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 Please note, this situation is changing very rapidly and thus this information may become outdated quickly.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
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
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:
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:
- 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.
May 15, 2020
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.
S. Lauren Hibbert
April 8, 2020
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.
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.
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
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 a retired Vermont professional, we welcome you back into the healthcare workforce.
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
March 20, 2020
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
March 18, 2020
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).
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.
- 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
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 email@example.com or call (888) 449-0443, option 1.
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