COVID-19 Policy Updates

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.


Resources

COVID-19 Screening Tool

Telehealth Revenue Calculator (tool provided by Azalea Health)

COVID-19 and Telehealth Coding “Cheat Sheet” (supplied by the AMA)


Alabama Division of Medicaid (DOM)

The extension of telemedicine services through the Alabama Division of Medicaid is effective March 16, 2020. This extension allows clinicians to provide medically necessary services that can be appropriately delivered via telecommunication services including telephone consultations. The extension also allows some behavioral health services to be appropriately delivered via telecommunication services including telephone consultations. These actions will be effective for one month, expiring on dates of service April 16, 2020. It will be reevaluated for a continuance as needed. This is applicable for recipients who wish to receive their care remotely and limit their exposure to the virus. It can also serve as an initial screening for recipients who may need to be tested for COVID-19. For guidance on coronavirus testing, please refer to the Centers for Disease Control & Prevention, Alabama Department of Public Health, and Alabama Department of Mental Health websites.

 


Centers for Disease Control and Prevention (CDC)

CDC Infection Control Guidance: This updated guidance from the CDC provides updated PPE recommendations for the care of patients with known or suspected COVID-19.

  • Facemasks are an acceptable alternative to N95 respirators when respirators are unavailable in healthcare settings.
  • Respirators should be prioritized for procedures that are likely to generate respiratory aerosols.
  • When an adequate supply of respirators is available in a healthcare facility, facilities should return to use of respirators per their respiratory protection program.
  • Continue to use eye protection, gown, and gloves.
  • If there is a shortage of gowns, they should be prioritized for aerosol-generating procedures, high contact patient care activities, and activities where splashes and sprays may occur.

Patients with known or suspected COVID-19 should be cared for in a single-person room with the door closed. Airborne Infection Isolation Rooms (AIIRs) (See definition of AIIR in appendix) should be reserved for patients undergoing aerosol-generating procedures.

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.

CAH Swingbed Flexibility

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.

Elimination of Geographic Restrictions

March 6, 2020, Medicare began temporarily paying clinicians to furnish beneficiary telehealth services residing across the entire country. In addition, the beneficiary generally could not get telehealth services in their home.

Services and Providers

Under this Section 1135 waiver expansion, a range of providers, such as doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers, can offer a specific set of telehealth services. The specific set of services beneficiaries can get include evaluation and management visits (common office visits), mental health counseling, and preventive health screenings. Beneficiaries can get telehealth services in any health care facility including a physician’s office, hospital, nursing home or rural health clinic, as well as from their homes.

Diagnostic Billing Code Tookit

CMS recently published a telehealth toolkit to assist providers in the new telehealth policies and diagnostic billing codes.

Co-Pay Requirements Waives

The Office of Inspector General stated that if a provider wishes to waive collection of the 20% coinsurance, they can and the OIG will not consider this a violation of the antikickback rules. This is voluntary.

To read the Fact Sheet on this announcement visit: https://www.cms.gov/newsroom/factsheets/

 


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.

Elimination of Geographic Restrictions

March 6, 2020, Medicare began temporarily paying clinicians to furnish beneficiary telehealth services residing across the entire country. In addition, the beneficiary generally could not get telehealth services in their home.

Services and Providers

Under this Section 1135 waiver expansion, a range of providers, such as doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers, can offer a specific set of telehealth services. The specific set of services beneficiaries can get include evaluation and management visits (common office visits), mental health counseling, and preventive health screenings. Beneficiaries can get telehealth services in any health care facility including a physician’s office, hospital, nursing home or rural health clinic, as well as from their homes.

Diagnostic Billing Code Tookit

CMS recently published a telehealth toolkit to assist providers in the new telehealth policies and diagnostic billing codes.

RHC Code Updates

Distance site telehealth visits for RHCs must be billed with HCPCS code G2025. For distant site services rendered between January 27th, 2020, and June 30th, 2020, RHCs must bill G2025 with modifier CG. After July 1, RHCs will no longer need modifier CG. Furthermore, modifier 95 is completely optional for all G2025 claims.

Audio-only services such as the audio E/M services 99441, 99442, and 99443, may now be billed as G2025 services.

View More Details

RHC Telehealth Reimbursement Prior to June 30, 2020

All CMS G2025 claims prior to June 30, 2020 must be billed with modifier CG and will reimburse at the RHC’s all-inclusive rate. Beginning July 1, 2020 all these claims will be reprocessed to $92.03. After July 1st, the CG modifier is no longer needed, and these claims will pay $92.03 from the onset.  Guidance has been provided that CMS may recoup the difference between the all-inclusive rate paid prior to July 1, and the $92.03 fee schedule.

Co-Pay Requirements Waives

The Office of Inspector General stated that if a provider wishes to waive collection of the 20% coinsurance, they can and the OIG will not consider this a violation of the antikickback rules. This is voluntary.

To read the recently released RHC billing practice form: visit www.cms.gov/files/document/se20016.pdf 

To read the Fact Sheet on this announcement visit: https://www.cms.gov/newsroom/factsheets/


CARES Act

As part of the CARES Act, Congress has authorized Rural Health Clinics to be the “distant site” for telehealth visits. Until now, RHCs could only be the originating site for these visits. CMS is working on the guidance necessary to allow you to begin submitting claims for these visits but you can begin doing these visits as of March 27th Providers may need to hold these claims until billing guidance is issued.

The CARES Act establishes a $100 billion grant fund exclusively for health care providers who are enrolled in the Medicare and Medicaid program. The purpose of this fund is to provide grants to healthcare providers who have experienced a reduction in revenue due to the COVID19 pandemic.

The CARES Act creates the Paycheck Protection Loan Assistance program which expands and modifies an existing Small Business Administration (SBA) Loan program. What makes this “loan” program unique is that the government will be able to FORGIVE all or most of this loan if the business does not terminate employees during the pandemic. If the small business uses the loan to cover monthly expenses such as: payroll, continuation of health benefits for employees, rent, mortgage, utilities and interest on other loans you may have, then that portion of the loan will be forgiven.


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.

This may include:

  • Facetime
  • Skype
  • Unencrypted Zoom / GoToMeeting, etc

This should not include:

  • Facebook live
  • YouTube
  • Other publicly facing streaming services

Blue Cross and Blue Shield of Alabama

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.

Read More


Substance Use Disorder Services Via Telehealth

CMS released guidance for rural health care and Medicaid agencies on telehealth flexibilities provided by the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) Act.

Read More

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s