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Provider Quick Tips #242: Telemedicine Guidelines Related to COVID-19 

Updated: June 21, 2021; Issued: April 20, 2020

On March 6, 2020, Governor Wolf issued an emergency disaster declaration in response to the presence of the COVID-19 (coronavirus) in Pennsylvania. Pursuant to this disaster declaration, the Department of Human Services (DHS) issued Provider Quick Tip # 229 related to telemedicine. This Quick Tip updates the information included in that guidance. 

The Office for Civil Rights (OCR) of the Department of Health and Human Services (HHS), has announced that during the COVID-19 pandemic it will exercise its enforcement discretion with respect to compliance with the Health Insurance Portability and Accountability Act (HIPAA) rules. Practitioners may provide services via applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, Zoom, or Skype. If a provider chooses to use a non-public facing audio or video communication product, there will not be a penalty for noncompliance with the HIPAA rules when a provider acts in good faith in the provision of services using telemedicine. Providers should notify patients prior to the start of the service that these third-party applications potentially introduce privacy risks, and 

providers should enable all available encryption and privacy modes when using such applications. 

The Pennsylvania Department of State (DOS) issued guidance advising out-of-state providers that they can apply for licensure in Pennsylvania and receive expedited review of their application if they are licensed in good standing in another state for the purpose of rendering services to Pennsylvanians via telemedicine. The MCOs may pay out-of-state providers as out-of-network without the need for the provider to enroll in the Medical Assistance (MA) Program. 

Services may be rendered via telemedicine to a beneficiary who is remotely located from the rendering provider, such as at their home, in a nursing facility, or in an alternative service site. As also set forth in the March 17, 2020, Telemedicine Guidelines, during the period of the emergency disaster declaration, telephone-only services may be utilized in situations where video technology is not available. 

Effective immediately, Pennsylvania’s MA fee-for-service program will cover services provided via telemedicine rendered under the following circumstances: 

    • The service is rendered by one of the following provider types: 
        • 01: Inpatient Facility – ONLY for Specialty Code 183 (Hospital Based Medical Clinic) 
        • 05: Home Health – ONLY for face-to-face initial certification and recertification visits (Added 4-9-2020) 
        • 06: Hospice – ONLY for face-to-face initial certification and recertification visits (Added 4-9-2020) 
        • 08: Clinic 
        • 09: Certified Registered Nurse (Expanded 4-9-2020) 
        • 11: Mental Health/Substance Abuse – ONLY for Specialty Code 116 (Licensed Clinical Social Worker). Guidance issued by the Office of Mental Health and Substance Abuse Services applies to this provider type and may include requirements in addition to those included in this Ops Memo. (Added 4-9-2020) 
        • 14: Podiatry (Added 4-9-2020) 
        • 16: Nursing (Added 4-9-2020) 
        • 17: Therapist – Guidance issued by the Office of Child Development and Early Learning applies to this provider type and may include additional requirements. (Expanded 4-9-2020) 
        • 19: Psychologist – Guidance issued by the Office of Mental Health and Substance Abuse Services applies to this provider type and may include additional requirements. (Added 4-9-2020) 
        • 20: Audiologist – ONLY for Specialty Code 592 (Early Intervention Services) (Added 4-9-2020) 
        • 21: Case Manager – Guidance issued by the Office of Mental Health and Substance Abuse Services applies to this provider type and may include additional requirements. Guidance issued by the Office of Child Development and Early Learning applies to this provider type and may include additional requirements. (Added 4-9-2020) 
        • 27: Dentist – ONLY for Procedure Codes D0140 (limited oral evaluation) and D9995 (teledentistry – synchronous, real-time encounter) (Added 4-9-2020). Please refer to Provider Quick Tip # 237 for additional guidance. 
        • 31: Physician (Physician’s Assistants may provide services under the usual direction of their supervising physician) 
        • 33: Certified Nurse Midwife 
    • The service is rendered in conformance with the full description of the procedure code, in a clinically appropriate manner, and to the extent that it would have been rendered if the visit had occurred in person. 

Guidance regarding the use of COVID-19 CR modifiers and DR condition codes is forthcoming. Once guidance is issued, these CR modifiers and DR condition codes should be used as appropriate on claims for services provided due to the COVID-19 virus. 

This guidance will remain in effect for the duration of the Federal PHE related to the COVID-19 virus. DHS may re-issue these guidelines as appropriate. 

Additional information is also available on the CDC website and through CMS

Information on MA Program coverage related to COVID-19, to include an FAQ document, can be found on the Department of Human Services website

The Pennsylvania Department of Health has a dedicated page for COVID-19 that provides regular updates. Click here for the most up to date information regarding COVID-19.