MPA is working to assure that you have the information needed as Maryland deals with COVID-19 (coronavirus). The situation is fluid and will remain that way for a while.
COVID-19 information for the general public
Resources for Maryland residents from the special open enrollment period for the MD Health Exchange to solutions for managing stress during this time.
Resources for Maryland Psychologists
Coronavirus March 16 Webinar Recording – On Monday, March 16, MPA held a special MPA Office Hours webinar on coronavirus, MPA and psychological practice in Maryland. We would like to thank MPA’s Director of Professional Affairs Paul Berman, Legal Counsel Richard Bloch, Laura Steensen and Sarah Simpson from the Greater Baltimore Counseling Center for their participation. Click here for the video.
COVID-19 UPDATE (4/3/2020)
For Medicare AND for other insurance companies (except Medical Assistance and Tri-Care): This should be the final final (as opposed to the Interim Final, as some people noticed we have seen on some of the published regs):
- Place of Service: 11
- Modifier: 95
Below is from the4 April 3, 2020 publication from CMS. This is the issue, as I understand it, and it all has to do with the specific factors within the payment system used to determine reimbursement for services by Medicare, known as “Resource-based Relative Value Scale (RBRVS).
(For those who can’t sleep and want to learn more about RBRVS, I have some lengthy documents. But this is the essence: the final payment to practitioners is determined by the resource costs needed to provide them, with each service divided into three components:
- Practitioner “work”
- Practice expense
- Professional liability insurance (PLI)
Payments are calculated by multiplying the combined costs of a service times a conversion factor [a monetary amount determined by CMS] and adjusting for geographical differences in resource costs.)
So, if you want to understand the underlying policy issues:
- Up until now, Medicare only allowed for telehealth services from an approved facility.
- Approved practitioner fees at a facility are lower than practitioner fees in an office because the practitioner fees at a facility do not include the practice expense (a factor, above, in the RBRVS) which are costs of running the office – facilities are paid a separate fee for those costs, so the costs are not included in the practitioner fees in a facility.
- “02” Place of Service has been used by Medicare for practitioners providing telehealth in a facility, because they were the only ones who could provide these services.
- And, since “02” Place of Service indiciates the use of telehealth, the “95” modifier was not required (because the “95” modifier also indicates the use of telehealth)
- But, now, since private practitioners are being reimbursed for telehealth services by Medicare, we need a code which allows us to be reimbursed for our practice/office expenses – and these are not included in the “02” Place of Service code reimbursement scheme.
- Therefore, in order to make sure we are paid for our professional services and office expense services, we need to use Place of Service 11.
- But, if we use Place of Service 11 without any other modifier, then no one knows we are using telehealth. Therefore, we have to include the modifier “95” to indicate that we are providing telehealth services.
Many insurance companies want the Place of Service to be coded as: 02
Medicare still wants Place of Service to be coded as: 11
All (except Medicaid and Tricare) want the modifier: 95.
Friday, April 3, 2020
Billing for Professional Telehealth Distant Site Services During the Public Health Emergency — Revised
Billing for Professional Telehealth Distant Site Services During the Public Health Emergency — Revised
This corrects a prior message that appeared in our March 31, 2020 Special Edition.
Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. When billing professional claims for all telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with:
- Place of Service (POS) equal to what it would have been had the service been furnished in-person
• Modifier 95, indicating that the service rendered was actually performed via telehealth
As a reminder, CMS is not requiring the CR modifier on telehealth services. However, consistent with current rules for telehealth services, there are two scenarios where modifiers are required on Medicare telehealth professional claims:
• Furnished as part of a federal telemedicine demonstration project in Alaska and Hawaii using asynchronous (store and forward) technology, use GQ modifier
• Furnished for diagnosis and treatment of an acute stroke, use G0 modifier
There are no billing changes for institutional claims; critical access hospital method II claims should continue to bill with modifier GT.
Medical Assistance – Optum – (1) additional information on telephone based services AND (2) clarification that psychologists are included (psychologists were inadvertently left off the March 21st Memo as a practitioner group who can use telehealth)
HIPAA compliant electronic platforms: The Office of Civil Rights, the enforcement agency for HIPAA, has stated that it will not enforce regulatory requirements that practitioners use HIPAA-compliant electronic platforms during the COVID-pandemic when the practitioner provides “good faith” efforts to provide telehealth services.
Medicare: CMS has officially waived rules regarding the provision of telehealth services. Practitioners who participate with Medicare will now be reimbursed for telehealth services provided from their office or home to a new or existing patient in their home or other location. The CPT billing modifier for Medicare is GT.
NOTE: Medicare will NOT reimburse for services via telephone.
Medical Assistance (Optum): Medical assistance has officially expanded reimbursable services to include telehealth from therapist’s home or office to patient’s home or other location. Also, Dept. of Health confirmed psychologists are included as one of the behavioral health practitioner groups who can use telehealth (we were left off of a memo dated March 21, 2020.)
- Will reimburse for telephone-based therapy services. The modifier is “-UB” which identifies the claim as a telephonically delivered service. Providers can bill for audio-only telephonic services that were initiated by the participant.
- Place of service code is “11” for “Office”, except for Medicare Dual eligible (see below, 3c)
- However, Place of Service Code 02 (Telehealth) should be used for Maryland Medicaid participants who also have Medicare crossover claims to specify services rendered through a telecommunication system for dual eligible participants.
- Additional Guidance re: telehealth. “Providers who are not able to meet in-person with a participant should make every effort to use the following technology, in order of priority:
- Traditional telehealth technology which meets all formal requirements is strongly preferred. (These services remain unaffected by the measures in this guidance).
- If Medicaid participants are unable to access originating sites possessing fully qualified technology (ability to pan/focus camera, multiple views, etc.) this emergency policy will permit the use of notebook computers, smartphones, or audio-only phones. If Medicaid participants cannot access cell-phone based video technology, audio only telephone calls will be permitted.
Note: Providers may not use the audio-only telephone service option to expand services. Service volumes will be monitored, and outliers will be audited. The Department shall, upon determining that there is a substantial likelihood that a healthcare provider has failed to comply with this guidance…prohibit the healthcare provider from being reimbursed by the State for audio-only telephonic services.”
Services delivered via telehealth using two-way audio-visual technology assisted communication should be billed using the “-GT” modifier.
Additional information: email address for inquiries about telehealth: email@example.com
Additional telehealth info: https://mmcp.health.maryland.gov/Pages/telehealth.aspx
Providing Services to patients who reside in other states:
- DC has announced that it will allow practitioners who are licensed outside the state to provide telehealth services to existing patients in DC for the purposes of continuity of care. DC will NOT allow telehealth services from practitioners licensed out-of-state for NEW patients, except for healthcare facilities.
- Virginia has not made any official announcement that I have seen. However, an email from the Board administrator stated the following: “The Governor nor the Department of Health Professions have not officially waived the regulatory requirements; however, the Board is certainly not going to discipline unlicensed practice for those providing continuity of care with an established Virginia client via telehealth during a state of emergency.”
Specific insurance Company Policy Changes:
- Magellan*: reimburses therapy via telephone if computer-based platforms are not available
- Optum (aka United Behavioral Health)*: reimburses therapy via telephone if computer-based platforms are not available. They have also waived all attestation requirements. See below: https://www.providerexpress.com/content/ope-provexpr/us/en/Important-upates.html
- “Telephonic care: For providers who do not have access to HIPAA-approved technology typically required to conduct a video-enabled virtual session, or video chat platforms as listed below, telephonic services can begin immediately. Providers do not need to attest through our virtual visits process to provide telephonic care. Please refer to reimbursement guidelines below for telehealth billing guidelines as this will allow properly submitted claims to process through auto-adjudication without creating manual work and support timely payment.
- Billing guidelines: Optum Behavioral Health will reimburse telehealth services which use standard CPT codes and a GT modifier or a Place of Service of 02 for both video-enabled virtual visits and telephonic sessions to indicate the visit was conducted remotely.”
- FEP BC/BS – waived the requirement for patients to use their preferred vendor, TelADoc.
- Aetna* – waived the requirement for patients to use their preferred vendor, TelADoc
For all traditional insurance policies, $0 copay for telemedicine visits until June 4, 2020 for the following:
- Teladoc options through the Aetna Health app
- Network providers who deliver virtual care, such as live video-conferencing
- Other virtual care apps or services
*Note: If the health benefits are through the client’s self-insured employer, then benefits must be checked with the employer or insurance benefit plan administrator
Maryland Board of Examiners for Psychologists (BoE) update on license renewal (3/19/20)
At this time psychology license and psychology associate registration renewals have been extended to April 30, 2020.
- All CEs may be obtained through independent study.
- All psychologists with an active license with an expiration date of March 31, 2020, the expiration will be extended to April 30, 2020.
- All psychology associates with an active registration with an expiration date of March 31, 2020 will be extended to April 30, 2020.
- All renewals must be completed online using the Board’s online renewal system. The site can be found on the Board’s website. Payment must be made by credit card or a debit card. No paper renewals or checks will be accepted at this time.
- You may check online to see when your licensed renewal has been processed by performing a license verification check on the Board’s website (do not panic if you do not see your license updated, keep checking). YOU WILL NOT RECEIVE A NEW PAPER LICENSE OR REGISTRATION FOR SOME TIME.
Medicare coverage of Telehealth Services
The following is Paul Berman’s brief overview of the changes regarding Medicare and telehealth announced on March 18:
Medicare has changed its policy with regard to telehealth beginning March 6, 2020 and during the time of the COVID-19 public health emergency. The changes also allow the use of non-HIPAA compliant devices and platforms such as FaceTime and Skype.
- Medicare-participating psychologists can now use telehealth to see their Medicare clients from the therapist’s home/office to patient in their home/other location
- Medicare will waive HIPAA requirements for the devices and platforms as long as therapists provide their services in good faith using other technologies or platforms such as FaceTime or Skype.
- Payment for telehealth will be the same as for in-office sessions
- This will continue as long as the COVID-19 nationwide public health emergency remains in effect.
The following is taken directly from Medicare’s Announcement [with Paul’s clarifications in brackets]:
- Effective for services starting March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for Medicare telehealth services furnished to patients in broader circumstances. [from your office/home to patient’s home or any other appropriate location]
- These visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.
- Starting March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for professional services furnished to beneficiaries in all areas of the country in all settings.
- Medicare will make payment for Medicare telehealth services furnished to beneficiaries in any healthcare facility and in their home.
- The Medicare coinsurance and deductible would generally apply to these services. However, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.
- To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency. [Medicare typically requires a pre-existing relationship prior to use of telehealth but that is currently waived]
HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA): Effective immediately, the HHS Office for Civil Rights (OCR) will [allow the use of] everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency. For more information: https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/index.html
Billing Template for telehealth (from Paul Berman)
The example, below, is from a recent announcement sent out by CIGNA.
1. Place of Service, in 24B, below, is “02.”
2. The appropriate CPT code is listed in 24D, where the example below has the words, “CPT code.”
3. A modifier is required to indicate the use of telehealth: commercial carriers require the modifier “95” in 24D, while Medicare, Medical Assistance, and Tricare, require the modifier “GT” in 24D.
DC issues waiver for licensed out of state health care providers
Mayor Bowser has issued an administrative order waiving licensure for healthcare providers including psychologists to practice in the city effective March 13 through the end of the state of emergency. Approved services include telehealth. You can find the complete order here: Order – Licensure Waivers.20.03.13
MPA Professional Practice Toolkit
Resources prepared by MPA’s Professional Practice Committee including telehealth and informed consent.
Telehealth resources from APA
MPA Continuing Education
- There are currently no continuing education workshops scheduled for April.
- Our May and June CE events will have live stream options.
- If you’re sick and need to miss an MPA event, please contact the office at 410-992-4258 or CE@marylandpsychology.org. We can either apply your registration to another workshop or receive a refund.
- Looking for independent CE courses? Please see our Home Study CE library
In accordance with public health concerns, the MPA staff is now teleworking. Staff will be available by email and phone. You can find staff email addresses here
Maryland Health Exchange
APA resource on protecting yourself and your practice
Information on COVID-19 (coronavirus)
Recommendations from the CDC and WHO to minimize the risk of contracting COVID-19.
- Wash your hands often with soap and water for at least 20 seconds, especially after going to the bathroom; before eating; and after blowing your nose, coughing, or sneezing.
- If you need to cough or sneeze, please use the crook of your elbow instead of your hands.
- If you are sick, please stay home.
- Consider fist-bumping, air high fives or elbow tap greetings instead of handshakes and hugs
How to Cope
Fortunately, psychological research also points to ways to manage these difficult conditions. Before social distancing, quarantine or isolation orders are enacted, experts recommend planning ahead by considering how you might spend your time, who you can contact for psychosocial support and how you can address any physical or mental health needs you or your family may have.
Limit news consumption to reliable sources
It’s important to obtain accurate and timely public health information regarding COVID-19, but too much exposure to media coverage of the virus can lead to increased feelings of fear and anxiety. Psychologists recommend balancing time spent on news and social media with other activities unrelated to quarantine or isolation, such as reading, listening to music or learning a new language. Trusted organizations—including the U.S. Centers for Disease Control and Prevention, the U.S. Substance Abuse and Mental Health Services Administration and the World Health Organization—are ideal sources of information on the virus.
Create and follow a daily routine
Maintaining a daily routine can help both adults and children preserve a sense of order and purpose in their lives despite the unfamiliarity of isolation and quarantine. Try to include regular daily activities, such as work, exercise or learning, even if they must be executed remotely. Integrate other healthy pastimes as needed.
Stay virtually connected with others
Your face-to-face interactions may be limited, but psychologists suggest using phone calls, text messages, video chat and social media to access social support networks. If you’re feeling sad or anxious, use these conversations as an opportunity to discuss your experience and associated emotions. Reach out to those you know who are in a similar situation. Facebook groups have already formed to facilitate communication and support among individuals asked to quarantine.
Relying on pets for emotional support is another way to stay connected. However, the Centers for Disease Control and Prevention recommend restricting contact with pets if you contract COVID-19 until the risks of transmission between humans and animals are better understood.
Maintain a healthy lifestyle
Get enough sleep, eat well and exercise in your home when you are physically capable of doing so. Try to avoid using alcohol or drugs as a way to cope with the stresses of isolation and quarantine. If needed, consider telehealth options for psychotherapy. If you already have a psychologist, contact them ahead of a potential quarantine to see if they can continue your sessions using phone-based or online delivery.
Use psychological strategies to manage stress and stay positive
Examine your worries and aim to be realistic in your assessment of the actual concern as well as your ability to cope. Try not to catastrophize; instead focus on what you can do and accept the things you can’t change. One way to do this is to keep a daily gratitude journal. You may also choose to download smartphone applications that deliver mindfulness and relaxation exercises. For example, PTSD Coach is a free application developed by the U.S. Department of Veterans Affairs’ National Center for PTSD and the Department of Defense’s National Center for Telehealth and Technology. It contains coping and resilience resources such as exercises for deep breathing, positive imagery, muscle relaxation and more.
Focusing on the altruistic reasons for social distancing, quarantine or isolation can also help mitigate psychological distress. Remember that by taking such measures, you are reducing the possibility of transmitting COVID-19 and protecting those who are most vulnerable.