DHS COVID-19 PROVIDER RESOURCES // OMHSAS
Telehealth Guidelines Related to COVID-19
Updated: May 5, 2020
All Behavioral Health Managed Care Organizations (BH-MCOs),
behavioral health providers enrolled in the Medical Assistance (MA)
Program, and County Mental Health Authorities—Statewide
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.
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.
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.
- 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.
- 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.
- 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.
- 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.
- 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.
- Provision of telehealth services in homes will not be limited to Assertive
Community Treatment, Dual Diagnosis Treatment Team, or Mobile Mental Health
- Program requirements for the number or percentage of in-person contacts for
various behavioral health services may be met with the use of telehealth.
- 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.
Providers that are currently approved to provide services through telehealth
technology may immediately begin to implement the expanded use of telehealth.
Providers that are not currently approved to provide services through telehealth
technology may immediately begin to implement the use of telehealth; however, new
providers are still required to submit the Attestation Form as required by Bulletin
OMHSAS-20-02. The Attestation Form must be submitted within 5 business days of
initiating telehealth. When submitting an attestation to RA-PWTBHS@pa.gov for the
COVID-19 state of emergency, please identify in the subject line “COVID-19
Providers of Behavioral Health Rehabilitation Services (BHRS) and Intensive Behavioral
Health Services (IBHS)
Because of the unique nature of these interventions, before providing
Therapeutic Staff Support (TSS) services, Behavioral Health Technician (BHT) services,
Behavioral Health Technician-Applied Behavior Analysis (BHT-ABA) services, Assistant
Behavior Consultation-Applied Behavior Analysis (Assistant BC-ABA) services, IBHS
group services and group services approved through the program exception process
through telehealth, the provider must submit a proposal explaining how services will be
delivered. Further information can be found in the bulletin OMHSAS-20-03 “Instructions
and Guidelines for the Delivery of BHRS and IBHS Through Telehealth.” The proposal
must be approved before the provider can begin to deliver these services.