DHS COVID-19 PROVIDER RESOURCES // OMHSAS
COVID-19 Frequently Asked Questions (FAQs)
Issued: March 25, 2020
All Behavioral HealthChoices Managed Care Organizations (BH-MCOs), Fee-For-Service (FFS) Providers, and County Mental Health Authorities – Statewide
The purpose of this memorandum is to issue Frequently Asked Questions
(FAQs) for Behavioral Health Medicaid covered programs related to the COVID-19
disaster emergency declaration.
1. Behavioral Health (BH) providers are concerned about how they will
retain staff during quarantine/outbreaks. Is the Office of Mental Health and
Substance Abuse Services (OMHSAS) taking steps to allow providers to continue
Health care services, including BH services, are lifesustaining services and therefore should remain available. OMHSAS has
released guidance on expanded telehealth services during the emergency
disaster declaration, which will allow staff to continue working during social
distancing and stay at home or shelter in place conditions. The “OMHSAS
COVID-19 Telehealth Expansion” document is available here.
2. Is the Department of Human Services (DHS)/OMHSAS considering
waiving regulations given the disaster emergency declaration declared by the
Yes. OMHSAS is reviewing regulations and policies to
determine which regulations, if any, need to be suspended based on the needs
of our stakeholders. Further guidance will follow on specific regulatory
3. What should be the response if psychiatrists are unavailable due to
Primary contractors and their BH-MCOs should work with
providers to ensure there are plans in place for service coverage, including
psychiatric services, during the disaster emergency declaration period. BH
providers are encouraged to collaborate to ensure psychiatric access during the
emergency disaster declaration period. In addition, the Pennsylvania
Department of State (DOS) has issued suspensions of regulatory requirements
to relax requirements for out-of-state providers to temporarily provide services in
Pennsylvania. The Full PA DOS guidance is available here.
4. Will BH providers who are unable to provide face-to-face services
through the FFS delivery system be able to continue to provide services?
OMHSAS has expanded services that are available
through telehealth. The “OMHSAS COVID-19 Telehealth Expansion” document
is available here.
5. What is the appropriate response if individuals in a residential service
need to be isolated or quarantined?
Counties should have contingency plans in place for
when there is an emergency for residential services. Providers of residential
services should also have emergency plans in place, in coordination with the
counties where they are located. Providers of residential services should
implement their emergency plans. Expanded telehealth services as outlined in
the “OMHSAS COVID-19 Telehealth Expansion” document can also be used to
provide services to individuals in residential settings. For specific
recommendations regarding requirements for isolation, consult the PennsylvaniaDepartment of Health and the Centers for Disease Control and Prevention (CDC).
6. Is the state able to issue waivers regarding requiring face-to-face
contacts for Blended Case Management and allow 100 percent of contacts to be
telephonic during the emergency disaster declaration?
On March 15, 2020, OMHSAS expanded the use of
telehealth to address service issues for the duration of the disaster emergency
declaration. OMHSAS removed the limitations on the number and percentage of
services that can be provided through telehealth. During the disaster emergency
declaration period, telehealth contacts can be counted toward face-to-face
7. Will OMHSAS allow phone-based service provision for psychiatric
Audio-visual technology is the preferred method of
service delivery for the duration of the disaster emergency declaration. However,
if that technology is unavailable, telehealth can be provided by telephone (voice
8. Will OMHSAS be waiving the limits on the number of individuals
permitted to participate in mental health out-patient groups (12) or D&A out-patient
groups (10) due to possible staff shortages?
On March 16, 2020, the White House COVID-19
Taskforce recommended that individuals “avoid gathering in groups of more than
10 people.” In addition, Governor Wolf and the Secretary for PA Department of
Health, issued information to cancel or postpone in-person group events with 10
or more participants. At this time, OMHSAS will not be supporting a waiver for
increased group sizes.
9. Since it is likely that additional coordination will be needed with Physical
Health, will the state allow for reimbursement of coordination activities during the
emergency disaster declaration period?
Coordination activities with physical health continue to be
reimbursable through administrative funds.
10. Question: How can individuals get their medication from the pharmacy if they are
The Office of Medical Assistance Programs (OMAP) is
actively working on ways to increase access to medication from pharmacies.
OMHSAS will provide updates as they become available. All updates for the
Department of Human Services are located here.
11. What if pharmacies begin to run out of medications manufactured
OMHSAS is not aware and does not expect any
medication shortages at this time but will continue to monitor the situation.
12. BH providers are concerned that BH crisis lines (hotlines, peer support
talk lines, warmlines) may be overburdened as anxiety around COVID-19 continues
to grow. Is there consideration on the state level to setting up a warmline for
individuals to call who have Coronavirus concerns?
OMHSAS is monitoring the volume of calls received on
BH crisis lines and will consider the need for setting up a warmline. There are
several support lines available, including:
- • SAMHSA Disaster Distress Line: 1-800-985-5990 or text “TalkWithUs” to
- Crisis Text Line: Text “PA” to 741741
- Optum Public Crisis Line: 866-342-6892
13. Can the timeliness for member notification related to denial of services,
complaints and grievances be modified?
The Department is seeking a waiver of some of the
requirements associated with the complaint and grievance requirements. As with
any identified emergency in which it is determined that requirements need to be
modified due to a safety concern, OMHSAS will support the decision of the
Primary Contractor/BH-MCO to implement its emergency plan that may include
initiating alternative practices in the interim of approval of a waiver. Any
modifications implemented, and the reason for the modifications, need to be
clearly documented in every Complaint/Grievance case record in which the
modification was implemented, including documentation that this was
communicated with the member. Additionally, although prior OMHSAS approval
is not necessary, the OMHSAS Quality Assurance Risk Management (QARM)
Director (Jocelyn Maddox) and the appropriate QARM coordinator needs to be
notified of these modifications.
14.Will in-person complaint/grievance panel requirements be waived?
As with any identified emergency in which it is determined
that requirements need to be modified due to a safety concern, OMHSAS will
support the decision of the Primary Contractor/BH-MCO to implement its
emergency plan that may include initiating alternative practices in the interim of
approval of a waiver. As per Appendix H, OMHSAS permits panels to meet
telephonically. Videoconference or telephonic reviews must be offered if an inperson review cannot be accommodated when requested by the member. Any
modifications, and the reason for the modifications, need to be clearly
documented in every Complaint/Grievance case record in which the modification
was implemented, including documentation that this was communicated with the
member. Additionally, although prior approval is not necessary, the OMHSAS
QARM Director (Jocelyn Maddox) and the appropriate QARM coordinator needs
to be notified of these modifications.
15. Will a monetary stipend for telephonic attendance be allowable?
OMHSAS has not issued any requirements on monetary
stipends for individuals participating in a Complaint/Grievance hearing. This is a
business decision of the Primary Contractor/BH-MCO.
16.Does the temporary telehealth expansion also apply to Drug & Alcohol
Yes, the temporary measures outlined in OMHSAS
Memorandum dated 03/15/20 “Telehealth Guidelines Related to COVID-19”
apply to mental health as well as D&A services provided to Medical Assistance
17. Will Alternative Payment Arrangements (APA’s) be permitted to help
support and sustain providers during the emergency and will their approval be
APA’s consistent with the HealthChoices Behavioral
Health Agreement Section II-7.M.3, will be reviewed on a case by case basis and
approved as appropriate within 24 hours to help support and sustain providers
during the emergency.
18. Will there be flexibility in the review of HealthChoices Reinvestment
Plans to allow funding for the purchase of secure telehealth equipment and software,
or third-party contracts for these services?
19. Will Reinvestment Plans that outline assistance in emergency solvency
plans be acceptable during this emergency?
Reinvestment requests outlining assistance in emergency
solvency plans received during this time will be reviewed on a case by case basis
and approved as appropriate and as quickly as possible.
20. During this time of reduced outpatient clinic activity there is a
corresponding reduction in revenue. Some clinics are asking if there is a problem
with reducing hours.
Primary Contractors and BH-MCOs should work with
providers to ensure that individuals receive the services they need and that
services are delivered in the format that is needed during this emergency. This
may require innovation, such as expanding the use of telehealth and delivering
services in the home. Providers should also ensure that there are sufficient
office and clinic hours available to meet the needs of established and new
patients. To keep staff safe, in addition to social distancing, providers may look
for ways to allow staff to work from home and continue to practice.
21. Are the BH providers considered Health Services that are allowed to
22. The OMHSAS Memorandum dated 03/15/20 “Telehealth Guidelines
Related to COVID-19” appears to allow telehealth flexibility only for those
participants who are quarantined, self-quarantined or "possible risk of exposure". Is
this an accurate reading?
No. The intent of the memorandum is to allow services to
be provided through telehealth for all MA beneficiaries when clinically
appropriate. The OMHSAS Memorandum states “This expansion applies to
behavioral health services delivered to MA beneficiaries via FFS or through a
Behavioral Health HealthChoices Managed Care Organization (BH-MCO).”
23. Does the OMHSAS Memorandum dated 03/15/20 “Telehealth
Guidelines Related to COVID-19” apply to Medicare beneficiaries?
DHS-OMHSAS does not have any jurisdiction over
Medicare. CMS is the oversight authority for Medicare.
24. Why are 992XX codes not listed in the Telehealth Bulletin OMHSAS-20-
02, Attachment A?
The codes listed in the bulletin are for FFS. As outlined in
OMHSAS Memorandum dated 03/15/20, “Telehealth Guidelines Related to
COVID-19”, services that can be provided are not limited to the codes listed in
the bulletin during this emergency. For BH HealthChoices, BH-MCOs have
always had the flexibility to decide which codes to allow.
25. Does the state allow services to be delivered over the phone if the
patient does not have a mobile device or computer that would enable
As outlined in OMHSAS Memorandum dated 03/15/20,
“Telehealth Guidelines Related to COVID-19”, telephone only services may be
utilized when audio/video technology is not available.
26. Will BH-MCOs’ telehealth rates remain the same as face-to-face rates?
The rates for services provided under Managed Care are
determined by the BH-MCOs. Please contact your BH-MCOs for this information.
27. Can clinicians work from home?
During this disaster emergency declaration period,
services can be provided using telehealth. Provider agencies can determine how
they are able to provide services using telehealth, while ensuring that service
needs are met. This may include permitting clinicians to work from home
28. Does each individual mental health clinician seeking to deliver mental
health services via telehealth need to submit an Attestation Form?
No, only the provider agency needs to submit an
29.Does the telehealth expansion apply to Peer Support Services?
Yes, OMHSAS expanded telehealth services to BH
providers beyond those identified in bulletin OMHSAS-20-02, including Certified