Targeted Case Management · 27/03/2020 · The contents of this presentation are based on the most recent information we have available from the Department of Medicaid Services (DMS)

Telehealth

Presentation Contents

The contents of this presentation are based on the mostrecent information we have available from the Department ofMedicaid Services (DMS) and the Centers for Medicare andMedicaid Services (CMS) and is subject to change.

Kentucky CHFS Telehealth Website

https://chfs.ky.gov/agencies/ohda/Pages/telehealth.aspx

https://chfs.ky.gov/agencies/dms/Pages/cv.aspx



Telehealth Network

Do providers have to be a part of a telehealthnetwork? No.

Sources:https://chfs.ky.gov/agencies/ohda/Pages/telehealth.aspxhttps://apps.legislature.ky.gov/law/statutes/statute.aspx?id=48459


https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=48459

Technology UtilizationPrevious Requirements vs. Current COVID-19 Nationwide Public Health Emergency

The Office for Civil Rights (OCR) at the Department of Health and Human Services (HHS)has relaxed its enforcement of HIPAA for certain non-public facing applications. Thismeans that OCR will not enforce penalties for the good faith provision of telehealth.Specifically included popular applications that are currently exempted include, but are notlimited to, these services:

• Apple FaceTime• Facebook Messenger video chat• Google Hangouts video• Skype

Source: Provider Telehealth or Telephonic Health Services FAQs, Cabinet for Health andFamily Services, Department for Medicaid Services, March 19, 2020

Technology UtilizationFor current or future reference, these services advertise as being currently HIPAA-compliant video communication (providers may need to conduct additional verification with these services). DMS and CHFS are not endorsing any of these products and only include them for informational purposes:

• Skype for Business• Zoom for Healthcare• BlueJeans• Vidyo• VSee• Doxy.me• thera-Link• Updox• Google G Suite Hangouts Meet


Technology UtilizationPublic facing services are specifically not allowed by OCR and should not be used for the provision of telehealth. These include, but are not limited to:

• Facebook Live• Twitch• TikTok


Can telephone or other audio-only technology be used during this emergency?

DMS has filed an emergency regulation to allow for “telecommunication or otherelectronically mediated health services” to be used throughout the Medicaidprogram. DMS envisions that these services will be utilized as a “telehealth-like”service wherever appropriate. If they are real-time conversations, telephonicservices - where it is not appropriate or possible for a visual video connection tobe utilized - will be treated as synchronous telehealth. DMS will also provide anupdated fee schedule to include the new codes and guidance aboutdocumentation for services that can now be provided via telehealth.

If a service could have been provided via telehealth, but the individual or providerdoes not have the capability to deliver or participate in the service via telehealth,the service may be delivered via telephone as a “telecommunication or otherelectronically mediated health service”. If service delivery is audio-only but theservice would normally be dependent on the exchange of visual information, theprovider should facilitate appropriate electronic or other data exchanges tosupport any treatment delivered.


What services are now available via telehealth or via a telehealth-like service throughout the entire Medicaid

program?DMS and WellCare are making system changes to allow for allprovider types to bill for telehealth services. To the extent possible,providers should provide all services via telehealth. If a service couldhave been provided via telehealth, but the individual or providerdoes not have the capability to deliver or participate in the servicevia telehealth, the service may be delivered via telephone as a“telecommunication or other electronically mediated healthservice”. If service delivery is audio-only but the service wouldnormally be dependent on the exchange of visual information, theprovider should facilitate appropriate electronic or other dataexchanges to support any treatment delivered.


Telehealth Coverage & ReimbursementKRS 304.17A-138

• In accordance with KRS 304.17A-138, a health benefit plan shallrequire a telehealth provider to be licensed in Kentucky in order toreceive reimbursement for telehealth services.

• A health benefit plan shall reimburse for covered servicesprovided to an insured person through telehealth as defined inKRS 304.17A-005.

• Telehealth coverage and reimbursement shall be equivalent to thecoverage for the same service provided in person unless thetelehealth provider and the health benefit plan contractually agreeto a lower reimbursement rate for telehealth services.

Sources:https://chfs.ky.gov/agencies/ohda/Pages/telehealth.aspxhttps://chfs.ky.gov/agencies/ohda/telehealth/FAQsHealthBenefitPlans.pdf


https://chfs.ky.gov/agencies/ohda/telehealth/FAQsHealthBenefitPlans.pdf

Telehealth Billing

• Place of Service: Use 02 (zero two) on the 1500 Claim Form, line 24B, to denote a telehealth service.

• Telehealth modifier not needed at this time.

Source: https://chfs.ky.gov/agencies/ohda/Pages/telehealth.aspx


Kentucky Medicaid Prior AuthorizationsEarlier this week, DMS instructed MCOs that claims with a DOS of 2/4/20 or greater,should not be denied for authorization. This applies to medical outpatient, inpatientand behavioral health claims. It does not apply to pharmacy.

DMS has not lifted requirements pertaining to medical necessity. Any service thatcurrently requires prior authorization will continue to be reviewed for medicalnecessity. We encourage providers to submit requests for authorization for medicalnecessity review. Any service that is not reviewed for medical necessity is subjectto post payment review in accordance with DMS guidelines.

Please note that as this guidance was just clarified for us mid-week we are still working to ensure our systems are configured appropriately. Any claim denials that qualify for payment will be adjusted.

Source: Source: Provider Telehealth or Telephonic Health Services FAQs, Cabinet for Health and Family Services, Department for Medicaid Services, March 25, 2020

What behavioral health services are now allowable via telehealth that were not before?

Within 907 KAR Chapter 15, these services are restricted to face-to-face only.However, for the duration of this declared emergency, the following services arepermissible as synchronous telehealth or as a telecommunication mediatedhealth service:

• Peer support services• Intensive outpatient program services• Group outpatient therapy• Service planning• Partial hospitalization• Targeted case management• Mobile crisis services• Applied Behavioral Analysis• Comprehensive Community Support Services

Source: Provider Telehealth or Telephonic Health Services FAQs, Cabinet for Health and Family Services, Department for Medicaid Services, March 19, 2020

BHSOs and CMHCsLicensed behavioral health providers can deliver servicesvia telehealth, with the exception of residential substanceuse disorder treatment services and residential crisisservices.


Behavioral HealthDMS will allow the following services to be conducted viatelehealth or telephone on a temporary basis:

• Targeted Case Management (all types)• Peer Support Services• Community Support Services

Source: All Behavioral Health Providers, Provider Letter # A-106, Cabinet for Health and Family Services, Department for Medicaid Services: Lisa D. Lee, Wendy Morris, March 17, 2020

G2012 & G2010 DefinitionsIn accordance with CMS and DMS guidance, WellCare hasadded the following codes on a temporary basis for briefcommunications with established patients:• G2012 to be utilized for telephone calls and other

telecommunication devices between physician or otherlicensed behavioral provider and patient; and

• G2010 to be utilized for remote evaluation, such asemail, of recorded video or images submitted by apatient.

Source: All Behavioral Health Providers, Provider Letter # A-106, Cabinet for Health and Family Services, Department for Medicaid Services: Lisa D. Lee, Wendy Morris, March 17, 2020

G2012 & G2010DMS recommends utilizing the description within the G2012 andG2010 service when providing that service. If the health servicebeing provided is more expansive than the definition in the G2012or G2010 code, then DMS recommends still providing the service viasynchronous telehealth or via a telecommunications orelectronically mediated health service but noting that how thatservice was delivered.

G code rates have been published by DMS. Provider reimbursementis driven by provider contract terms and conditions.

Sources: Provider Telehealth or Telephonic Health Services FAQs, Cabinet for Health and Family Services, Department for Medicaid Services, March 25, 2020

https://chfs.ky.gov/agencies/dms/Pages/feesrates.aspx


E-Signatures for Consent ReleasesCan DocuSign or similar programs be used to get e-signatures or consent releases for telehealth services?

Yes. DMS will accept electronic signatures for all purposes.


Occupational, Physical, and Speech Therapy Language Pathology or PT 76 Services

What about initial in-person meetings required for services such asoccupational therapy, physical therapy, and speech and languagepathology or Provider Type 76 (multi-therapy agency) services?

To the extent allowed or not restricted by executive order orlicensing board action, DMS will allow for these facilities andproviders to provide services via telehealth or othertelecommunication method.


Therapy ServicesCan a physical and occupational therapist provideservices in a home setting?

Yes, with the changes made to telehealth services overthe last year – including the previously existing allowancesunder 907 KAR 3:170 - a physical and occupationaltherapist can provide any service via telehealth unlessthat service is prohibited by the providers licensure andlicensure board or if it is residential in nature.


Dentistry ServicesDMS will expand teledentistry – when using the POS 02 code to include: screenings (CDT code D0190), assessments (D0191), and/or examinations (CDT codes D0120, D0140, D0145, and D0150) via teledentistry.

WellCare’s Dental and Vision delegated vendor, Avesis, has confirmed they are ready


Vision ServicesDMS will expand the services that can be utilized by visionservices providers. When using POS 02, appropriateproviders may bill using the following codes: 92002,92012, 92004 and 92014.

WellCare’s Dental and Vision delegated vendor, Avesis, has confirmed they are ready


FQHCs and RHCs

Can federally qualified health centers (FQHCs) or rural health centers(RHCs) provide medical and behavioral health services via telehealth?

FQHCs and RHCs can provide every appropriate service via telehealth aslong as it is an approved service that the individual provider’s licensureboard allows for the provider providing the service.

For an FQHC or RHC to generate the PPS rate, the appropriate providermust provide the service to trigger the payment. A zero pay services codewill continue to zero pay regardless of whether it is provided in person orvia telehealth or telehealth-like service. Zero pay services would continueto get recorded for data and cost reports.

Source: Source: Provider Telehealth or Telephonic Health Services FAQs, Cabinet for Health and Family Services, Department for Medicaid Services, March 25, 2020

Wrap Payments for FQHCs and RHCs

WellCare’s experience is that wrap should be adjudicated for FQHCs and RHCs billing with place of service 02 (zero two). We have providers who confirm they have been paid wrap in the past when billing with place of service 02 (zero two).

FQHCs and RHCs: Distant Site

Currently, FQHCs and RHCs cannot be thedistant site for telehealth services.

Source: https://www.cms.gov/media/125181

https://www.cms.gov/media/125181

Billable Medicare Codes

List of services payable under the Medicare Physician Fee Schedule when furnished via telehealth:

Source: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes

https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes

RHC and FQHC Medicare Information

https://www.cms.gov/Center/Provider-Type/Federally-Qualified-Health-Centers-FQHC-Center

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/RuralHlthClinfctsht.pdf





Other Medicare Informationhttps://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/TelehealthSrvcsfctsht.pdf

https://www.cms.gov/files/document/provider-enrollment-relief-faqs-covid-19.pdf

https://www.cms.gov/files/document/MM11560

https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet

https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf





Medicare Information from DMSDMS Website Medicare Information Links



SourcesCMS RHCs and FQHCs Sources:





SourcesCMS Additional Medicare Sources:















SourcesDMS Sources:






Provider Telehealth or Telephonic Health Services FAQs, Cabinet for Health and Family Services, Department for Medicaid Services, March 19, 2020

Provider Telehealth or Telephonic Health Services FAQs, Cabinet for Health and Family Services, Department for Medicaid Services, March 25, 2020

All Behavioral Health Providers, Provider Letter # A-106, Cabinet for Health and Family Services, Department for Medicaid Services: Lisa D. Lee, Wendy Morris, March 17, 2020






Will these changes be permanent?

Currently, DMS plans to restrict telehealth to previousrequirements after this current emergency has ended.However, DMS will carefully consider any newdevelopments and innovations in service delivery thatoccur during this time and may expand currentregulations or interpretations to encourage any newefficiencies that are discovered. When possible, DMSencourages providers to carefully document newapproaches and efficiencies that improve outcomes andhealth of our members for future study.


Questions

Thank you!

Documents

Targeted Case Management · 27/03/2020 · The contents of this presentation are based on the most recent information we have available from the Department of Medicaid Services (DMS)