The Alabama Rural Health Association has been working to develop policies and flexibility for providers in order to best protect themselves and meet the needs of their patients in a safe and effective manner.
We have provided an update, below, of all policy changes enacted by various state and national organizations related to COVID-19. Please read carefully and call us at 334.697.8541 if you have any questions or need additional information.
Alabama Division of Medicaid (DOM)
• LabCorp is accepting COVID-19 test orders and samples from physicians and other healthcare providers, clinics, and hospitals anywhere in the U.S. We are processing tests in the order received.
• COVID-19 tests can be ordered directly from LabCorp. We are not aware of any requirements that state or local health authorities must provide approval for LabCorp to perform testing. However, healthcare providers who are evaluating or treating patients under suspicion for COVID-19 may be required to coordinate with or provide information to their local or state health authorities. As noted above, testing should be conducted on appropriate patients in accordance with the latest clinical guidance from the CDC and other expert organizations. Please check with those authorities for more information.
• LabCorp is reporting COVID-19 test information to public health authorities as may be required, but the ordering provider may also be required to report results and other information as well.
• CMS has established reimbursement in the amount of $51.31 for COVID-19 testing, and an HCPCS code for billing. LabCorp will use that rate for all customers, payers, and patients.
Please visit LabCorp’s COVID-19 website for the most current
Centers for Medicare and Medicaid Services (CMS)
Medicare will pay doctors and hospitals for a broad range of telehealth services on a temporary basis, effective March 6. The program will pay for office and hospital telehealth visits and include a wide range of providers including nurse practitioners, clinical psychologists and social workers. Telehealth visits will be reimbursed for the same amount as in-person visits.
New Guidance NEW
CMS issued a Section 1135 waiver to allow CAHs and rural (non-CAH) swing-bed hospitals to move patients from their acute care beds to swing beds for extended care services without a 72-hour prior hospitalization. This clarification will help utilization review processes in rural hospitals to better maximize use of patient care beds.
Note: The expanded waiver does not apply to Rural Health Clinics (RHC) or Federally Qualified Health Centers (FQHC) to bill for Medicare telehealth visits or e-visits. CMS does not have statutory authority to issue a waiver for these purposes. See the Congressional Action section below for more information.
CMS recently published a telehealth toolkit to assist providers in the new telehealth policies and diagnostic billing codes.
Blue Cross Expands Telehealth Coverage
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.
What does the expansion include?
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®.
What types of providers can perform telehealth?
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.
How does this affect behavioral health?
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 more information about behavioral health phone consultations, see our telemedicine operational policy. For behavioral health billing and coding guidelines specific to this telehealth expansion, refer to the New Directions Behavioral Health telehealth expansion memo (link will be posted here when available).
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.
What services can be performed?
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.
What codes apply?
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.
Department of Health and Human Services (HHS)
During the COVID-19 national emergency, which also constitutes a nationwide public health emergency, covered health care providers subject to the HIPAA Rules may seek to communicate with patients, and provide telehealth services, through remote communications technologies. Some of these technologies, and the manner in which they are used by HIPAA covered health care providers, may not fully comply with the requirements of the HIPAA Rules.
OCR will exercise its enforcement discretion and will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules against covered health care providers in connection with the good faith provision of telehealth during the COVID-19 nationwide public health emergency. This notification is effective immediately.
A covered health care provider that wants to use audio or video communication technology to provide telehealth to patients during the COVID-19 nationwide public health emergency can use any non-public facing remote communication product that is available to communicate with patients. OCR is exercising its enforcement discretion to not impose penalties for noncompliance with the HIPAA Rules in connection with the good faith provision of telehealth using such non-public facing audio or video communication products during the COVID-19 nationwide public health emergency. This exercise of discretion applies to telehealth provided for any reason, regardless of whether the telehealth service is related to the diagnosis and treatment of health conditions related to COVID-19.
Congressional Action NEW
The US Senate recently released its version of the Phase 3 COVID-19 Stimulus Package, which includes language to make RHCs and FQHCs distance site providers for telehealth. We are working to ensure that all needed language is included. This bill is expected to come up for vote in the coming week.