The Pennsylvania Department of Human Services, Office of Mental Health and Substance Abuse Services (OMHSAS) is issuing this Memorandum to offer clarification regarding the ability of providers to use telehealth to render behavioral health services to Medical Assistance (MA) beneficiaries.

Background

On March 6, 2020, Governor Wolf issued an emergency disaster declaration in response to the presence of the 2019 novel coronavirus (COVID-19) in Pennsylvania. COVID-19 is a new virus that causes respiratory illness in people and can spread from person-to-person. This virus was first identified during an investigation into an outbreak in Wuhan, China. COVID-19 is a severe respiratory disease, resulting in illness or death, caused by person-to-person spread of the virus. 

Commonly reported symptoms of COVID-19 infection include fever, cough, and shortness of breath. While the exact incubation period for this coronavirus has not yet been determined, it is believed that most infected people will develop symptoms 2 to14 days after they were exposed. There is no vaccine available for COVID-19. Prevention measures center on frequent handwashing, covering coughs and sneezes, and separating people who have respiratory symptoms. Treatment for COVID-19 includes the use of over the-counter fever-relievers, drinking plenty of fluids and resting at home to help relieve symptoms. Those with more severe symptoms may be hospitalized to provide additional support.  

Discussion

Given the Centers for Disease Control and Prevention’s (CDC) recommendations related to quarantine and isolation, both self-imposed and mandatory, OMHSAS is announcing a preference for use of telehealth as a delivery method for medically necessary behavioral health services as ordered, referred, or prescribed by a provider or practitioner, that can be delivered effectively when the patient is quarantined, selfquarantined, or self-isolated due to exposure or possible risk of exposure to the COVID19 virus. 

In order to ensure that individuals continue to receive necessary behavioral health services as we bolster our efforts to mitigate the spread of COVID-19, OMHSAS is temporarily suspending certain requirements that govern the provision of behavioral health services using telehealth. The guidelines for the provision of telehealth in the MA Program are delineated in the bulletin OMHSAS-20-02 “Guidelines for the Use of Telehealth Technology in the Delivery of Behavioral Health Services” effective February 20, 2020. OMHSAS is adopting the following measures to fully utilize the capabilities of telehealth to manage the situation brought about by the spread of COVID-19. This expansion applies to behavioral health services delivered to MA beneficiaries via FFS or through a Behavioral Health HealthChoices Managed Care Organization. 

1. During this state of emergency, telehealth will allow the use of telephonic video technology commonly available on smart phones and other electronic devices. In addition, telephone only services may be utilized in certain situations where video technology is not available.
2. Staff trained in the use of the telehealth equipment and protocols to provide operating support and staff trained to provide in-person clinical intervention will not be required to be present with the individual while they are receiving services. 
3. The practitioner types that can provide services through telehealth will not be limited to psychiatrists, licensed psychologists, Certified Registered Nurse Practitioners and Physician Assistants certified in mental health; Licensed Clinical Social Workers; Licensed Professional Counselors; and Licensed Marriage and Family Therapists. Other individuals providing necessary behavioral health services will be permitted to utilize telehealth for services that are within their scope of practice.
   
4. The provider types that can bill for telehealth under MA FFS will not be restricted to Psychiatric Outpatient Clinics, Psychiatric Partial Hospitalization Programs, and Drug & Alcohol Outpatient Clinics. When completing the Attestation Form (Appendix B), the “Other” Field (section I.a.) is not limited to HealthChoices during this state of emergency. BH-MCOs may continue to allow billing for any provider type they determine appropriate.
5. The services (procedure codes) that can be provided through telehealth under MA FFS will not be restricted to the procedure codes identified in Attachment A of the Bulletin OMHSAS-20-02. BH-MCOs already have the flexibility to do this.
6. Provision of telehealth services in homes will not be limited to Assertive Community Treatment, Dual Diagnosis Treatment Team, or Mobile Mental Health Treatment.
7. Program requirements for the number or percentage of in-person contacts for various behavioral health services may be met with the use of telehealth.
8. Program limits on the amount of service that can be provided through telehealth are temporarily suspended.
   

It should be noted that these temporary measures still require adherence to other requirements that apply to the service being delivered as they would when delivered in-person.