COVID-19 & SERVICES BY TELEPHONE...June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez...

June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario GuttierezExecutive Director

COVID-19 & SERVICES BY TELEPHONE

April 22, 2020

CENTER FOR CONNECTED HEALTH POLICY (CCHP)is a non-profit, non-partisan organization that seeks to advance state and national telehealth policy to promote improvements in

health systems and greater health equity.Mei Wa Kwong, JD,

Executive Director, CCHP


DISCLAIMERS• Any information provided in today’s talk is not to be regarded as legal

advice. Today’s talk is purely for informational purposes.• Always consult with legal counsel. • CCHP has no relevant financial interest, arrangement, or affiliation with

any organizations related to commercial products or services discussed in this program.

CENTER FOR CONNECTED HEALTH POLICY© Copyrighted by the Center for Connected Health Policy/Public Health Institute

© Center for Connected Health Policy/Public Health Institute




ABOUT CCHP• Established in 2009• Program under the Public Health

Institute• Became federally designated

national telehealth policy resource center in 2012

• Work with a variety of funders and partners

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CCHP PROJECTS• 50 State Telehealth Policy

Report• Administrator National

Consortium of Telehealth Resource Centers

• Convener for California Telehealth Policy Coalition




NATIONAL CONSORTIUM OF TRCS


CENTER FOR CONNECTED HEALTH POLICY

TELEHEALTH STATE-BY-STATE POLICIES, LAWS & REGULATIONS

Search by Category & TopicMedicaid Reimbursement• Live Video• Store & Forward • Remote Patient Monitoring Reimbursement

Private Payer Reimbursement• Private Payer Laws • Parity Requirements

Professional Regulation/Health & Safety• Cross-State Licensing• Consent• Prescribing• Misc (Listing of Practice Standards)

Interactive Policy Map

© Copyrighted by the Center for Connected Health Policy/Public Health Institute© Center for Connected Health Policy/Public Health Institute


What can I do and get reimbursed for when using the telephone to provide health services?

As of September 2018CENTER FOR CONNECTED HEALTH POLICY© Copyrighted by the Center for Connected Health Policy/Public Health Institute

COVID-19




MEDICARE


FOR TELEHEALTHWe are adding the following language at § 410.78(a)(3)(i): “Exception. For the duration of the public health emergency as defined in § 400.200 of this chapter, Interactive telecommunications system means multimedia communications equipment that includes, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner.”

Interim Final Rule March 30, 2020 - https://www.cms.gov/about-cms/emergency-preparedness-response-operations/current-emergencies/coronavirus-waivers (pages 48-49)

https://www.cms.gov/about-cms/emergency-preparedness-response-operations/current-emergencies/coronavirus-waivers


Communications-Based Technologies Virtual Check-In – G2010; G2012 Audio-only Services – CPT 98966-98968; 99441-99443 Interprofessional Telephone/Internet/EHR Consultations

(eConsult) – 99446-99448; 99451-99452


MEDICARE



DEA


PRESCRIBING CONTROLLED SUBSTANCES USING TELEPHONE


Starting March 31, 2020, during this public health emergency may prescribe and dispense buprenorphine to new and existing patients with OUD via telephone if they are:

• Practitioners who are registered with the DEA as an opioid treatment program (OTP) if a program physician, primary care physician, or an authorized healthcare professional under the supervision of a program physician determines that an adequate eval of the patient can be done via phone.

• “DATA-waived practitioners,” who have a special registration to qualify for a waiver to dispense buprenorphine for maintenance or detoxification and are complying with all applicable standards of care.

https://www.samhsa.gov/sites/default/files/dea-samhsa-buprenorphine-telemedicine.pdf

https://www.samhsa.gov/sites/default/files/dea-samhsa-buprenorphine-telemedicine.pdf




MEDICAID REIMBURSEMENT BY SERVICE MODALITY(Fee-for-Service)

Live Video50 states and DC

Store and ForwardOnly in 14 states

Remote Patient Monitoring22 states As of October 2019


During COVID-19 States Have Been Allowing the Use of Phones to provide health services Must check to see how far they will let you go!


COVID-19 WORLD STATES




COMPARISON OF STATE POLICIES DURING COVID-19


CALIFORNIA FLORIDA• Will reimburse G2010 & G 2012

codes• CA Medicaid program has also

clarified that the telephone may be used to provide services and reimbursed at the same in-person rate if certain requirements are met. If they cannot be met, then the G2010 & G2012 codes can be used.

• Specific codes will be reimbursed for services via telephone 99441-99443


Keep in mind some of these emergency orders may be expiring soon!


COVID-19 WORLD STATES



CCHP Website – cchpca.org Telehealth Federal Policies - https://www.cchpca.org/resources/covid-

19-telehealth-coverage-policies State Emergency Waivers/Guidances -

https://www.cchpca.org/resources/covid-19-related-state-actions Subscribe to the CCHP newsletter at cchpca.org/contact/subscribe


CCHP


https://www.cchpca.org/resources/covid-19-telehealth-coverage-policies

https://www.cchpca.org/resources/covid-19-related-state-actions


877-707-7172cchpca.org CENTER FOR CONNECTED HEALTH POLICY

Mei Wa Kwong, JDExecutive Director, CCHP

Thank You!


www.cchpca.org [email protected]

COVID-19 & SERVICES BY TELEPHONE...June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez...

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