DHS COVID-19 PROVIDER RESOURCES // OMAP
Managed Care Ops Memo 04/2020-009:
Telemedicine Guidelines Related to COVID-19
Issued: April 15, 2020
Audience
All Physical Health (PH) HealthChoices Managed Care Organizations (MCOs) –
Statewide
Purpose
The Office of Medical Assistance Programs (OMAP) is issuing this Operations
Memorandum to offer clarification regarding the coverage of telemedicine services
rendered to Physical HealthChoices members.
Background
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 and Managed Care Operations Memo 03/2020-03 related to telemedicine. This Managed Care Operations Memo updates the information included in Managed Care Operations Memo 03/2020-03.
The Office for Civil Rights of the Department of Health and Human Services 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.
PH-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. These out-of-state nonparticipating providers must still be licensed to practice in Pennsylvania. The Pennsylvania Department of State 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.
Coverage of Telemedicine Service Related to COVID-19
PH-MCOs may pay for services rendered via telemedicine to a member who is
remotely located from the rendering provider, such as at their home, in a nursing
facility, or in an alternative service site. Telemedicine services may be provided by
any means that allows for two-way, real time interactive communication, such as
through audio/video conferencing. During the period of the emergency disaster
declaration, telephone-only services may be utilized in situations where video
technology is not available. Text-only messaging does not constitute a method of
rendering services via telemedicine.
Pennsylvania’s MA fee-for-service program is covering 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)
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 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.
Next Steps
MCOs must cover services rendered via telemedicine at least to the extent to which
the services are covered in the fee-for-service delivery system. MCOs should
disseminate information to their members and providers about coverage of
telemedicine services and work to ensure that members and providers are aware of
the ways in which they may access these services. MCOs should instruct providers to
bill for services as they would have billed if the services had been rendered in-person.
MCOs should map the place of service as follows, documenting in the notes that the
service was provided via telemedicine:
- Place of Service 02 (Telehealth) should be coded as Place of Service 11
- Place of Service 19 (Off-Campus Hospital) should be coded as Place of Service
22
- Place of Service 20 (Urgent Care) should be coded as Place of Service 11
Obsolete
This OPS Memo supersedes previously issued OPS Memo 03/2020-003 and remains in effect until further notice.