Telehealth Policy Updates - COVID - 19
Most Americans are glad that we are closing the book on this week! It has been a wild week economically and from a practice management perspective, but there are many things to be thankful for and that we can celebrate together.
Commercial and government insurance continues to make wide-sweeping changes to their telehealth policies and the last few days are no exception.
AETNA
• “Effective January 1, 2020, our policy will cover telemedicine services for members enrolled in all Aetna commercial plans. We’ll reimburse for two-way, real-time audiovisual interactive communication between the patient and the health care practitioner” • “Reimbursement will be the same as if the service was rendered face-to-face.” • Prior to March 6th, 2020, client copays were the same as they are for face-to-face visits. However, “as of March 6, 2020, Aetna will offer zero co-pay telemedicine visits for any reason for 90 days, until June 4,2020” • “The claim should be billed with one of the following modifiers: GT: Telehealth service rendered via interactive audio and video telecommunications system 95: Synchronous telemedicine service rendered via real-time interactive audio and video telecommunications system” • NOTE from BG: It is unclear if out of network providers will be covered. On the Aetna website under “What You Need to Know About the Coronavirus (COVID-19), assessed 3/16/20 , it stated: “For the next 90 days, until June 4, 2020, Aetna will offer zero co-pay telemedicine visits – for any reason. Aetna members should use telemedicine as their first line of defense in order to limit potential exposure in physician offices. Cost sharing will be waived for all virtual visits through the Aetna-covered Teladoc® offerings and in-network providers delivering synchronous virtual care (live video-conferencing) for all Commercial plan designs. stated telehealth sessions were for “virtual visits provided through the Aetna-covered Teladoc® offerings and in-network (emphasis mine) providers delivering virtual care for all Commercial plan designs,” so it is unclear if out of network providers are covered for telehealth, even during this health emergency.
One of the questions on the page was: “Would you be willing to open access to in-network levels of care on out-of-network providers for the period of this potential pandemic?” And the answer given was “We are currently evaluating this within the parameters of how we handle other disasters, e.g. hurricanes, floods, wildfires. However, unlike natural disasters, the COVID-19 is not limited to a specific geographic area, which makes this situation more complicated. We are working with both network and out-of-network providers throughout the country to render care to members in the best possible ways based on the volumes of patients seeking services and appointment availability within a specific geographic area.” Doesn’t sound like a definite “yes” to me. • Self-insured employers can opt-out of this program, so telehealth (or free telehealth) benefits may not apply to all your clients. f you have questions, or have a specific member for whom you would like to check coverage, it was suggested that you contact Aetna, provide the patient’s name and ID number (and probably date of birth) along with your question at https://www.aetna.com/health-care-professionals/forms/contact-us-online.html (I received a quick response) or possibly email aetnamemberservices@aetna.com. • Aetna phone numbers: 1-800-624-0756 (for HMO plans); 1-888-632-3862 (for Traditional plans); 1-877-480-4161 (for Aetna Student Health plans)”
Sources: correspondence to author from aetnamemberservices@aetna.com March 12, 2020, in response to author’s question; also, What You Need To Know About the Coronavirus, Aetna Website, https://www.aetna.com/individuals-families/member-rights-resources/need-to-know-coronavirus.html
ALWAYS HEALTH PARTNERS
“Always Health Partners is removing all cost-sharing for telemedicine services, including virtual visits with primary care providers and specialists, and through Partners HealthCare On Demand, to enable members to seek COVID-19-related care without the need to go to medical offices.”
AMERIHEALTH NEW JERSEY
“To help reduce potential exposure, AmeriHealth New Jersey encourages members to utilize telemedicine services if they are available as part of a member’s plan. To support use of these services, AmeriHealth New Jersey will waive cost-sharing, where applicable, for phone and video telemedicine visits for 90 days (through June 4). To access telemedicine options, members should login to our member website at amerihealthnj.com.” For details click here
ANTHEM BLUE CROSS OF CALIFORNIA
From email to provider from California Network Relations, 3/17/20: “I can speak to your Anthem Mental Health Network Commercial individual agreement. Services for Telemedicine are allowed under your Anthem agreement in your professional office for psychotherapy. Services need to be provided through a secure, HIPAA compliant mechanism (no Facetime or Skype) and in live, real-time audio/visual capability.” “Telemedicine for patient psychotherapy is the delivery of mental health care services through telecommunication technology, videoconferencing.” “Technology would not include telephone, text or email consultations, FaceTime, SKYPE, etc.”
Patient would need to have the benefit specifically for telemedicine or not be an excluded benefit.Providers rendering psychotherapy to members in CA must be licensed and have an active private practice in CAA provider cannot be contracted just for TelemedicineTelemedicine does not apply to ABA service.Service must be a service that could also be rendered in person and on payment schedule
Billed according to contract, along with the GT modifierPlace of service for Teleheath is 02
The following are examples of services not eligible for reimbursement as Telehealth services.
ABA service are not eligible for telemedicine servicesNon-direct patient care (e.g. coordination of care before or after patient interaction)Services rendered by audio-only telephone or mobile phone calls, facsimile, email or any other non-secure (not HIPPA approved i.e. FaceTime or Skype) electronic communication.Anthem will not reimburse any provider for Telehealth Services delivered through a medium that does not meet the requirements.Any services not eligible for separate reimbursement when rendered as in-person services
Follow these steps:
Immediately before the Scheduled Appointment:
Confirm you have obtained verbal consent from the patient and it is documented in the patient’s record/file. Answer all questions the patient may have about the Telehealth process. Gather the necessary Telehealth materials (i.e. clinical data, patient file /medical records). Confirm that the Telehealth program (HIPPA compliant audio visual secure portal) is working properly.
During the Patient’s Appointment, be cognizant of the following: Maintain a professional environment that respects the patient’s privacy and confidentiality. Limit distraction by eliminating background noise as much as possible. Prevent unknown people from entering the room during the psychotherapy /consultation. Post Consultation and Documentation
After you complete the psychotherapy/consultation, perform the following: Mute the audio and disconnect the phone call. Maintain all information from the Telehealth psychotherapy/consultation as part of the patient’s medical record or file to substantiate the services provided and to indicate that services were rendered via Telehealth. “
Source: email to two providers from Nicole Smith, Network Relations Consultant, Sr., Provider Solutions l California Commercial Behavioral Health. CABHNetworkRelations@Anthem.com
2. “Telemedicine services must be provided on a HIPPA compliant audio visual secure portal. This would not include FaceTime, SKYPE, telephonic etc. Patient would need to have the benefit specifically for telemedicine or not be an excluded benefit.
Providers rendering care to members in CA must be licensed in CATelemedicine must be through a secure, HIPAA compliant mechanism (no Facetime or Skype)Live, real-time audio/visual capabilityService must be a service that could also be rendered in personBilled according to contract, along with the GT modifier
As a Commercially contracted provider please e-mail your questions to Behavioral Health Network Relations at: CABHNetworkRelations@anthem.com“
Source: Ann Frank, Provider Network Mgr 1, Anthem Inc, 9655 Granite Ridge Drive, Suite 600, San Diego, CA 92123 , O: (858) 571-8215. ann.frank@anthem.com
ANTHEM BLUE CROSS EAP
” We can amend your contract to include telephonic counseling at any time. With EAP, we do not make a distinction with regard to telephonic/telehealth, so when you amend your contract, we would allow phone calls as well as video sessions with a HIPAA compliant platform. We do not make recommendations on platforms but it is your responsibility to comply with federal (HIPAA) and any state regulatory mandates around information security with those platforms. Telehealth sessions are paid at the same contracted rate as face to face. “
Source: March 12, 2020 email from Philip Prewitt, MA LPC, Manager, Network Relations, Anthem Employee Assistance Program Provider Networks, 700 Broadway, Denver, Colorado 80273, Office: 303-869-3191, Mail code: CO0105-0542. philip.prewitt@anthem.com, EAPProviderNetworks@anthem.com,
ANTHEM (not California)
Anthem announcement 3/17/20: “For 90 days, Anthem’s affiliated health plans will waive any member cost share for telehealth visits, including visits for mental health, for our fully insured employer plans, Individual plans, Medicare plans and Medicaid plans, where permissible. Cost sharing will be waived for members using Anthem’s telemedicine service, LiveHealth Online, as well as care received from other telehealth providers delivering virtual care. Access to LiveHealth Online as well as virtual care via text is available to members through the Sydney Care app. Self-insured plan sponsors will have the choice to participate in this program.”
Source: https://ir.antheminc.com/news-releases/news-release-details/anthem-issues-updates-regarding-covid-19-testing-and-care?field_nir_news_date_value%5bmin%5d=
ANTHEM BLUE CROSS MEDI-CAL
“The plan will cover psychotherapy sessions provided via telehealth to new or existing clients (ex. CPT code 90837,90834, 90847) Video sessions are covered, we are still waiting on guidance from leadership as to whether phone sessions will be covered. No additional authorization is required to render telehealth services. Only ABA and Psych Testing require prior auth for our Medi-Cal network. There are no other requirements for the provider to be covered (ex. client location, therapist on approved telehealth list.In terms of billing and mofiers, please refer to the DHCS’s telehealth policy https://www.dhcs.ca.gov/provgovpart/Pages/Telehealth.aspx. Modifiers and Place of Service coding are addressed. Updates to the telehealth policy include the following: • Allow Medi-Cal providers flexibility to determine if a particular service or benefit is clinically appropriate for telehealth via audio-visual two-way real time communication and store and forward. • Place no limitations on origination or distant sites. • Implement Place of Service Code 02 for all services delivered via telehealth and modifier 95 for services delivered via audio-visual two-way communication. Telehealth will be covered at the same rate as in person sessions There is no need to alter your provider contract to include telehealth. Providers can use any telehealth platform that is HIPAA Compliant” Note from author: It is unclear if provider must be in-network with the plan to provide telehealth.”
Source: 3/16/20 email to author from Rita Salazar, Network Relations Consultant, Anthem CA Medicaid Provider Solutions – Behavioral Health. F: (855) 514-9240. BHMedi-CalNetworkRelations@anthem.com
BEACON HEALTH OPTIONS
“At the moment due to the crisis, please feel free to conduct telehealth services, we will f/u later with required documentation.”
source: email 3/16/20(?) from Eddie Vivero to beacon Provider, Mr. Vivero is Contract Development Manager, Beacon Health Options, 5665 Plaza Drive, Suite 400, Cypress, CA 90630 Office: 562.246.3793, edward.vivero@beaconhealthoptions.com. www.beaconhealthoptions.com
2. ” Telehealth is being allowed for all providers due to COVID-19. Beacon is currently working to send out notice/announcement to all providers with further information.”
source: email 3/17/20 to a provider via Secure messaging from Beacon Provider Relations Department, Beacon Health Options, P.O. Box 1866, Hicksville, NY 11802-1866, Phone: 800-397-1630, Direct Provider Relations Fax: 800.646.9371. www.beaconhealthoptions.com
3. 3/17/20 Email from Beacon provider: “I called Beacon – for Northern CA it is the Great Lakes Service Center for Provider Services 855-847-8347 and they told me that there are internal discussions about telemental health going on and no decisions have been made! The follow-up number is going to be 800-397-1630 for Provider Relations. I signed in to the Beacon provider web pages and nothing.”
Note from author: I have been unable to get substantive telehealth coverage info for psychotherapy from this plan yet. Check back to this website and I will update as it comes in. If you have received any written plan information outlining current telehealth policy, please contact me.
BEACON MEDI-CAL
“We appreciate your partnership over the past several days as we looked for ways to increase members’ access to telehealth and to help you continue to provide quality behavioral health services to your patients during this unprecedented time. To mitigate the spread of COVID-19, Beacon is committed to enabling Members to remain in their homes to reduce exposure and transmission, and to preserve health system capacity for the duration of this public health emergency consistent with governmental mandates. Consistent with the California Department of Healthcare Services Information Notice 20-009, Beacon Health Options will permit providers to deliver clinically appropriate, medically necessary covered services to Medi-Cal Members via telephone or telehealth (live video conferencing). Moreover, Beacon strongly encourages providers to utilize this increased telehealth flexibility to maximize the number of services provided by telephone or telehealth.
The following changes are effective immediately (until further notice) for providers serving Medi-Cal members:
No contract adjustments or signed attestation is required to provide services to Medi-Cal members.
The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) Notification of Enforcement Discretion have stated that they will not be enforcing HIPAA compliance for telehealth remote communications during the COVID-19 nationwide public health emergency.Beacon is not imposing specific requirements for technologies used to deliver services via telehealth and will allow reimbursement for covered services delivered through telephone or telehealth so long as such services are medically necessary and clinically appropriate. Providers are reminded, however, that state confidentiality may still apply.Providers are encouraged to use appropriate HIPAA compliant telehealth platforms to communicate with individuals. When leveraging widely available communication apps, such as FaceTime or Skype, to the extent feasible, ensure the same rights to confidentiality and security as provided in face-to-face services. Providers must inform members of any relevant privacy considerations.There are no site restrictions on where services are performed for Medi-Cal members.Clinical documentation for telehealth services is the same as face to face documentation for services.Rates of payment for services delivered via Telehealth will be the same as rates of payment for services delivered via traditional in-person methods as it applies to your contract. Providers should continue normal billing practices until further notice. Providers will be able to bill Beacon for these services delivered via telephone or telehealth beginning March 16, 2020, for a period of time to be determined.The situation with COVID-19 is very dynamic, we will continue to monitor developments and review the proposed end date each week as we have new information.”Source: Beacon Provider Relations Dept. email to providers. 3/18/20, from provider.inquiry@beaconhealthoptions.com
BLUE CROSS BLUE SHIELD FEDERAL EMPLOYEES PROGRAM MENTAL HEALTH/SUBSTANCE ABUSE (MHSA)
Email from provider, 3/17/20: “I just wanted to let you know that I spoke with a rep from fepblue.org this morning and she told me that telehealth services are now covered for federal employees outside of Teledoc.”
2. From BCBS press release: “FEP will waive copays for telehealth services related to COVID-19.
These actions will apply to all FEP members of the 36 U.S. and Puerto Rico-based BCBS companies For more information on FEP’s policy changes, please visit www.fepblue.org for details on the expansion of benefits and services. Members can also call the National Information Center at 1-800-411-BLUE (2583). If you are not an FEP member and have questions about your health plan, please contact your local BCBS Company: bcbs.com/memberservices. Contact info: Blue Cross Blue Shield Federal Employees Program Mental Health/Substance Abuse (MHSA): Phone: MHSA: 800 424-4011 (8AM – 5PM ET) Monday-Friday FAX: 866 793-0469; Other phone numbers: Phone: 800 860-2156 (8AM – 7PM ET) Monday-Friday FAX: 800 732-8318″
Source: https://www.bcbs.com/press-releases/blue-cross-and-blue-shield-federal-employee-program-waives-cost-shares-and-prior-authorizations-for-coronavirus and https://www.anthem.com/docs/public/inline/2019_FEP_15.pdf
BLUE CROSS/BLUE SHIELD OF ALABAMA
“March 13. 2020: As we continue to monitor the outbreak of the new coronavirus (COVID-19) in Alabama, we are expanding telehealth to ease access to appropriate medical services for your patients who are Blue Cross and Blue Shield of Alabama members. The expansion of telehealth services is effective March 16, 2020, and allows clinicians to provide medically necessary services that can be appropriately delivered via telephone consultation. These actions will be effective for one month, expiring on April 16, 2020. It will be reevaluated for a continuance as needed. This is applicable for patients who wish to receive their care remotely and limit their exposure. It can also serve as an initial screening for patients who may need to be tested for the coronavirus. For guidance on coronavirus testing, please refer to the Centers for Disease Control & Prevention and the Alabama Department of Public Health websites. Member cost-sharing (copayments, deductibles, etc.) will apply according to the member’s contract benefits. This applies to all Blue Cross and Blue Shield of Alabama members including Blue Advantage®.This applies to physicians and their extenders who currently receive Blue Cross reimbursement on the Preferred Medical Doctor (PMD), Physician Extender, Select and Select Extender fee schedules. Urgent care is also included; however, at this time, we are not including other provider types.
Behavioral health providers are included in this policy expansion. Some of these providers already perform telemedicine services. Under this policy, all behavioral health providers will be able to perform services telephonically. This policy expansion will expire on April 16, 2020, but be reevaluated for continuance as needed. For behavioral health billing and coding guidelines specific to this telehealth expansion, refer to the New Directions Behavioral Health telehealth expansion memo.
New Directions will communicate additional telehealth services information to providers. To support providers who may have patients experiencing distress or anxiety, New Directions is offering a crisis hotline for the public at 1-833-848-1764.
Telehealth is appropriate for consultations and visits for either low complexity, routine or ongoing evaluation and management. This would include acute illnesses or chronic disease management that, based on the provider’s medical judgment, can be managed over the phone.
Providers should bill established-patient evaluation and management codes up to a level 3 (CPT codes 99211, 99212 and 99213). Standard documentation applies and additional billing guidelines will be posted on ProviderAccess. Claims should be filed with place of service 02 (telehealth). A modifier is not required.
Providers should only bill for telephonic consultations when the provider speaks directly with the patient. Providers should not bill Blue Cross for services when, for example, a nurse speaks to the patient, even if the provider was consulted.
If you have questions, call Provider Networks at 1-866-904-4130.”
Source: BCBS of Alabama website, viewed 3/17/20, https://providers.bcbsal.org/portal/web/pa/resources/-/resource/viewArticle/XBPIOOAUGB?frm=alabamablue.com
BLUE CROSS/BLUE SHIELD OF ARIZONA
“BCBSAZ will waive the member cost share for telehealth sessions, and expand access to telehealth and nurse/provider hotlines. Given the nature of the COVID-19 outbreak, seeking in-person medical care may lead to further spreading of the virus. BCBSAZ will encourage the use of virtual care and will also facilitate member access and use of nurse/provider hotlines.”
BLUE CROSS BLUE SHIELD OF ILLINOIS
” March 18, 2020: Blue Cross and Blue Shield of Illinois (BCBSIL) is responding to the coronavirus (COVID-19) pandemic by offering additional coverage for telehealth visits to give members improved access to care while reducing their risk of exposure. Effectively immediately, BCBSIL will accept telehealth billing codes for additional services, including behavioral health therapy, as described in the table below. This expansion is in addition to the new telehealth program announced on March 11, 2020, and applies to eligible BCBSIL PPO and Blue Choice PPOSM members for medically necessary services with an in-network Illinois provider who offers telehealth services. Telehealth benefits for medically necessary services are also available to HMO members (in accordance with the details of their health plan) from providers in their medical group who offer telehealth. BCBSIL will continue to follow the applicable guidelines of the Illinois Department of Human Services and Centers for Medicare & Medicaid Services (CMS) as appropriate for Blue Cross Community Health PlansSM (BCCHPSM) (Medicaid Plans), Blue Cross Community MMAI Plans (Medicare-Medicaid Plan)SM and Blue Cross Medicare Advantage (PPO)SM members. BCBSIL is also temporarily lifting cost-sharing for medically necessary health services delivered via telehealth. This applies to all fully insured members whose benefit plan includes telehealth benefits. Benefits may be different for our members covered under certain employer-funded health plans, depending on the decisions their employer makes about telemedicine. Between now and April 30, 2020, BCBSIL will continue to consider whether to extend the timeframe of this temporary cost-sharing change…. The following telehealth codes are now accepted by BCBSIL for use by health care professionals1 authorized by Illinois State law to provide services via telehealth:
Code
Description
90791*
Psych diagnostic evaluation
90792*
Psych diagnostic evaluation w/medical services
90832*
Psychotherapy 30 min
90833*
Psychotherapy 30 min w/e&m evaluation
90834*
Psychotherapy 45min
90836*
Psychotherapy 45 min w/e&m evaluation
90837*
Psychotherapy 60 min
90838*
Psychotherapy 60min w/e&m evaluation
90847*
Family psychotherapy
99213*
Office visit established patient 15 min
99214*
Office visit established patient 25 min
99215*
Office visit established patient 40 min
99421
Physician /Qualified Health Professional telephone evaluation 5-10 min
99422
Physician /Qualified Health Professional telephone evaluation 11-20 min
99423
Physician/Qualified Health Professional telephone evaluation 21-30 min
99441
Physician/Qualified Health Professional online digital evaluation 5-10 min
99442
Physician/Qualified Health Professional online digital evaluation 11-20 min
99443
Physician/Qualified Health Professional online digital evaluation 21-30 min
98966
Nonphysician telephone assessment 5-10 min
98967
Nonphysician telephone assessment 11-20 min
98968
Nonphysician telephone assessment 21-30 min
98970
QNHP online digital E/M SVC EST PT <7 D 5-10 min
98971
QNHP online digital E/M SVC EST PT <7 D 11-20 min
98972
QNHP online digital E/M SVC EST PT <7 D 21+ min
*Providers submitting claims for telehealth services using these codes must append with modifier 95.
Available telehealth visits with BCBSIL providers currently include 2-way, live interactive telephone communication and digital video consultations, which can allow members to connect with physicians while reducing the risk of exposure to contagious viruses or further illness.
As a reminder, it’s critical to check eligibility and benefits for each member at every visit prior to rendering services. Providers may connect with a Customer Advocate to check eligibility and telehealth benefits via phone, or verify general coverage by submitting an electronic 270 transaction via the Availity® Provider Portal or other preferred vendor portal. This step will help providers determine coverage information, network status, benefit preauthorization/pre-notification requirements and other important details.
Continue to watch the News and Updates section of the BCBSIL Provider website for more information.”
BLUE CROSS/BLUE SHIELD OF MASSACHUSETTS
See complete information on telehealth policies at https://provider.bluecrossma.com/ProviderHome/wcm/connect/7de2d366-27c9-4ef2-9125-5cce9626502c/MPC_082715-2U+Telehealth+Final.pdf?MOD=AJPERES&CVID=Includes this question and answer: “Q: Is behavioral health a part of telehealth services? A: Yes. Some of the most common behavioral health conditions treated with online. therapy include depression, anxiety, stress management, and sleep difficulties. Our contracted behavioral health providers can see their established patients via short telehealth video visits and provide medication management as well. Here are the covered behavioral health codes: Code Narrative 90791 Psychiatric diagnostic evaluation 90792 Psychiatric diagnostic evaluation with medical services 90832 Psychotherapy, 30 minutes with patient and/or family member 90833 Psychotherapy, 30 minutes with patient and/or family member when performed with an evaluation and management service 90834 Psychotherapy, 45 minutes with patient and/or family member 90836 Psychotherapy, 45 minutes with patient and/or family member when performed with an evaluation and management service 90837 Psychotherapy, 60 minutes with patient and/or family member 90838 Psychotherapy, 60 minutes with patient and/or family member when performed with an evaluation and management service (list separately in addition to the code for primary procedure) 90846 Family psychotherapy (without the patient present), 50 minutes 90847 Family psychotherapy (conjoint psychotherapy) (with patient present), 50 minutes Required modifier:📷📷95 Telemedicine service using a real-time interactive audio and video telecommunications system GT Via interactive audio and video telecommunication systemsNote: We will deny telemedicine claims submitted without modifier GT or 95.
“March 6, 2020: Effective today, we will…. Waive co sharing for members in plans with telehealth benefits for the screening, evaluation, diagnosis, and/or suggested treatment of COVID-19. Telehealth offers convenience as well as the opportunity to avoid potential exposure to contagion. We will reach out to any employer customers without the benefit to ensure they know this option is available as well.”
BLUE CROSS BLUE SHIELD OF MICHIGAN
“BCBSM will expand access to telehealth and its 24-hour nurse hotline. Given the nature of the COVID-19 epidemic, seeking in-person medical care may lead to further spreading of the virus. BCBSM will encourage the use of virtual care and will also facilitate member access and use of nurse/provider hotlines.” For more information, go to https://www.mibluesperspectives.com/news/blue-cross-blue-shield-of-michigan-will-waive-member-copays-and-deductibles-for-covid-19-tests-among-series-of-proactive-steps-on-coronavirus/
BLUE CROSS BLUE SHIELD OF MINNESOTA
“Blue Cross will expand access to telehealth and nurse/provider hotlines. Given the nature of this epidemic, seeking in-person medical care may lead to further spreading of the virus. We will encourage the use of virtual care and also facilitate member access and use of nurse/provider hotlines.” For more information go to https://www.bluecrossmn.com/about-us/newsroom/news-releases/blue-cross-and-blue-shield-minnesota-expands-coverage-coronavirus
BLUE CROSS AND BLUE SHIELD OF NEBRASKA
“Starting Monday, March 16, 2020, all telehealth visits from providers will be paid with no member cost share for all members covered under a Blue Cross and Blue Shield of Nebraska medical plan until further notice.”
“We believe making telehealth available free of charge is in the best interests of our members during an emerging public health crisis.To register to use services provided by Blue Cross and Blue Shield of Nebraska’s preferred telehealth provider, AmWell, please follow the instructions found on NebraskaBlue.com/Telehealth.”
For more information go to https://newsroom.nebraskablue.com/how-blue-cross-and-blue-shield-of-nebraska-is-responding-to-the-coronavirus-and-what-you-need-to-know/
BLUE CROSS BLUE SHIELD OF NORTH CAROLINA
“HEY CLINCIANS! Video or phone! Tell your patients to stay home and see you by video or phone. We’ll pay for it! Below, you’ll find 4 steps we’re taking to make it easier for you to provide care to your patients. Switch to Virtual ASAP: We will pay for virtual visits at parity including visits through secure video or by phone. On March 6th, we announced we were making telehealth easier for our members and clinicians to use. And, we meant it. You can even use telehealth options in the hospital and ED. Behavioral health too. Click for a detailed guide on clinical scenarios and how to file claims here.”“These changes apply to our fully insured, Medicare, State Health Plan and Federal Employee Program members. Self-funded employer groups will be given the option to apply these changes to their employees’ plans. These …steps took effect on March 6, 2020. They will remain in effect for 30 days and then be re-evaluated.”Source: https://blog.bcbsnc.com/coronavirus-providers/
BLUE SHIELD OF CALIFORNIA
Most Blue Shield of California clients have behavioral health handled by Blue Shield’s MHSA (Mental Health Service Administrator, Magellan. See Magellan listing below or info regarding those clients. If your client is Blue Shield (not Magellan), I’m sorry to report I have been unable to get substantive telehealth coverage info for psychotherapy from this plan yet. Check back to this website and I will update as it comes in. If you have received any written plan information outlining current telehealth policy, please contact me.
BLUE SHIELD OF CALIFORNIA, U.C.BERKELEY SHIP
Email from UCSHIP Contracting 3/16/19: “Yes, you can bill for Telehealth phone calls.”
Email 3/17/20: “Telehealth services are covered under the UCB SHIP and are the same rates regardless of the place of service (office vs telehealth). For telehealth, providers bills the same code as if they were face to face in the office. Please use modifier 95 to show telehealth and Place of Service code 02 for the virtual visit. Please contact Wellfleet Member Services at (833) 302-978 for billing-related questions.”
source: UCB SHIP Contracting Blue Shield of California, 3300 Zinfandel Drive – A-1 C312F Rancho Cordova, CA 95670 UCBSHIPContracting@blueshieldca.com
“UC Berkeley is compiling a list of psychotherapists who are able to offer video/phone sessions to students during this current crisis. If you are:
-contracted with an insurance carrier – have availability for at least 3 UC Berkeley students – have availability to provide services via telehealth (phone, and/or video)
Please fill in this form: https://docs.google.com/forms/u/0/d/e/1FAIpQLScxNiGuYNXy4FR5S-pJS2CmVExbDI1dZyntMKF_ZL1VJT_iOw/formResponse
Source: Provider
CARE FIRST
CareFirst is encouraging the use of telemedicine and virtual sites of care. For telemedicine accessed through a CareFirst Video Visit, copays, coinsurance, and deductibles will be waived for the duration of this public health emergency—including behavioral health. For more info, click here: CareFirst
CIGNA / CIGNA BEHAVIORAL HEALTH
“Telehealth, is meant for those patients who are unable to get to your office for any reason to have a face to face sessions. You will still need to continue to call to verify benefits – there will be additional communcation sent out on this today 3/16/20 from Cigna Corporate. When you do bill for these type of sessions you would continue to bill under the CPT code you would normally use on your fee schedule but add the GT modifier to your bill (under Field 24-D in claim form). You will be reimbursed at the same amount as that code on your fee schedule. I have also attached a Telehealth Flyer [text pasted below] for your review which covers billing and service resources. In regards to contacting you, Cigna Behavioral Health (CBH) would refer patients to you the same way we have before. If a member calls in for a list of counselors in your area we will refer them according to the member’s needs. Contracted behavioral providers need to attest to meeting the designated specialty requirements before delivering behavioral telehealth sessions to Cigna customers. Upon receipt of the completed form, “telehealth” will be added as a specialty to the provider’s Cigna profile. For your conveinience I have attached attested specialty form in this email. You may review, complete, and sent to: CompletedForms.ProviderNetwork@cigna.com.
You must utilize a secure video-based technology and be appropriately licensed in the state in which the customer is being treated. You also must be aware of relevant practice guidelines developed by any applicable specialty societies as they relate to both in-person and telehealth practice. You are expected to follow federal, state and local regulatory and licensure requirements related to your scope of practice, any limitations on the use of specific technologies and prescribing practices, and need to abide by state board and specialty training requirements. CBH medical necessity criteria (page 51) indicates that providers should be licensed where they are rendering services and in the state where the member is physically receiving treatment. If such services cross state lines, providers may require multi-state licensure. The American Telemedicine Association (ATA), a non-profit organization that serves as an international resource and advocate promoting the use of advanced remote medical technologies, offers additional guidance on technology. Visit www.americantelemed.org for more information. Our front line staff at Provider Services should also be able to support you in this service and further inquiry at 800.926.2273.”
ATTACHED FLYER: “CIGNA INTERIM TELEHEALTH GUIDANCE:” Announcement from Cigna Behavioral Health: “During this time of heightened awareness of the novel Coronavirus, COVID-19, and its recent classification by the World Health Organization (WHO) as a global pandemic, we want to keep you up to date on how Cigna Behavioral Health is working to help support you and your patients with Cigna coverage.
Many behavioral providers have contacted us about delivering telehealth sessions. While we have been reimbursing for telehealth since 2017, we have made some temporary revisions to telehealth requirements to support continuity of care during this unique situation. The following changes are effective March 17, 2020 through May 31, 2020.
Behavioral telehealth sessions are available to patients with Cigna coverage and are administered in accordance with their behavioral health benefits. Prior to rendering services, you should verify behavioral health benefits and eligibility for all plan types, including services administered by a third-party administrator, by calling the number on the back of the patient’s ID card. An “S” identifier on the bottom left of the card can help you identify which of your patients have services administered by a third-party administrator.
As a general requirement, Cigna-participating outpatient providers must complete an attestation to deliver telehealth sessions. During this interim period, however, telehealth attestations are notrequired. Please note that regardless of your attestation status, it is expected that you use a secure platform to deliver services and follow all Health Insurance Portability and Accountability Act (HIPAA) requirements.
While telephonic sessions are not typically covered in accordance with our Medical Necessity Criteria, we are making an exception during this interim period. You may provide telephonic sessions to patients who do not have access to technology to participate in telehealth sessions, as appropriate.
Best practice standards indicate that providers be licensed in the state(s) where they practice and where their patient is located at the time of service. During this interim period, we understand that special considerations may need to be made, as some individuals may be displaced. We are aware that state-specific licensing requirements for the delivery of telehealth may be waived and/or loosened during this time. You are required to follow federal and/or state guidance as it evolves for the delivery of telehealth. If you have questions about licensing mandates, please contact the appropriate state licensing board(s).
Behavioral providers who meet telehealth requirements (see above) may deliver services via telehealth with no additional credentialing.
If you are an individual provider or an outpatient clinic, you may use telehealth for outpatient therapy, applied behavior analysis (ABA),* medication management, and Employee Assistance Program (EAP) services. Include the following information on your claim form:
Appropriate Current Procedural Technology® (CPT®) code in Field 24-D for the service(s) providedModifier 95** in Field 24-D to specify telehealth (see sample claim form below)Place of Service 02 in Field 24-B (see sample claim form below) If you are rendering services as part of a facility (i.e., intensive outpatient program [IOP], partial hospitalization program [PHP], inpatient), expanded use of telehealth to include psychiatric evaluations, group, or family therapy is permitted at this time, in accordance with current legislative telehealth guidance. Use applicable revenue codes and normal billing procedures. Excluded physician services may be billed separately using the 95 modifier (see above) in cases where the contracted facility rate is not inclusive of psychiatric evaluation charges. There is no separate billing required for therapy sessions, as they are already included in the contracted facility rate. Medical Necessity Criteria for the level of care being delivered must continue to be met.
Please use your existing fee schedule/contract to determine the correct charge. Your reimbursement is the same whether you render face-to-face or telehealth sessions.Additional resources
For the foreseeable future, the following platform is available, free of charge, to behavioral providers to deliver telehealth sessions: https://www.psychiatryrecruitment.org/articles/telepsychiatry-software-and-covid-19For more information about the delivery of telehealth in relation to COVID-19, visit: https://info.americantelemed.org/covid-19-news-resourcesIf you have additional questions about providing behavioral telehealth sessions patients with Cigna coverage, call Provider Services at 800.926.2273
We will continue to update you on this situation”
Source: flyer and response went in email to author on March 16, 2020 from Ciji Linares, MSW, Provider Relations Representative, AZ, CA, NM, OR, TN. Phone: 770.779.4912, Fax: 860.847.5239, Ciji.Linares@Cigna.com
CLAREMONT EAP
“In light of the current COVID-19 Pandemic, telehealth will be a critically important means for providing care. Claremont is fully supportive of telehealth.
• If you are currently seeing clients over video, please reply to this email and confirm that you utilize a HIPAA-compliant videoconference platform.
• Please note, Facetime and Skype are not HIPAA compliant platforms.
• If you would like to work with Claremont clients over video but do not have a HIPAA-compliant platform, please reply to this email and let us know – we can set you up with a SecureVideo.com account. Note, we do not generally allow telephone sessions except in cases of emergency. However, during the COVID-19 crisis, we are allowing our providers to offer sessions over the phone. We will reimburse the same for video, phone or in-person sessions.”
Source: email 3/13/20, “COVID-19 Announcement to Providers” from Michele Guyton, MA., Director of Provider Relations, CLAREMONT EAP, Client Services 800.834.3773, Provider services 888.699.7675 Fax 510.337.8833. mguyton@claremonteap.com www.claremonteap.com
COMPSYCH
From Reilly Tangen, Provider Relations Specialist , in an email March 16, 2020: “In order to participate in ComPsych Telehealth, please note that the platform you use must be HIPAA Compliant. Once a HIPAA compliant platform has been established, please feel free to conduct telehealth sessions as needed. There is nothing additional required beyond this and there is no need to reply with what platform you are utilizing. If you do not already have a platform, some of the HIPAA complaint platforms that most providers use are: Simple Practice, Skype Business, Doxy.Me, Clocktree, and TheraNest. TELEHEALTH SESSIONS ARE EXACTLY THE SAME AS ANY EAP AND/OR MANAGED CARE SESSIONS; BILLING/REIMBURSEMENT IS ALSO THE SAME. THERE IS NO MODIFIER OR ADDITIONAL BILLING CODES FOR TELEHEALTH SESSIONS THROUGH COMPSYCH.”
source: Reilly Tangen, Provider Relations Specialist, ComPsych Corporation, NBC Tower – 13th Floor, 455 N. Cityfront Plaza Drive, Chicago, IL 60611. 800-557-1005, Ext. 255, Fax: 312-595-4219 providerrelations@compsych.com
From Christine Ulrich at ulrich@compsych.com, email March 16, 2020: “ComPsych providers are allowed to provide telehealth services to their clients for both EAP and Managed Care. No additional code will be needed.”
CONCERN EAP
“We have been getting questions from many providers re: how to respond to requests for phone/video counseling if clients are uncomfortable coming into the office. Here are our thoughts and suggestions:
• If you have a current client who asks about this, and you are comfortable providing phone/video services, and you have a HIPAA compliant phone/video platform from which to provide clinical services, it is fine with Concern that you offer these services. You will bill us at the usual session rate in the same manner as you would face-to-face counseling. o HIPAA compliant video platforms include (but are not limited to) Simple Practice, Doxy.me, Zoom, Theralink, and VSee. We do not endorse one over the other. Some have a fee, some do not. o Please check with your phone carrier to determine if your phone line is HIPAA compliant. Google Voice for G suite is HIPAA compliant. o If you have questions or would like to consult about the clinical appropriateness for a particular case, please call us at 800-344-4222 and ask for your clinical supervisor or the clinical manager on call. o Phone and video sessions are 45-50 minutes in length and replace a face-to-face visit. Please be sure to conduct sessions in a private, professional space where there are no interruptions or distractions. You may need to clarify with clients that they are part of the EAP benefit level and “count” the same as a face-to-face session. • New clients referred to you may be requesting face to face counseling. However, because the COVID-19 situation is changing daily, you may get questions about remote services from these clients as well. o If you are comfortable offering telephonic or video counseling, please do so. If not, please refer these new cases back to Concern. • New clients who call Concern specifically asking for video or telephonic counseling will be referred only to counselors who indicate they are comfortable providing these services as well as face to face. • As always, if you are unavailable or out of the office, please call provider relations and let us know so we can make a note of it and not send referrals your way.
From, The Concern Network Team (1-800-344-4222) — Kiersten Daniel-Baca, LCSW, Director of Clinical Services, 650-940-7061, Kiersten_danielbaca@concernhealth.com; Margot Brown, PsyD, Clinical Services Manager, 650-988-7513, Margot_brown@concernhealth.com; Susan Zweig, LCSW, Clinical Services Manager, 650-988-7422, Susan_zweig@concernhealth.com”
Source: Source: Email on 3/13/20 to Concern Providers
EMPATHIA
“In order to give our members flexible options to access care, which can help reduce the spread of infection, we are expanding our services to include video and telephone telehealth services during the duration of this state of emergency. Effective March 17, Empathia will cover telephone and video “virtual” visits with members. Providers must follow all state legal and ethical provisions of EAP telehealth services including ensuring that the enrollee is appropriate for these services. We ask all providers to complete a brief survey (https://empathia.formstack.com/forms/telehealth_attestation) to notify Empathia of the types of services you will be offering during these critical times. In order to conduct sessions via video, providers must complete the EAP telehealth attestation for which will appear below the service delivery method once “Video sessions (telehealth)” is selected. Phone and video visits will be reimbursed at the same rate as a regular in-person visit. For any additional questions or concerns, please reach out to field operations at 877-844-8693 extension 6.”
Source: 3/17/20 Email to providers from Tim Sumiec, tsumiec@empathia.com, signed by Carol Wilson CEO, Empathia, Inc. , N17 W24100 Riverwood Drive, Suite 300 Waukesha, WI 53188 and Patti Ackermann, CEO/CFO, Empathia Pacific, Inc., 5234 Chesebro Road, Suite 201, Agoura Hills, CA 91301
HUMANA
“Humana has created a website to keep our providers updated on our organizational response to COVID-19 and provide information and resources related to claims payment, member responsibility, etc. Please click on the link: https://www.humana.com/provider/coronavirus. See also
1. 2019 CMS Guide to Telehealth Services MLN Booklet — Humana follows CMS guidelines. 2. Approved TeleHealth Policy.
There should be no need to amend your provider contracts as these codes should be on the 005-33x fee schedule. As always we recommend that you verify members eligibility and benefits and or contact Customer Service for more guidance. Responsibility for payment shall be subject to but not limited to membership eligibility, benefit limitations and coordination-of-benefits rules, etc. Here is also a website where the Telehealth policy is so you can check in case Humana updates the policy at any time. Here is the link , search by keyword “telehealth” https://www.humana.com/provider/medical-resources/claims-payments/claims-payment-policies “
Source: 3/16/20 email from Behavioral Health Provider Services, Humana Behavioral Health Network, 2001 W. John Carpenter Freeway Irving, TX 75063, T 800-890-8288, F 833-931-0662, behavioralhealthproviderservices@humana.com
KGA (EAP)
“As you are likely aware, concerns regarding COVID- 19 are causing citizens to take extra precaution in order to decrease risk of exposure. We understand that for this reason many clinicians will begin to offer counseling via phone or video as opposed to in-person sessions. We want to inform you that we encourage these efforts and many of our clients would be interested in the option of virtual counseling during this time. If you decide to make arrangements for online counseling, the EAP billing process will remain the same. As our office will be closed for the next few weeks and our staff will be working from home, it will be best to email billing invoices as opposed to faxing. Click here to email us. If you do fax the invoice we will be unable to reimburse you until our office is open. Please let us know if you plan to offer all counseling sessions online for the foreseeable future. This will enable us to inform potential referrals. If you have any questions or concerns about this, please contact our Counseling Assistants at 800-648-9557 and ask for Tiffany or Michelle.”
Source: Email to provider 3/16/20 from KGA Inc., info@kgreer.com,
KGA Inc.161 Worcester Road, The Meadows Framingham, MA 01701
LIFEWORKS BY Morneau Shepell
From email to affiliates 3/17/20: “In light of the current concerns surrounding COVID-19, we are seeing a significant increase in requests for tele counselling in lieu of in person appointments. We want to offer support both to you as a LifeWorks Counselor, as well as to our clients who request a counseling service. You may have concerns about clients in your office, and clients may experience increased anxiety about being in a public place. We encourage you to check with your licensing board, and if permissible, you have our support and endorsement to provide counseling sessions telephonically or using a HIPAA compatible Video platform. (Please note that Skype and FaceTime are NOT HIPAA compatible and should not be used.) … If you are no longer able to see clients in person in your office and are moving exclusively to tele-counselling, please be sure to inform your clients and update your voicemail with a message that you are only doing appointments via telephone. If you are not able to reach all of your clients, be sure to leave a sign on your office door saying that you have attempted to reach everyone to move to tele- appointments and asking that they reach out to you by phone or email to reschedule.
We will continue to monitor events regionally, and will make any adjustments to these plans as necessary based on local circumstances. For all concerns, please connect with us at PNS_inquiries@morneaushepell.com”
2. From email to a provider 3/17/20: “Because of the COVID-19 pandemic, we are temporarily allowing our Affiliates on both the LifeWorks and Morneau Shepell sides to take on Tele-Support and Video Counseling if they do not want to do In-Person Counseling. We allow our Affiliates to conduct Video Counseling sessions through a HIPAA compliant platform. Reimbursement would be the same as your In-Person rate at this time. When it comes to billing, if you receive an in-person case, but do Tele-Support/Video, you should still indicate the session as In-Person.”
Source: Kourtney Julious, Affiliate Specialist, LifeWorks by Morneau Shepell T: 312.807.0518 134 North LaSalle Street, Suite 2200, Chicago, IL 60602 LifeWorks
3 From email to providers 3/18/20 from Mailroom@morneaushepell.com: “During this unprecedented time, LIfeWorks by Morneau Shepell continues to monitor the rapidly changing impact to our communities as a result of the COVID-19 pandemic. First and foremost, please know that our thoughts and best wishes remain with you, your loved ones, and the clients you serve on our behalf. We recognize the increased need for flexibility and understanding during this time. Please consider the following:
Use Tele Health services whenever possible and appropriate. You may need to check with your licensing or regulatory board to confirm this modality has been approved during the pandemic.Video sessions on a secure platform are acceptable. (Note, Skype and Face Time are NOT compatible with HIPAA regulations and should not be used.)If you are a current and credentialed Tele or Video Support counselor in the LifeWorks network, use your current process to bill for sessions.If you are currently a face to face (FTF) counselor, it is okay during this time to bill for Tele and Video Sessions as if they were a FTF appointment.Please feel free to contact us at pns_inquiries@morneaushepell.com with any questions or concerns.”
LYRA
Email to providers March 19, 2020: “Given current CDC guidelines, which recommend social distancing to prevent community spread of coronavirus, we encourage providers in areas highly impacted by COVID-19 to consider moving their in-person sessions to video sessions, provided video is clinically appropriate for their clients. If you would like to temporarily offer video sessions during this public health situation, please contact us at providers@lyrahealth.com. Once we receive your request, we can refer new clients who designate a preference for video to your practice. Even if your area is not highly impacted by COVID-19 and you are new to video, we encourage you to take steps to prepare your practice to see clients by video, if and when appropriate.
Best Practices to Consider
If you are able to offer video sessions, be sure to use a HIPAA-compliant video platform.Choose a private setting that is free of distractions.Ask clients for a contact number in advance, in case your connection is disrupted.Ask clients for the address where they are taking the session in case of a clinical emergency.Learn more about our video therapy resources here.
Once the public health concern has stabilized, please plan for a return to in-person sessions. Lyra’s network of highly skilled, evidence-based in-person providers is a primary reason that employers choose the Lyra benefit for their employees. Lastly, we encourage you to follow the recommendations of local, state and federal government agencies as you take preventive measures to keep yourself and your clients healthy. Please contact us at providers@lyrahealth.com if you have any questions about care for your Lyra clients.”
2. Email 3/19/20 from Lyra after author contacted providers@lyrahealth.com and asked to be placed on video list: “Thank you for reaching out. We have enabled your profile for video sessions. We appreciate you making accommodations for Lyra clients at this time…
1) If you are planning on conducting video therapy sessions in the short term (during the crisis), Please take a moment to review Lyra’s requirements and resources for video therapy here: https://provider-support.lyrahealth.com/hc/en-us/articles/222972387-Become-a-Video-Therapy-Provider
2) Please note that we will NOT be removing your office address from your profile. If a client reaches out for in person sessions, we ask that you please tell your client that you are not able to meet in person and that you send them instructions on how to do sessions online. We do not have the ability to make changes to your profile bio to reflect this at this time.
3) Please ensure when you invoice Lyra for the virtual sessions, you mark the sessions as such on the invoice form. There is a section on the invoice where you can indicate how the session was conducted. As a reminder, the reimbursement rate for video sessions is the same as in person.4) If you no longer have any office and anticipate never having an office in the future, please reply here to let us know you need your address removed for that reason. There is a different process for requesting this, as your contract will need to be reviewed by the Provider Relations team.”Source: 3/19/20 email from providers@lyrahealth.com
MAGELLAN
Email from Magellan to providers 3/19/20: “Like you, we are deeply concerned about the health and safety of people everywhere as we face the COVID-19 crisis. To support you in ensuring Magellan members get the care and services they need, effective March 18, 2020, during this national state of emergency, we are taking various measures, such as:
Waiving requirements to provide services via telehealth (e.g., attestations).Helping providers access a telehealth platform.Allowing sessions via telephone if telehealth is not possible.Permitting intensive outpatient (IOP) and partial hospitalization programs (PHP) to deliver services via telehealth, if feasible.
Visit MagellanProvider.com/crisis for details in our list of provider questions and answerspertaining to these topics and more. Please bookmark and refer to this webpage and Q&As frequently as we will continually update them.”
Source: Magallan Healthcare email 3/19/20 to providers from providernotices@magellanhealth.com, www.MagellanProvider.com, 14100 Magellan Plaza, Maryland Heights, MO 63043
2. Information from Magellan website: “The following CPT codes can be billed by physicians/psychiatrists, psychologists, master’s level, and clinical nurse specialists.” (with modifier)
90791 Psychiatric Diagnostic Evaluation – no medical services GT or 95 90832 Psychotherapy with patient, 30 minutes GT or 95 90834 Psychotherapy with patient, 45 minutes GT or 95 90837 Psychotherapy with patient, 60 minutes GT or 95 90839 Psychotherapy for Crisis, initial 60 minutes GT or 95 +90840 Psychotherapy for Crisis, additional 30 minutes GT or 95 90846 Family Psychotherapy (without the patient present), 50 minutes GT or 95 90847 Family Psychotherapy (conjoint psychotherapy) (with the patient present), 50 minutes GT or 95 +99354‐99355 Prolonged Physician Service with Direct (face‐to‐face) Patient Contact, Office/Outpatient GT or 95 +90785 Interactive Complexity Add‐On GT or 95
• Telehealth Services Provider Attestation: Magellan requires completion and return of this document for provision of all telehealth services. • Telehealth is defined by Magellan as a method of delivering behavioral health services using interactive telecommunications when the member and the behavioral health provider are not in the same physical location. Telecommunications MUST be the combination of audio and live, interactive video. • CPT/HCPCS codes performed by telehealth distant providers must be billed with the GT or 95 modifier. • Organizational providers billing professional services should bill the license level modifier in the first modifier field and the telehealth modifier in the second modifier field. • HCPCS code Q3014 performed by telehealth originating site providers should not be billed in conjunction with the GT or 95 modifier; some accounts may require separate authorization for this HCPCS code to be reimbursed. • Place of Service code: All telehealth claims should be billed with the “02” POS code.
Source: https://www.magellanprovider.com/media/51605/telehealth_billing.pdf
MANAGED HEALTH NETWORK (SEE MHN)
MEDICA
“Q: Will Medica cover telehealth services to ensure access to care while reducing the opportunities for disease transmission? A: This will depend on member coverage and if telemedicine is part of their benefits. As a reminder, see related reimbursement policies on www.medica.com for telemedicine, telemedicine for Minnesota Health Care Programs members and telephone services. See coverage policies for telemedicine and virtual care, too. (Some Medica plans offer virtual care benefits.)”Source: https://www.medica.com/-/media/documents/provider/medica-covid-19-preparedness-provider-faq.pdf?la=en&hash=58AA2956226B0969670E49A29B841259
MEDICARE
“EXPANSION OF TELEHEALTH WITH 1135 WAIVER: Under this new waiver, Medicare can pay for office, hospital, and other visits furnished via telehealth across the country and including in patient’s places of residence starting March 6, 2020. A range of providers, such as doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers, will be able to offer telehealth to their patients. Additionally, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs. Prior to this waiver Medicare could only pay for telehealth on a limited basis: when the person receiving the service is in a designated rural area and when they leave their home and go to a clinic, hospital, or certain other types of medical facilities for the service. Even before the availability of this waiver authority, CMS made several related changes to improve access to virtual care. In 2019, Medicare started making payment for brief communications or Virtual Check-Ins, which are short patient-initiated communications with a healthcare practitioner. Medicare Part B separately pays clinicians for E-visits, which are non-face-to-face patient-initiated communications through an online patient portal. Medicare beneficiaries will be able to receive a specific set of services through telehealth including evaluation and management visits (common office visits), mental health counseling and preventive health screenings. This will help ensure Medicare beneficiaries, who are at a higher risk for COVID-19, are able to visit with their doctor from their home, without having to go to a doctor’s office or hospital which puts themselves and others at risk.”
See complete details on telehealth in updated article on CMS website dated 3/17/20 at https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet
See also 3/17/2020 telehealth FAQ at: https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf
Excerpts: “Q: Would physicians and other Qualified Providers be able to furnish Medicare telehealth services to beneficiaries in their homes? A: Yes. The waiver temporarily eliminates the requirement that the originating site must be a physician’s office or other authorized healthcare facility and allows Medicare to pay for telehealth services when beneficiaries are in their homes or any setting of care.Q: How does a qualified provider bill for telehealth services? A: Medicare telehealth services are generally billed as if the service had been furnished in-person. For Medicare telehealth services, the claim should reflect the designated Place of Service (POS) code 02-Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site.”
MHN
From MHN email to provider 3/18/20: MHN Policy and Procedure, Policy Number NM41, Subject: Contracting for Telemedicine, Medi-Cal and Commercial Lines of Business, effective 11/19/14, revision 3/26/19: The purpose of this policy is to document and outline the protocol for contracting for telemedicine (web video) services.Policy: MHN contracts with providers of telemedicine services for Medi-Cal and Commercial plans. Because of Medicare restrictions, we cannot include Medicare business in telemedicine contracts. All providers delivering telemedicine services must be contracted with MHN and meet MHN credentialing criteria. They must also attest to following specific telemedicine guidelines. This policy applies to Medi-Cal and Commercial business only.Definitions:Telemedicine The technology described in this policy is referred to as “telemedicine” and involves a videoconferencing or video interactive telecommunication at two locations. “Telehealth” on the other hand, is a broader term and can consist of other technologies such as telephonic sessions, email communication, texting etc. The two terms are sometimes used synonymously however technically “telemedicine” must involve audio-video.Originating Site MHN does not current contract with Originating sites, which are host sites (such as a hospital, doctors office or clinic), required by Medicare.Consumer or Home Based Model MHN contracts with providers under a consumer or home based model which means that the patient connects from their home computer or electronic device (ie: smart phone or tablet).Distant Site The term “distant site” means the site where the provider is located.Metropolitan Statistical Area (MSA) This is relevant to Medicare only. The Office of Management and Budget defines a Metropolitan Statistical Area (MSA) as one city with a population of 50,000 or more, or an urbanized area (as defined by the Bureau of the Census) with a population of at least 50,000 and a total MSA population of at least 100,000Provider Responsibilities: Providers must agree to the following in order to be contracted for telemedicine: They must agree to provide telemedicine services according to applicable State and Federal laws related to the delivery of telemedicine services. They must maintain the necessary education, training/orientation, and continuing education and professional development for the delivery of telemedicine services. They must comply with the Best Practices Guidelines published by the American Psychiatric Association (APA) and American Telemedicine Association (ATA). These guidelines are located on the ATA website at: http://hub.americantelemed.org/resources/telemedicine-practice-guidelines . They must agree to only provide telemedicine services via HIPAA and Privacy compliant platforms. They must agree to only provide telemedicine services to those MHN Enrollees who reside within the same state in which provider is clinically licensed.Billing and Reimbursement: MHN pays the same level of reimbursement for face to face vs telemedicine. Providers are performing the same services with a different delivery method. For reimbursement, providers must bill the relevant CPT code, add a “GT” modifier and indicate “02” as the Place of Service (POS) on the claim. The member is still responsible for any applicable co-pay or cost-sharing. The co-payment amount is the same as if the service was office based.Reflecting Telemedicine Providers in Symphony and Directory Display. After contracting with a telemedicine provider, Provider Relations staff should select “TEL” as the primary license type, and enter a 4 in the specialty “TEL”. The license type TEL is the indicator that pulls into the MHN directory. When performing a provider search on MHN.com, there is a telemedicine option.Credentialing: All providers delivering telemedicine must be credentialed per usual MHN credentialing policies.The following applies to Medicare Only (not yet implemented): For Medicare Beneficiaries only, telemedicine services are only reimbursable if they are delivered in an Originating Site that is located in a county outside of a Metropolitan Statistical Area (MSA). See definitions section for Originating Site and MSA.Some examples of counties outside of MSAs in states where Health Net manages Medicare business are: Pima, Pinal, Cochise, and Santa Cruz Counties.Reimbursement – Originating Site (not yet implemented): For billing the originating site fee, providers use HCPCS code Q3014 (telemedicine originating site facility fee).Restrictions for billing transmission costs are as follow:HCPCS Code Site Frequency LimitQ3014 Originating site Once per day, same recipient, same providerAll fees associated with managing the cameras and performing any hands-on activities to successfully complete the clinical encounter are absorbed in the HCPCS codes.Source: email 3/18/20 to author from MHN provider services, MHN.ProviderServices@healthnet.comAlso: From a network provider: “I called MHN (1-800-647-7526) on 3/16/20 to inquire about telehealth benefits… today I received an email with an “Amendment to the Participating Provider Agreement” which I had to sign and send/fax back. It was easy. The Amendment is effective retroactively to 3/1/2020. Email response was from MHN.ProviderServices@healtnet.com“. Telehealth Agreement required therapist to operate by state laws, get necessary training about the delivery of telehealth, only use HIPAA compliant platforms, and deliver services to members who reside within the state where the provider is licensed. It also states that “provider shall bill MHN with the applicable CPT code, GT modifier and indicate “02” as the Place of Service (POS).”
Source: provider who supplied MHN Amendment to the Participating Provider Agreement, Amendment W, Telemedicine Services
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