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)

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:

• 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-19
• For more information about the delivery of telehealth in relation to COVID-19, visit: https://info.americantelemed.org/covid-19-news-resources
• If you have additional questions about providing behavioral telehealth sessions patients with Cigna coverage, call Provider Services at 800.926.2273
  

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