Pandemic Update: Telepsychology
Monday, March 16, 2020
Posted by: Jim Broyles, PhD, OPA Dir. of Professional Affairs
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.
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.
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:
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.