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PANDEMIC UPDATE: When will Emergency Policies Expire

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Tuesday, May 19, 2020

This is a continuation of my messages to you regarding the ongoing changes occurring in the insurance/healthcare regulation world in response to the COVID-19 crisis. My previous updates which can be found by clicking here

OPA is currently maintaining an information hub, which can be found by clicking here.

APA also is currently maintaining an information hub, which can be found by clicking here.

Many members seem now to have a better understanding of current issues with delivering and billing teletherapy services during the current crisis. I encourage everyone to look back at my previous updates if you still have questions about this. I am now receiving questions regarding current emergency policies many insurance entities now have in place. Misconceptions and confusion exist regarding when these policies will expire and what may be allowed by the various insurance entities once these emergency policies are no longer in effect. In my last update, I stated most insurance companies were already covering telehealth (teletherapy) before the current circumstance. The emergency, temporary policies implemented by most pertain to relaxing restrictions for telehealth delivery which were part of their standard, ongoing policies. These included requirements such as making attestations directly with the company, requiring the use of company's web-based telehealth platforms, requiring therapy sessions to use visual as well as auditory connections, etc. Once the recently issued emergency policies expire, it is highly likely the company or entity will revert to their previous policy, which for most allowed teletherapy within the parameters of those former restrictions. For some of these former restrictions, our current circumstance likely prohibits their active implementation. For example, some companies required the use of the company’s special web-based platform. It is quite unlikely these platforms have the capacity to meet the current demand brought about by the crisis. Therefore, the current demand would need to be reduced considerably before this older requirement could be put back in place. 

Most of the new, emergency policies were identified as having specific expiration dates. I identify these dates for each entity I am aware of below. In some cases, the expiration is set to coincide with the current state of emergency declared for the State of Ohio by the Governor or nationally by the President. A state of emergency has been declared on both levels with no official expiration in sight. Other entities, mostly private companies, give expiration dates as a part of the policy. However, these dates issued by private companies have already been revised more than once. As I monitor the developments from most of these companies, I find them to be actively responding to the crisis circumstances as they unfold, revising their policies to adapt to the need and demand as it evolves. Among other things, this means that for those companies who have emergency policy expiration dates rapidly approaching, I believe it is highly likely they will revise the date. (In the case of Optum, for example, this has happened twice already). 

These are the current emergency policy expiration dates I am aware of as of today, May 19, 2020:

  • Anthem—June 19
  • Cigna-- May 31
  • Medical Mutual— the policy will be in effect “during the current state of emergency in Ohio.”
  • Aetna-- August 4
  • Medicare—" . . . through the end of the [national] emergency declaration.”
  • Optum—“This change in policy is effective until May 31, 2020, but we may extend that date as necessary and will communicate through all appropriate channels.”
  • Medicaid— ” . . . for the duration of the state of emergency [in Ohio].

I will continue to report updated information as I become aware of it.

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Pandemic Update: How Long Will the Emergency Adaptations Last

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Wednesday, April 22, 2020

This is a continuation of my messages to you regarding the ongoing changes occurring on the insurance/healthcare regulation world in response to the COVID-19 crisis.  My previous updates which can be found by clicking here

OPA is currently maintaining an information hub, which can be found by clicking here.

APA also is currently maintaining an information hub, which can be found by clicking here.

I was recently asked a question regarding the sweeping emergency adaptations taking place with insurance company policies and regulations.  Specifically, the member asked whether it was likely the insurance companies would continue to cover teletherapy sessions after April 30, which is a question I'm sure many of you have.  This was my response:

"Most insurance companies were already covering telehealth (teletherapy).  The emergency, temporary policies implemented by most pertain to relaxing restrictions for telehealth which were part of their standard, ongoing policies.  These included requirements such as making attestations directly with the company, requiring the company's web based telehealth platforms, requiring therapy sessions to be visual as well as auditory connections, etc.  Most of the new, emergency policies were identified as having specific expiration dates.  I am more typically seeing these policies set to expire somewhere late May or mid June.  The soonest, Optum, is set to expire April 30.  However, theirs was one of the earliest issued, and the policy specifically states " . . . but we may extend that date as necessary and will communicate through all appropriate channels."  In general, most of these companies appear to be monitoring and responding to circumstances as they are rapidly developing."

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Pandemic Update: Waived Copays and Deductibles for Telehealth Treatment

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Monday, April 6, 2020

This is a continuation of my messages to you regarding the ongoing changes occurring on the insurance/healthcare regulation world in response to the COVID-19 crisis.  My previous updates which can be found by clicking here

OPA is currently maintaining an information hub, which can be found by clicking here.

APA also is currently maintaining an information hub, which can be found by clicking here.

A member recently asked for more information on which companies are promising to waive copays and deductibles for relevant telehealth treatment during this crisis time.  I will include all information I have received thus far on this topic here.  I also understand that the information I am giving in my updates will sometimes be contradicted by the telephone representatives from the respective insurance companies.  I ask you to bear in mind most of my information comes from medical directors, network managers, and official bulletins from the companies.  It may be that telephone representatives from the companies have not been updated.

Medical Mutual

Medical mutual recently released an FAQ document updating their policy, which includes the following information: 

“During the current state of emergency in Ohio, Medical Mutual is waiving the requirement that telehealth (telemedicine) visits have a visual encounter. Therefore, telephonic visits, in addition to web or app, will be covered at this time.”

“During the current state of emergency in Ohio, Medical Mutual is waiving the requirement that an initial behavioral health visit be done in person before visits can be conducted via telehealth (telemedicine).”

“Individual therapy can be conducted by a provider to their patients. During the current state of emergency in Ohio, Medical Mutual is waiving the requirement that an initial behavioral health visit be done in person before visits can be conducted via telehealth (telemedicine). At this time, we are also waiving the requirement that telehealth (telemedicine) visits have a visual encounter. Therefore, telephonic visits, in addition to web or app, will be covered.”

No information regarding waiving of copays or deductibles for behavioral health is available.

Cigna

Please refer to previous updates.  Teletherapy is permitted, no attestation is currently being required, and telephone only sessions are permitted.  I have received no information on waiving copays or deductibles.  The following coding guidelines should be used:

  • Appropriate Current Procedural Technology® (CPT®) code in Field 24-D for the service(s) provided
  • Modifier 95** in Field 24-D to specify telehealth (see sample claim form below)
  • Place of Service 02 in Field 24-B (see sample claim form below)

Anthem

Please refer to previous postings regarding this company.  They are still in effect.  In addition, Anthem gives the following guidance:

Effective March 17, 2020, Anthem’s affiliated health plans will waive member cost share for telehealth (video + audio) visits, including visits for behavioral health, for our fully-insured employer plans, individual plans, Medicare plans and Medicaid plans where permissible for 90 days. Cost sharing will be waived for members using Anthem’s telemedicine service, LiveHealth Online, as well as care received from other providers delivering virtual care through internet video + audio services. Self-insured plan sponsors may opt out of this program.

Effective March 19, 2020, Anthem will cover telephone-only medical and behavioral health services from in-network providers and out-of-network providers when required by state law for 90 days. Anthem will waive associated cost shares for in-network providers only except where a broader waiver is required by law. Exceptions include chiropractic services, physical, occupational, and speech therapies. These services require face-to-face interaction and therefore are not appropriate for telephone-only consultations. Self-insured plan sponsors may opt out of this program
.

Optum

Starting March 31, 2020 until June 18, 2020, United Behavioral Health (dba Optum Behavioral Health) will waive cost-sharing for in-network, outpatient, behavioral health telehealth visits for members of Medicare Advantage, Medicaid and fullyinsured Individual and Group market UnitedHealthcare (UHC) health plans. We will work with all health plans and self-funded customers who want us to implement a similar approach. Providers are encouraged to confirm member benefits and coverage provided by their health plan at the time of service due to the rapidly changing situation. This updated policy applies to members of Medicare Advantage, Medicaid and Individual and Group market health plans issued by UnitedHealthcare. Providers that treat members of Medicare Advantage, Medicaid and fully-insured Individual and Group market health plans issued by UnitedHealthcare and administered by Optum Behavioral Health do not have to collect co-pays from fully insured UHC plan members effective March 31, 2020 through June 18, 2020. Again, please confirm the member’s benefits at the time of service due to the rapidly changing situation. Out-of-Network member benefits and cost-sharing will apply, as applicable, according to plan terms. Check out the latest telehealth policy updates for behavioral health services, reimbursement and coding guidelines and member cost sharing updates and resources at our new COVID-19 Provider Hub on Provider Express here.

Billing guidelines: Optum Behavioral Health will reimburse telehealth services which use standard CPT codes and a GT modifier or a Place of Service of 02 for both video-enabled virtual visits and telephonic sessions to indicate the visit was conducted remotely.

Medicare

All previously posted guidance still applies, with this update I just received from APA.  This is new blling guidance for Medicare only:

The Centers for Medicare and Medicaid Services (CMS) has once again issued new guidance on the delivery of health care services during the COVID-19 public health emergency. Effective March 31, 2020 providers furnishing services through telehealth should use the place of service that would have been reported if the service was being furnished in-person. CMS is making this change to identify when it is appropriate to pay a non-facility fee, rather than a facility fee which would have automatically been included under POS 02. 

To illustrate, a psychologist who would have seen patients in a private office should use POS 11. Those who would have treated the patient in a clinic or skilled nursing facility should use the appropriate POS. All claims for telehealth services should now include modifier 95.

While phone only psychotherapy continues to be prohibited by Medicare (a real concern for many of us), phone-only billing codes are available for more limited interventions.  More information on this can be found here:
https://www.apaservices.org/practice/clinic/covid-19-audio-only-phone-service-codes

BWC (updated provide by Dr. David Schwartz, OPA Chair BWC Task Force)

As previously posted by OPA’s BWC lead, Dr. David Schwartz

  1. They will allow telephone-only sessions as psychotherapy (which has to be pre-authorized as per their normal rules0 but will not pay it at psychotherapy rates. They want us to use phone consultation codes which pay MUCH less). Obviously this isn’t good and any strategies to encourage them would help- my thought is that if Medicare gets on board that would be a strong comeback.
  2. They have dropped the ‘no smartphone” rule and will allow their use in teletherapy.
  3. They don’t see a need to develop telemedicine IMEs, feeling they have enough evaluators willing to do face to face. I personally think that is a bad idea and contrary to best practices in terms of minimizing exposure. Not sure how hard to come back on that one -a big concern is that too many of their evals are done by a small group of folks who make that their primary practice and do a poor job- they were on our radar before the sudden appearance of all these alligators.

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Pandemic Update: Emergency and Temporary Regulations

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Tuesday, March 31, 2020

I am posting the most up to date information I have regularly on the many, ongoing changes which are affecting our practice. These changes are quickly emerging from the insurance industry, the Center for Medicare and Medicaid Services, the State of Ohio, and our federal government.  My updates are posted here on this listserv, are being blast emailed to all Ohio psychologists, and may be found on the OPA website here:

https://ohpsych.org/blogpost/1567785/Director-of-Professional-Affairs-Blog

I am making every effort to keep this as up to date as possible, and it may be helpful to take a few minutes to read through the five most recent posts (starting from 3/16/20).  Guidance on many of the issues discussed on this thread may be found there.

APA is also presently offering a resource page on similar issues: https://www.apaservices.org/practice/clinic/

A very brief summary: many insurance companies have issued emergency, temporary regulations for the provision of teletherapy.  Many former guidelines which were stricter have been relaxed.  Teletherapy sessions are billed using the same CPT Codes as face to face therapy, using the place of service code "02" (teletherapy) and a modifier, either "GT" or "95."  Most companies have temporarily relaxed the restriction which requires teletherapy connection be both video and audio.  As of the time of this email, Medicare has not, and continues to require our connections to be both video and audio.  Medicaid, which is administered through the State of Ohio, has created new rules which do allow for audio connection (phone) only.

As I am sure you are aware, we are living in very tumultuous times.  As part of my role with OPA, I am spending hours and days connecting with multiple information sources tracking and organizing the most recent, useful information for you.  If you obtain newer, recently issued information, I urge to carefully vet it before disseminating.  To do otherwise could add to the current confusion (which is considerable).  However, the best strategy would be to email me the newer information directly, and I will help ascertain its accuracy and usefulness.


Jim Broyles, PhD
Director of Professional Affairs, Ohio Psychological Association

 

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Pandemic Update: HIPAA Compliant Technology for Communication

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Tuesday, March 24, 2020

This is an update of my messages to you regarding the ongoing changes occurring on the insurance/healthcare regulation world in response to the COVID-19 crisis.  This is a continuation of my previous updates which can be found here: https://ohpsych.org/blogpost/1567785/Director-of-Professional-Affairs-Blog

A more general crisis resource page can be found here: https://ohpsych.org/page/PandemicResources

The Ohio Governor has issued a stay at home for Ohio residents.  Individuals are still permitted to leave their homes to visit health care professionals.  Our work as mental health and substance use providers is considered an essential activity and is permitted to continue to operate.

I am seeing many questions and requests regarding HIPAA compliant technology for communication with clients who are homebound.  In a previous update, I reported the Department of Health and Human Services website states right now it “will waive potential penalties for HIPAA violations against health care providers that serve patients through everyday communications technologies during the COVID-19 nationwide public health emergency.”   The best advice we are receiving from APA in on interpreting this statement is 1) make a good faith effort to secure a HIPAA compliant means of communication and 2) if none is available connect with your client via other available means.  I believe at this point the best direction we are being given is to make the well being of our clients be our highest priority.

While some definitions of teletherapy include audio only means of interacting with clients, many insurance company regulations have typically required the connection to be both visual and audio.  Due to the circumstance of so many individuals having more sophisticated electronic communications unavailable to them and being reachable only by phone, many insurance companies have been adapting their regulations, allowing audio only (cell/telephone) connections to conduct therapy.  In past updates I have documented companies who have made these revisions in their regulations and am including more here.

MEDICAID

The Ohio Department of Medicaid recently passed temporary, emergency rules. (It will also be made available on OPA’s resource webpage).  The rules make allowance for the audio only connection as well give specific definitions for the patient site and practitioner site.

CIGNA

Cigna has also issued a recent revision of their policy:

As a general requirement, Cigna-participating outpatient providers must complete an attestation to deliver telehealth sessions. During this interim period, however, telehealth attestations are not required. Please note that regardless of your attestation status, it is expected that you use a secure platform to deliver services and follow all Health Insurance Portability and Accountability Act (HIPAA) requirements.

While telephonic sessions are not typically covered in accordance with our Medical Necessity Criteria, we are making an exception during this interim period. You may provide telephonic sessions to patients who do not have access to technology to participate in telehealth sessions, as appropriate.

MEDICARE

As of this posting I have received no update on changes to Medicare beyond those in my 3.20.20 update.  Many of you have expressed concern regarding Medicare recipients who reachable only by phone.  I have heard that many of you have reached to your current members of Congress to advocate for a change with this issue.  My hope is that this proves effective.

EMERGENCY LICENSURE

 Many of asked about reaching client who are quarantined in other states.  Clearly, only psychologists who are licensed to practice in other states are permitted to provide psychological services there.  At this point, many states have created emergency orders and procedures for allowing temporary licensure in those states.  ASPPB is doing a good job of tracking those states who have made such provisions, and that information may be obtained here: https://www.asppb.net/page/covid19

The Ohio Board of Psychology also has created similar emergency rules and procedures for psychologists licensed in other states.  They may be found here:
https://psychology.ohio.gov/Applicants/Nonresident-Temporary-Permission-to-Practice

I will continue these updates as information becomes available to me.

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Pandemic Update: HIPAA Compliant Technology for Communication

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Tuesday, March 24, 2020

This is an update of my messages to you regarding the ongoing changes occurring on the insurance/healthcare regulation world in response to the COVID-19 crisis.  This is a continuation of my previous updates which can be found here: https://ohpsych.org/blogpost/1567785/Director-of-Professional-Affairs-Blog

A more general crisis resource page can be found here: https://ohpsych.org/page/PandemicResources

The Ohio Governor has issued a stay at home for Ohio residents.  Individuals are still permitted to leave their homes to visit health care professionals.  Our work as mental health and substance use providers is considered an essential activity and is permitted to continue to operate.

I am seeing many questions and requests regarding HIPAA compliant technology for communication with clients who are homebound.  In a previous update, I reported the Department of Health and Human Services website states right now it “will waive potential penalties for HIPAA violations against health care providers that serve patients through everyday communications technologies during the COVID-19 nationwide public health emergency.”   The best advice we are receiving from APA in on interpreting this statement is 1) make a good faith effort to secure a HIPAA compliant means of communication and 2) if none is available connect with your client via other available means.  I believe at this point the best direction we are being given is to make the well being of our clients be our highest priority.

While some definitions of teletherapy include audio only means of interacting with clients, many insurance company regulations have typically required the connection to be both visual and audio.  Due to the circumstance of so many individuals having more sophisticated electronic communications unavailable to them and being reachable only by phone, many insurance companies have been adapting their regulations, allowing audio only (cell/telephone) connections to conduct therapy.  In past updates I have documented companies who have made these revisions in their regulations and am including more here.

MEDICAID

The Ohio Department of Medicaid recently passed temporary, emergency rules. (It will also be made available on OPA’s resource webpage).  The rules make allowance for the audio only connection as well give specific definitions for the patient site and practitioner site.

CIGNA

Cigna has also issued a recent revision of their policy:

As a general requirement, Cigna-participating outpatient providers must complete an attestation to deliver telehealth sessions. During this interim period, however, telehealth attestations are not required. Please note that regardless of your attestation status, it is expected that you use a secure platform to deliver services and follow all Health Insurance Portability and Accountability Act (HIPAA) requirements.

While telephonic sessions are not typically covered in accordance with our Medical Necessity Criteria, we are making an exception during this interim period. You may provide telephonic sessions to patients who do not have access to technology to participate in telehealth sessions, as appropriate.

MEDICARE

As of this posting I have received no update on changes to Medicare beyond those in my 3.20.20 update.  Many of you have expressed concern regarding Medicare recipients who reachable only by phone.  I have heard that many of you have reached to your current members of Congress to advocate for a change with this issue.  My hope is that this proves effective.

EMERGENCY LICENSURE

 Many of asked about reaching client who are quarantined in other states.  Clearly, only psychologists who are licensed to practice in other states are permitted to provide psychological services there.  At this point, many states have created emergency orders and procedures for allowing temporary licensure in those states.  ASPPB is doing a good job of tracking those states who have made such provisions, and that information may be obtained here: https://www.asppb.net/page/covid19

The Ohio Board of Psychology also has created similar emergency rules and procedures for psychologists licensed in other states.  They may be found here:
https://psychology.ohio.gov/Applicants/Nonresident-Temporary-Permission-to-Practice

I will continue these updates as information becomes available to me.

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Pandemic Update: Telephone (Audio Only) Psychotherapy Sessions

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Friday, March 20, 2020

I want to give an update on the latest information I have as a continuation of my updates from 3/15 and 3/17. OPA now has a Pandemic resource page on our website: https://ohpsych.org/page/PandemicResources

All past my past updates are located here:
https://ohpsych.org/blogpost/1567785/Director-of-Professional-Affairs-Blog

One of the most significant questions on everyone’s mind is the use if telephone (audio only) to conduct psychotherapy sessions.  As I mentioned previously, our regulations come from a variety of sources.  Some definitions of teletherapy may include audio only, but typically regulations from insurance entities do not.  In the last few days I have seen the insurance companies working quickly to revise many of their policies regarding teletherapy, and some are including telephone sessions in their definitions, at least temporarily.  My hope is that more insurance entities will follow suit in the coming days.

As I reported previously, Medicare has lifted some restrictions on teletherapy, allowing more recipients to receive services via teletherapy (see my last update).  However, they continue to require the connection used to be audio as well as video.  APA and NASW very recently sent a letter to CMS imploring them to relax this restriction to permit audio only.  Also, many are aware of the Medicare requirements for supervised services. CMS stipulates that for services billed to Medicare which are delivered using a supervisee, the supervisor must be physically present in the office suite for help if needed.  This requirement has not changed.  

I have been able to make contact directly with a Medical Mutual representative who was able to supply me with their policy.  They do cover teletherapy, and there are no other specific requirements other than the billing procedures (below).  Audio only sessions are not considered a part of their teletherapy definition.  

Anthem Blue Cross/Blue Shield recently issued this update, which permits audio only sessions.  From their FAQ document:
Anthem covers telehealth (i.e., video + audio) services for providers who have access to those platforms/capabilities today.

Effective March 17, 2020, Anthem’s affiliated health plans will waive member cost share for telehealth (video + audio) visits, including visits for mental health, for our fully insured employer plans, Individual plans, Medicare plans and Medicaid plans where permissible for 90 days. Cost sharing will be waived for members using Anthem’s telemedicine service, LiveHealth Online, as well as care received from other providers delivering virtual care through internet video + audio services. Self-insured plan sponsors may opt out of this program.
 
Will Anthem cover telephone only services in addition to telehealth via video + audio?
Anthem does not cover these services today (with limited state exceptions) but we are providing this coverage for 90 days effective March 19, 2020, to reflect the concerns we have heard from providers about the need to support continuity of care for Plan members during extended periods of social distancing. Anthem will cover telephone-only medical and behavioral health services from in-network providers and out-of-network providers when required by state law. Anthem will waive associated cost shares for in-network providers only except where a broader waiver is required by law.

Aetna continues to be difficult for me to contact.  Fortunately, the Directors of Professional Affairs throughout the country maintain a good network of interconnection.  My counterpart in Utah was able to forward information she received from her contact with the company.  I received the following:

Aetna – Aetna has waived the requirement for patients to use their preferred vendor, TelADoc. All contracted providers are eligible to provide virtual visits for Commercial Plan members for the next 90 days. Self-insured plans do have the option to opt-out of this program so we will still want to verify policies prior to rendering service. 

At one point, there was a question about their teletherapy provider requirement, which was restricted to one platform, TelaDoc.  It would appear at this point that restriction has been lifted, and all providers are being made eligible to provide teletherapy services.

As mentioned in my last updates, when billing teletherapy services, the procedure remains the same for all entities: the CPT Code continues to be the same as that used for face to face therapy.  However, the claim must report place of service as “02” and include the modifier “95” or “GT.” 

APA is offering some great teletherapy resources:

OPA resource page:
https://ohpsych.org/general/custom.asp?page=PandemicResources

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Pandemic Update: Telepsychology, HIPAA and Medicare

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Wednesday, March 18, 2020

This is my effort to keep you updated with my work on your behalf, as promised during my last message on 3/15/20.  Most of my day today has been spent gathering information from members, my insurance contacts, the Ohio Board of Psychology, and APA. As I am sure most of you are aware, our circumstance is changing very quickly, and the messages I receive are often conflicting and confusing. My strategy at this point is to tell you what I know for sure, what I think could be coming, and what we do not know. My thought is if I continue to this process frequently, the confusion may eventually clear.

I ask you to keep in mind the rules and restrictions which govern the delivery of our services come from multiple sources, including state law, federal law, and insurance company policy and regulation. Each of these can interact with one another in a complex way which adds to the confusion. This means that, as the circumstances evolve, few are completely clear on the full implications for our work.

At this point, as far as I know, all rules governing psychologists as telepsychology providers remain in place. We have received word (as many of you have heard) that Governor DeWine has issued an emergency order to “reduce restrictions on telehealth.” This could have implications for our board rules or might also have implications for insurance company restrictions. Dr. Ron Ross of the Ohio Board of Psychology and I have been in communication regarding this and unfortunately have been able to obtain very little information on the details of this order. (I’m sure they are very busy right now).

It would also appear that that federal entities have relaxed HIPAA restrictions during the crisis. The Health and Human Services website states it “will waive potential penalties for HIPAA violations against health care providers that serve patients through everyday communications technologies during the COVID-19 nationwide public health emergency.”  Presently the APA Department of Legal and Regulatory Affairs are at work on defining the implications of this for psychologists, and we hope to have an update tomorrow. This may mean that HIPAA compliant platforms are not necessary for connecting with your client during the crisis. 

In my last message I mentioned that Medicare enforces strict regulations on the delivery of teletherapy services, and that an emergency law was passed by Congress to allow the Secretary of Health and Human Services to relax these standards, and the change was awaiting his approval. That approval has been granted. According to the CMS website: “Under this new waiver, Medicare can pay for office, hospital, and other visits furnished via telehealth across the country and including in patient’s places of residence starting March 6, 2020.” 

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

Stay tuned for more guidance from APA on this also. 

Optum’s (UHC/UBH) website is now stating: Telephonic Care: For members or providers who do not have access to HIPAA-approved technology required to conduct a video-enabled virtual session, we will now accept telephonic sessions.”  My hope is that other insurance companies may follow this lead, but no other has created a similar policy as far as I know. 

Cigna has confirmed that teletherapy is permitted for many of their plans, and an attestation is required. Click here to view a flier that I received from their medical director. Many members have verified that Medical Mutual is covering teletherapy session, but my efforts to contact them have received no response. (Again, I’m sure they are very busy).  As I receive more details from these companies, I will share with you. 

If any of you have more information to add, please email me directly and I will do my best to verify the information and keep you updated.

Jim Broyles, PhD
Director of Professional Affairs
Ohio Psychological Association
395 E. Broad St. Suite 310 | Columbus, Ohio  43215 | 614-266-1301

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Pandemic Update: Telepsychology

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Monday, March 16, 2020

In response to the current, evolving pandemic situation, many of you have been asking about the use of telepsychology and related insurance regulations. Dr. Jim Broyles, OPA Director of Professional Affairs, has spent considerable time gathering information for you and will undoubtedly continue to do so over the course of the next several days and weeks. His intention is to give you as much information as is available at this time. He asks that you understand that additional and updated information is highly likely given the fact that circumstances are evolving very quickly. OPA and Dr. Broyles will work to provide updates on a regular basis.

TELEPSYCHOLOGY TRAINING

Please consider that offering psychotherapy via an electronic platform (telepsychology) is considered a specialty area by our Ohio Board of Psychology and should be undertaken by those psychologists who have completed the training requirements and are legally and ethically competent to deliver these services. We are aware of a very recent news story stating, “. . . Ohio Governor Mike DeWine announced he has filed emergency rules for complete mental health telehealth coverage.” We do not know the implication of this for these Board of Psychology requirements nor for insurance entities. Information on this will be one of the updates provided as it becomes available. For those interested in getting up to speed on telepsychology training, a number of training resources are available online. While it is very difficult here to be definitive regarding which sources of training suffice to make one competent in this area, our OPA telepsychology experts offer guidelines in what good training should cover. Click on the following links to access summary documents from APA and OPA.

Dr. Ron Ross of the Ohio Board of Psychology recently issued a statement regarding contact with clients which falls outside the parameters of treatment defined as telepsychology:

“[Ohio rules give] . . . license holders authority to use their judgment about when a client requires extra support between appointments without having to document all the processes in the telepsychology rules. Therefore, the rule authorizes inter-session telecommunications to manage crises even by license holders who do not necessarily “practice” telepsychology. With the evolving landscape of illness, social distancing, quarantines, and the risk of increased anxiety and other psychological symptoms, it is reasonable for license holders to interpret “ensuring client welfare” broadly, given our dramatic shift in context. Specifically, license holders may judge, on a case-by-case basis, that client welfare and continuity of care requires temporary, judicious use of telephone sessions when the client and license holder are prohibited from meeting in-person because of efforts to contain COVID-19. This temporary leeway is rooted in a specific context and is not to be used as a basis to undertake routine use of telecommunications by exemption from the telepsychology rules for reasons unrelated to the COVID-19 crisis. License holders who 2 wish to routinely deliver services via telecommunications must establish and maintain telepsychology competence and practice in accord with the telepsychology rules.”

MEDICARE AND MEDICAID

Until recently Medicare has maintained strict rules regarding the use of telepsychotherapy, including limiting service recipients to those individuals located in specific geographic regions as well as requiring that the client be present at their primary care physician’s office to receive the service. Last week, an emergency temporary bill was passed by Congress to lift those restrictions. This bill authorizes the present Secretary of Health and Human Services to lift those restrictions. As of this writing that has not occurred and there may be specific requirement accompanying that change, and OPA will update you as that information becomes available. Also, be aware that Medicare Advantage plans are authorized to provide services that the federal Medicare program does not. Clients who participate in these plans may well be eligible to receive tele-services. At this time, we have no information specific to these plans, but we suspect the allowances are congruent with the company’s non-Medicare plans.

Current rules governing Medicaid allow for “telehealth.” The rules may be found here: http://codes.ohio.gov/oac/5160-1-18v1. Psychotherapy is identified as a covered service within the parameters identified by the rules. Our contact with the Ohio Department of Medicaid has indicated that these rules are currently under revision and that a more definitive guide (which may include a lifting of certain restrictions) will be forthcoming soon. We will pass this along as soon as it is received. Similar to Medicare, Medicaid Managed Care Organizations have more latitude in terms of what they offer than the state program, and our contact with CareSource has assured us that telepsychology services are covered. Unfortunately, we have not received informaton from other Medicaid companies.

PRIVATE INSURANCE

Optum (UHC/UBH) has assured OPA that they encourage telehealth services and even offer an electronic platform for “virtual visits.” Participants in the delivery of these services are asked to sign an attestation. Their policy and directions for complying with requirements may be found here:

https://www.providerexpress.com/content/ope-provexpr/us/en/Important-upates.html

Anthem Blue Cross Blue Shield has stated that telehealth services are allowed with guidelines:

The Provider can utilize their own interface for Telehealth service and are not required to use Live Health Online or any other specific vendor

  • The tool used to provide Telehealth must include both audio and visual connection capabilities, i.e. the physician and patient must both see and hear each other during the interaction.
  • The Provider can bill using their current TINs/NPIs.
  • There is a broad list of services available to be billed via Telehealth, and we follow the Medicare Learning Network (MLN) publication to determine those services.
  • E-consults between physicians are NOT covered via the Telehealth policy. Only member to physician interactions are included.
  • Claims must be billed using POS “02” for Telehealth and using modifiers “GQ”, “GT” or “95”. This requirement is consistent with Medicare. Not using this POS or modifiers will result in post-pay audits and recoveries.
  • Telehealth services will reimburse at rates equivalent to our facility based professional rates (not office based).

The above mentioned MLN publication includes our most used psychotherapy codes.

We are hearing from some very good sources that Medical Mutual allows for telepsychotherapy as a service. We have yet to verify that or know about any specific parameters required by them. Dr. Broyles has a call in to them and will share information as it becomes available. Also, remember when billing telepsychology for any insurance entity, the basic billing procedure is the same: as stated above, the claim must report place of service as “02” and include the modifier “95” or “GT.” These trigger the insurance entity’s system to recognize your claim as being for the telepsychology service. Otherwise, the CPT Code and other information is the same as for face to face services.

Preesently, OPA has no other information about other companies, but we hope to get this soon. If any of you receive information to add to what has been presented here, please reach out to Dr. Jim Broyles directly, especially with a contact person if possible. Keep in mind Dr. Broyles' work with this issue and the information  gathered would not be possible without our staff at APA; an entire network of DPA’s across the country; Dr. Leslie McClure, Christine Taylor, and our other OPA Insurance Committee members, as well as, Dr. Mark Babula, one of OPA’s Telepsychology leads.

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New Parity Bill Introduced - SB 254 / HB 443

Posted By Jim Broyles, PhD, OPA Director of Professional Affairs, Wednesday, February 19, 2020

I have had many discussions over time with OPA members who express frustrations with insurance companies and their negative impact on psychologists’ ability to practice effectively. I often hear about issues such as plans which require excessive deductibles and copays, limitations on allowed diagnoses or number of sessions, or reimbursement rates which make operating a mental health practice financially inviable. At the same time, our association can be quite restricted, for variety reasons, in the avenues available to it for effectively pushing back against these barriers and challenges. However, one potential immediate vehicle for change currently on our horizon is the parity bill recently introduced in our legislature. Parity laws are those which require insurance companies to offer benefits for behavioral health treatment comparable to physical health care. This means that a number of factors, including the quantity and kinds of treatment allowed, required out of pocket expenses, and panel participation adequacy (which is directly associated with reimbursement rates) must be comparable to similar factors on the physical health side of the plans. 

Presently, both federal and state parity laws exist which affect insurance companies providing health plans here in Ohio. Unfortunately, weaknesses exist in the current laws which allow the above difficulties to continue. The current bill (SB 254/HB 443) will establish new standards for those companies who provide health insurance here in Ohio, as well as effective means of measuring compliance with these standards. This bill, should it become law, will be one more step toward a more balanced health care system which recognizes and supports the delivery adequate behavioral healthcare services in our state. 

I often remind our members that the passage of such bills which do not favor our insurance companies can often be an uphill battle. A primary reason for this is the resources available to insurance companies to lobby against such legislation which have no counterpart in our professional association. That means that a bill such as this is far more dependent on grassroot support from individuals. My purpose in writing here is to help OPA members understand the potential impact of this legislation on their professional lives. The next step, however, will be up to individual professionals and Ohio citizens. At the right time, you will receive an Action Alert email from OPA with sample letters asking you to contact your legislature to support this piece of legislation. Please be on the lookout and willing to make our voice heard! 

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