In The News

Temporary Authorization of Telemedicine Services during COVID-19 State of Emergency

HHAC Members -- This is obviously WELCOME NEWS from the Colorado Department of Health Care Policy & Financing. We are seeking more clarifying guidance, if needed. Thanks, Don Knox, Executive Director, HHAC
Dear Providers,
Throughout the COVID-19 state of emergency, Health First Colorado (Colorado’s Medicaid Program) is temporarily expanding its telemedicine policy to authorize the following:
  1. Expanding the definition of telemedicine services to include telephone only and live chat modalities.
  2. Authorizing Federally Qualified Health Centers (FQHCs), Rural Health Clinic (RHCs), and Indian Health Services to bill encounters for telemedicine visits
  3. Adding specified Physical Therapy, Occupational Therapy, and Home Health, Hospice and Pediatric Behavioral Therapy services to the list of eligible interactive audiovisual telemedicine services.
Existing Telemedicine Policy
Health First Colorado currently defines telemedicine as the delivery of medical services and any diagnosis, consultation, treatment, transfer of medical data or education related to health care services using interactive audiovisual communication instead of in-person contact. The list of CPT and HCPCS codes that are already allowed to be provided through telemedicine is available on the Telemedicine - Provider Information page.
For existing telemedicine policy information, including physician services, refer to the Telemedicine Billing Manual, located on the Billing Manuals web page under the CMS 1500 drop-down. The billing manual provides information on covered services, billing, reimbursement and confidentiality requirements.
Telemedicine does not include consultations provided by facsimile machines, text, email or instant messaging. 
COVID-19 State of Emergency Changes to Telemedicine Services
To facilitate the safe delivery of health care services to members throughout the COVID-19 state of emergency, the Department is authorizing three temporary changes to the existing telemedicine policy. 
  1. Telephone and Live Chat Modalities - Services that are allowed to be provided by telemedicine under the existing policy will no longer be restricted to an interactive audiovisual modality only. Providers may deliver the allowable telemedicine services by telephone or via live chat. All other general requirements for telemedicine services, such as documentation and meeting same standard of care, still need to be met (see below for more details). 
  2. Federally Qualified Health Centers, Rural Health Clinics, and Indian Health Services - For the duration of the COVID-19 state of emergency, Health First Colorado is allowing telemedicine visits to qualify as billable encounters for Federally Qualified Health Centers (FQHCs), Rural Health Clinic (RHCs), and Indian Health Services (IHS). Services allowed under telemedicine may be provided via telephone, live chat, or interactive audiovisual modality for these provider types.
  3. Physical Therapy, Occupational Therapy, Home Health, Hospice and Pediatric Behavioral Health Providers - Health First Colorado has expanded the list of providers eligible to deliver telemedicine services to include physical therapists, occupational therapists, hospice, home health providers and pediatric behavioral health providers. Services delivered by these provider types require an interactive audiovisual connection to the member; they cannot be provided using telephone only or live chat.
Requirements for Telemedicine Services:
It is acceptable to use telemedicine to facilitate live contact directly between a member and a provider. Services can be provided between a member and a distant provider when a member is in their home or other location of their choice. Additionally, the distant provider may participate in the telemedicine interaction from any appropriate location. 
Other standard requirements for telemedicine services include:
  • The reimbursement rate for a telemedicine service shall, as a minimum, be set at the same rate as the medical assistance program rate for a comparable in-person service. [C. R. S. 2017, 25.5-5-320(2)]. 
  • Providers may only bill procedure codes which they are already eligible to bill. 
  • Any health benefits provided through telemedicine shall meet the same standard of care as in-person care. 
  • Providers must document the member’s consent, either verbal or written, to receive telemedicine services.  
  • The availability of services through telemedicine in no way alters the scope of practice of any health care provider; nor does it authorize the delivery of health care services in a setting or manner not otherwise authorized by law.  
  • Services not otherwise covered by Health First Colorado are not covered when delivered via telemedicine. 
  • The use of telemedicine does not change prior authorization requirements that have been established for the services being provided. 
  • Record-keeping and patient privacy standards should comply with normal Medicaid requirements and HIPAA. Office for Civil Rights (OCR) Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency
Billing Guidance:
To receive reimbursement for telemedicine services, providers must follow the following billing practices:
  • UB-04 Institutional Claims - Providers must indicate that the service(s) were provided through telemedicine by appending modifier GT to the UB-04 institutional claim form with the service’s usual billing codes. This identifies the service as provided via telemedicine during the COVID-19 State of Emergency. 
  • CMS 1500 Professional Claims - Place of Service code 02 must be indicated on all CMS 1500 professional claims for telemedicine. Only specific CPT/HCPCS are allowed. 
More communications will be sent as updates to the policy are available.



HHAC Asks Governor To Relieve Burdens For Providers During Coronavirus Pandemic

On a call today with Colorado Gov. Jared Polis, the Home Care & Hospice Association sought relief for home health, home care and hospice providers dealing with increased difficulties caring for patients during the coronavirus pandemic. 

Among other things, HHAC asked to the governor allow for a mandatory 90-day supervisory home visit to be replaced by a phone interview, as well as expanding reimbursement for virtual health -- or tele-health -- services provided during the crisis. 

State agency directors acknowledged receiving multitude requests for emergency orders that would speed and streamline care, and they and the governor pledged to follow through on those requests.

At one point on the call, the governor suggested not letting the rules get in the way of providing care. 

"I would encourage you to be as flexible as possible," the governor said when told that seniors had grown suspicious of receiving meals delivered to their homes by various Area Agencies on Aging.  "Leave the meal outside the door."

He added: "If anything needs a corresponding state waiver, we’ll get that out, but don’t let that stand in the way."

Just three days ago, the Centers for Medicare and Medicaid Services released Guidance for Infection Control and Prevention Concerning Coronavirus Disease 2019 (COVID-19) in Home Health Agencies (HHAs). A day before that, CMS released Guidance for Infection Control and Prevention Concerning Coronavirus Disease 2019 (COVID-19) by Hospice Agencies. The hospice guidance followed reports that some long-term care facilities were unduly preventing hospice caregivers from enter the centers to provide care. 

In related news: 




How Is Your Agency Dealing With Coronavirus? Let Us Know

The Home Care & Hospice Association of Colorado seeks your comments about the challenges of providing care during the coronavirus pandemic. 

Please email us at [email protected] with your observations and recommendations. 

HHAC thanks all of our dedicated agencies and caregivers providing care to tens of thousands in this time of need. 





HHAC Issues Call For Nominations For Board of Directors

The association requests nominations and self-nominations for members wanting to join the board of the newly created Home Care & Hospice Association of Colorado -- the combination of January's merger of the HospIce & Palliative Care Association of the Rockies and the Home Care Association of Colorado. 

It's our goal to have representation across our provider members, which includes home health, home care, hospice and private pay agencies. We also seek representatives from each of the geographical regions in the state: the Western Slope, Southeast, Northeast and metro Denver.

Board members commit to serving a three-year term; these terms are staggered so that the makeup of the board changes annually. Board members serve HHAC by attending quarterly board meetings and the annual convention to conduct the business of the association and by chairing committees that accomplish the mission and vision of the association. Attendance of each entire board meeting and annual convention is mandatory for all board members according to board policy.

In selecting a slate of nominees the Nominating Committee looks at several factors: the applicant's experience in home care and hospice, leadership capability and potential, and their history of involvement in the work of HHAC.

If you would like to make a commitment to serve on the board as a director, please complete this online form no later than Tuesday, March 31, 2020. If you'd like to recommend someone for the board, email [email protected].




Tomorrow Is The 40th Anniversary of Colorado's Hospice Association

Coloradans created their statewide hospice association 40 years ago -- on March 14, 1980 -- and members will celebrate the achievement at annual conference later this year of the Home Care & Hospice Association of Colorado. 

The incorporators of the then "Colorado Hospice Coalition" were Boulder’s Beau Bohart, Greeley’s Hope Cassidy, Denver’s Betty Gordon, Fort Collins' Donna Loopo, Rifle’s Debbie Neilson, Grand Junction’s Amelie Starkey and Denver’s Father Paul von Lovkowitz. The group organized as a 501c3 and used the organization to encourage the expansion of hospice services statewide. 

The organization has gone by several names, but it's  service to hospice and palliative care professionals has continued over the decades. In 1989, the name was changed to the Colorado Hospice Organization. Eight years later, following a merger with a palliative care association, it became known as the Colorado Center for Hospice & Palliative Care, or COCHPC.

In 2015, COCHPC spun off a 501c4 membership organization, named the Hospice & Palliative Care Association of the Rockies, and both organizations continued until HPCAR's combination with the Home Care Association of Colorado. 

Today, COCHPC remains as the hospice and palliative care educational arm of the Home Care & Hospice Association of Colorado. This year, COCHPC is the proponent of a state hospice license plate. Having gathered in excess of 3,000 signatures, the organization just this week introduced a bill at the Colorado General Assembly that would make the initiative a reality. 

Congratulations to Colorado's hospices and Colorado's hospice association!



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