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This page contains a compliation of information and relevant resources regarding counseling practice in the current state of national emergency due to COVID-19. Please note, this situation is changing very rapidly and thus this information may become outdated quickly. 

May 22, 2020

  • Email communication from VT OPR regarding re-opening guidance

The Vermont Department of Health has issued new guidance for the re-opening of healthcare.  

These guidance documents are applicable to all healthcare practices, including private offices or clinics, with the exception of dental practices. Any questions about this guidance should be directed to the Vermont Department of Health.

I hope you have a wonderful long weekend.

Lauren, S. Lauren Hibbert, Director, Office of Professional Regulation


May 19, 2020

  • VTMHCA recommended considerations for transitioning from telehealth back to in-person meetings

There are several factors to consider regarding making the decision to transition from telehealth-sessions back to in-person sessions. Having a well thought out transition plan for transitioning counseling sessions from telehealth to in-person is important. Here are some things to consider as you create your plan:

        • Comply with all Federal, Vermont, and local guidelines and recommendations regarding legality and appropriateness of offering in-person meetings vs. telehealth. These have been changing regularly, so it is very important to stay up to date on the requirements and adjust your plan accordingly. 
In a recent communication from Vermont Office of Professional Regulation, they point to this Vermont Dept of Health guidance document regarding specific mitigation requirements for reopening:

https://www.healthvermont.gov/sites/default/files/documents/pdf/Phase-One-Openings-Outpatient-Procedures.pdf

    • Post and distribute a COVID-19 safety practices document that clearly articulates any conditions for meeting in-person, such as requirements about wearing masks, maintaining 6-feet of physical distance, not coming into office if they are displaying any COVID-19 symptoms or have had contact with people who are displaying symptoms, etc. Also include what steps you are taking for sanitizing meeting space and available bathrooms. The purpose of this document is to inform your clients of the practices you are putting in place to maintain their safety.
        • Check with your general commercial liability insurance provider and professional liability insurance carrier to see if your policy covers you for any possible COVID-19 related claims. (e.g. client comes into your office and later believes they were infected with COVID-19 at your office and takes legal action against you.) Insurance carriers have posted statements to consider regarding liability risks of meeting in-person:
        • Consider your own health risk factors – age, health, etc. In the helping field, it is common to be looking out for your client’s wellbeing, however, in this instance, it is also very important to consider your own wellbeing. Your life, health, and well-being matters.
        • Consider that not every client is a good candidate for telehealth and some may not have access to technology required to facilitate the sessions. Consider alternative meetings locations that may reduce risk factors, such as meeting outdoors (while maintaining appropriate distance and utilizing personal protective equipment).
VTMHCA recommends that counselors err on the side of caution and prudence and thus not rush the transition from telehealth-sessions back to in-person sessions. Without vaccines or greater availability of convenient testing methods, there is no way to predict when it will be truly safe to return to in-person meetings, thus it is imperative that each counselor consider these risks and make the best decision. 


May 15, 2020

  • Email communication from VT OPR regarding re-opening guidance 

Dear Health Care Professional Licensees,

Thank you for your patience over these last couple of weeks.  Today, the Vermont Department of Health has issued Resuming Outpatient Services Guidance, which outlines the requirements for reopening outpatient clinics for elective health care procedures (“Guidelines”).  These Guidelines require health care professionals to implement screening, testing, social distancing, PPE, and other precautionary processes prior to re-opening or performing elective procedures.  Once in compliance with these Guidelines, licensed health care professionals may recommence performance of elective practices. 

Though the Office of Professional Regulation (OPR) has worked with our counterparts at the Vermont Department of Health and the Agency of Commerce and Community Development to develop these Guidelines, it must be emphasized that these Guidelines were issued by the Vermont Department of Health.  OPR can continue to communicate updates to the Guidelines, to answer questions regarding the Guidelines, and to relay questions and offer input to the Department of Health regarding future guidelines.  OPR cannot, however, modify the Guideline requirements or excuse licensees from complying with the Guidelines.    

Please let us know if you have any questions or if we can assist in another way. 

Sincerely,

S. Lauren Hibbert


April 8, 2020

  • Vermont Program for Quality in Health Care (VPQHC) 
VPQHC has gathered a bunch of resources and information for Vermont based clinicians wanting to learn more about telehealth. They are also offering twice weekly virtual office hours to answer people's questions about telehealth. Visit the VPQHC webpage for more info.
  • VT Medicaid is offering financial assistance to providers

The Agency of Human Services (AHS) is considering requests for immediate cash flow assistance from Medicaid enrolled, Vermont-based (or border) health care providers experiencing financial distress due to the COVID-19 pandemic.  Visit their website for more info.

  • United States Small Business Administration (SBA) loan programs
The SBA is offering loan programs for small businesses who have been negativelty impacted by COVID-19. Read more about their offerings at the SBA webpage.


March 31, 2020

  • VT-OPR clarifies requirements of out of state licensed clinicians to provide telehealth service to Vermonters 

The Vermont Legislature passed emergency legislation that was signed by Governor Scott on March 30, 2020 that allows individuals who typically cannot practice in Vermont the ability to practice in Vermont during the COVID-19 State of Emergency.

If you hold an out of state license you may practice in Vermont without a Vermont license:

      • If you are providing only telehealth to people in Vermont you do not need a license and you do not have to provide your contact information to the Office of Professional Regulation;
      • If you are providing services to Vermonters in a licensed facility you do need to provide your contact information to the Office of Professional Regulation. 

If you are a retired Vermont professional, we welcome you back into the healthcare workforce.

      • If your license expired within the last three years you do not have to reactivate license. You do have to submit your contact information to the Office of Professional Regulation. 

The Office of Professional Regulation is tracking the COVID-19 Impact on Exams. If you are a graduate of an approved professional program but you are unable to take the required exam due to COVID-19 please apply for a temporary license.

If you have questions if you are required to apply for a temporary license or provide your contact information to our office, please click here.

This information is from this VT-OPR website which includes a form to submit your contact information to them if needed.


March 24, 2020

  • VT-OPR provides guidance regarding internships and supervision
https://sos.vermont.gov/media/af0gx3np/emergency-mental-health-provider-internship-and-supervision-guidance.pdf


March 20, 2020

  • VT-OPR announces emergency policy related to continuation credits
https://sos.vermont.gov/media/4f0pqnqf/opr-covid-19-continuing-education-providers.pdf

For the duration of the declared State of Emergency secondary to the COVID-19 pandemic, for all regulated professions under the umbrella of the Office of Professional Regulation (OPR)1 that require continuing professional education as a condition of license renewal:

(a) Remote continuing education may be substituted for live continuing education. Regulations to the contrary are suspended.

(b) Continuing education courses approved for live instruction may be adapted by course providers for remote presentation, whether online or via correspondence, real-time or asynchronous. Providers need not seek re-approval or otherwise notify OPR before adapting remote courses. OPR trusts course providers to preserve the rigor and educational integrity of approved courses.

(c) Licensees are asked to make reasonable efforts to meet continuing education requirements on time; however, OPR will grant continuing-education extensions as a matter of course when necessary to allow a licensee to renew on time.


March 19, 2020

  • VT-Medicaid will allow billing for audio-only telehealth sessions, starting on March 23, 2020
Billing requires use of V3 modifier and POS code of 99. Read the official VT-DVHA Memorandum for more information. VT-Medicaid will be hosting a webinar on March 20th, 12-12:30pm to discuss this change further. You can find info on how to attend the seminar on the VT-Medicaid website.


March 18, 2020

  • CIGNA has announced their Interim Telehealth Guidance

Information from CIGNA's announcement:

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.

Coverage of behavioral telehealth sessions:

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.

Expectations for providing telehealth sessions:

As a general requirement, Cigna-participating outpatient providers must complete an attestation to deliver telehealth sessions. During this interim period, however, telehealth attestations are not required. 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).

Billing guidance:

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) provided
  • Modifier 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)

telehealth-billing

For illustrative purposes only.


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:


March 17, 2019

  • BCBS-VT Allows billing for telephone (audio-only) telehealth counseling sessions

I'm not able to post the official BCBS-VT policy as it is located behind their secure, confidential website. You can find it on their website in the Provider Resource Center, under BCBSVT Policies (left side menu, near bottom), then Payment Policies link, then you must accept their conditions for viewing their secret material, then you will find this link under the telemedicine heading: Temporary/Emergency Policy: Telephone-Only Services (Effective 03/17/2020. Expires in 60 days.)

From the BCBS-VT provider news website:

Temporary/Emergency Payment Policy: Telephone-Only Services. 

This new policy is being implemented in the setting of active coronavirus infection with the health service area and in an effort to improve social distancing. We are activating it as of March 17, 2020 for a 60-day period. The complete policy has been posted to the Provider Resource Center under the BCBSVT Policies link under Payment Policies. If you require a paper copy, please email providerrelations@bcbsvt.com or call (888) 449-0443, option 1.

  • OCR relaxes HIPAA requirement for using secure telemedicine technology (visit HHS-OCR site)

OCR Announces Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency

Today, the Office for Civil Rights (OCR) at the U.S Department of Health and Human Services (HHS) announced, effective immediately, that it will exercise its enforcement discretion and will waive potential penalties for HIPAA violations against health care providers that serve patients through everyday communications technologies during the COVID-19 nationwide public health emergency.

This exercise of discretion applies to widely available communications apps, such as FaceTime or Skype, when used in good faith for any telehealth treatment or diagnostic purpose, regardless of whether the telehealth service is directly related to COVID-19.

In support of this action, OCR will be providing further guidance explaining how covered health care providers can use remote video communication products and offer telehealth to patients responsibly.

"We are empowering medical providers to serve patients wherever they are during this national public health emergency," said Roger Severino, OCR Director. "We are especially concerned about reaching those most at risk, including older persons and persons with disabilities," Severino added.

The Notification of Enforcement Discretion on telehealth remote communications may be found at: https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html.

For more information on HIPAA and COVID-19, see OCR's February 2020 Bulletin: https://www.hhs.gov/sites/default/files/february-2020-hipaa-and-novel-coronavirus.pdf - PD


March 16, 2020

  • Letter from VTMHCA President to membership

Dear VTMHCA Members

In this uncertain time, we know all too well that our clients will face personal stress and potential exacerbation of ongoing mental health struggles. We also know that we are some of the best means to assist and support our clients to help them work through the stress and fear, to help them access their “tools” and practices to support their well-being.

Many clinicians are asking great questions in regards to telehealth, licensure rules, and other things such as HIPPAA, legislature and the like. I appreciate your thoughtfulness in regards to thinking ahead and being prepared to help yourself stay healthy in order to help others.  Many of the answers that you are seeking are found in our individual resources and agreements. We have to consider our current skills and training, our clientele, our liability policies, and each individual insurance agreement that we might have.

That being said, at this time our VT legislature has been working to create a pretty comprehensive piece of legislature in regards to this state of emergency. It addresses many concerns that we are having. I will include a link below for this. The difficulty is that as of Friday, it went before the Vermont Senate, however they did not vote on it before leaving on Friday. And now, the State house is closed for the upcoming week at least. It is anticipated that Senate committee work will continue this week from a distance to work on key legislation.  Our lobbyist is participating in monitoring this process virtually, and we have communicated and I indicated that this is very important to us and that we would like to receive up-to-the-minute updates as available.

On a national level, AMHCA has been playing an active role in addressing national concerns in this same way. Please take the time to read AMHCA’s executive director Joel’s note in regards to the recent, current and future steps and updates to this process (link below).

There are many ways that this event is a fluid and fast moving process. Things are changing all the time, and each of us has a responsibility to tend to our individual needs, clients needs, and figure out how to make this work in the healthiest way possible. Best practice is to be thoughtful, to use the skills and tools that are within the scope of your ability to use. Use your best judgement in all areas taking into consideration your cumulative experience and wisdom. Consult your liability insurances, your agreements with insurance, and keep an eye on the rules coming out of our state house, congress and office of professional regulation.

Please see the links below which contain helpful information for your consideration. Also, at this time please consider your civic responsibility to keep the health and well-being of yourself and the people you serve at the forefront of your mind.

Sending you thoughts of health and well-being,

Cortney Slobodnjak, President VTMHCA

 

Legislature (DRAFT) from VT state house:

https://legislature.vermont.gov/Documents/2020/WorkGroups/Senate%20Health%20and%20Welfare/Bills/H.742/Bills,%20Amendments%20and%20Summaries/H.742~Jennifer%20Carbee~As%20Passed%20the%20House~3-18-2020.pdf 

 

AMHCA’s Executive Director Joel Miller has provided a comprehensive response to indicate our nationwide efforts and topics of relevance. Please read the link below:

The Coronavirus and Covid19: Resources on What You Need to Know and for Your Families, Your Clients and Your Practice


March 13, 2020

  • Vermont offers Temporary Licensure for Healthcare Workers
Information from the Vermont Secretary of State website

On March 13, 2020, the Governor issued a State of Emergency. This means OPR will be issuing temporary licenses to healthcare workers. 3 V.S.A. §129(a)(10).

Click HERE for instructions on how to obtain a temporary license. Thank you in advance for helping with this healthcare emergency.

Link for temporary license application: https://cms.sec.state.vt.us:8443/share/s/7S2Hlu7uTW-9ME8BrP0VqA



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