Listen Now To CMS Stakeholder Call With Administrator Seema Verma

The Centers for Medicare & Medicaid Services is making stakeholder calls available in the wake of the 2019 Coronavirus (COVID-19) outbreak.  

HHAC has archived the call for playback.

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

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: 

• NAHC urged CMS to make sweeping regulatory changes as coronavirus hit pandemic status
• Congress allowed the U.S. Department of Health and Human Services (HHS) to waive certain originating-site constraints, such as the ones that restrict telehealth in nonrural settings. Providers will also be allowed to conduct telehealth instruction over telephones with audio and video capabilities.
• Caregivers braced for spread of coronavirus
• Colorado mandated up to 4 days of paid leave for COVID-19 testing

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.