DHS COVID-19 PROVIDER RESOURCES // OMAP
Provider Quick Tips #242: Telemedicine Guidelines Related to
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
- 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
- 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)
o 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
- 19: Psychologist – Guidance issued by the Office of Mental Health and Substance
Abuse Services applies to this provider type and may include additional requirements.
- 20: Audiologist – ONLY for Specialty Code 592 (Early Intervention Services)
- 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)
- 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 while a valid disaster declaration by the Governor related to the COVID19
virus remains in effect. 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.