if audited
📄 Documentation, Billing, and Plan Impact
Which Kaiser plans are impacted?
All Kaiser plans are affected, including:
NorCal
SoCal
Managed Medicaid
Medicare
Mid-Atlantic States
GA
CO
This will also apply to future KP health plans as they are launched at Grow.
How does this change affect session notes and billing?
Grow will auto-fill telehealth start and stop times on invoices. If there’s a discrepancy (e.g., you switched to a phone call), a text box is available to explain the difference.