COVID-19 FAQs and Provider Bulletins

Community Health Plan of Washington Information on COVID-19

 

 

Provider Bulletin: April 6, 2020

Dear Provider:

We are providing the latest information for you regarding your work with CHPW around COVID-19. Please share this information with your clinical and administrative staff, as needed. 

We’ll continue to update you as this response evolves. As information is changing rapidly, please defer to the most recent communication.

For Previous Bulletins and a complete list of FAQs, click here.

CHPW is ready to partner with you in any ways we can be of assistance. You are not alone.

UPDATED INFORMATION (as of 4/6/2020. Information is subject to change)

The information in this section reflects new or revised information since the last dated bulletin.

PROVIDER RESOURCES

CHPW Billing and Guidance

CHPW is following billing guidelines for COVID-19 that are consistent with the HCA and CMS guidelines for Medicaid and Medicare.  These guidelines may change or expand, so please refer to these documents for the most current information.

HCA Information on COVID-19

HCA Medicaid Clinical Policies and Billing for COVID - includes telemedicine guidelines

HCA Behavioral Health policy and billing guidance (revised April 3, 2020)

CMS Current Emergencies

CMS General Provider Telemedicine and Telehealth Toolkit

Make sure that you are subscribed to the appropriate HCA notifications to receive direct updates on changes.


Telemedicine/Telehealth

Can non-physicians bill for telephone calls?

Yes.  The codes 98966 to 98968 were previously available for non-physician billing for Medicaid and Medicare.  Providers should consult the CPT guidance for the most appropriate code.  Additionally, providers can bill the standard in-person codes and include the “CR” modifier with appropriate place of service referenced in the HCA guidance.  Payment will be the same as if the member received care in person.

Will Physical Therapists, Occupational Therapists and Speech Therapists be reimbursed for telemedicine services?

Yes. Reference the HCA telehealth requirements for these therapy types for more specific guidance.

Can interpreter services be delivered via telemedicine?

Yes.  Refer to HCA guidance from March 27, 2020 for additional information.

Is there guidance available for nursing homes to deliver telemedicine services?

Yes.  Refer to the CMS Toolkit for Long-term Care Nursing Homes and Telemedicine released on March 27, 2020.

Notice: The Northwest Regional Telehealth Resource Center (NRTRC) has made their upcoming conference “Telehealth 20/20: New Perspectives, Innovation Insights and Expanded Vision of Care Delivery” on April 15-17 remote and now free!

Register here: NRTRC 2020 FREE Registration

Pharmacy

Has CHPW made changes to pharmacy benefits and policies in response to COVID-19?

Yes. CHPW has implemented the following changes to better provide for our members during this time: 

Refill too soon changes:  CHPW implemented emergency procedures on March 2—putting Policy PM 514 into effect. This policy lifts early refill restrictions for both Medicaid and Medicare members in Washington State. Pharmacies can submit clarification code 13 to override “refill too soon” rejections. The pharmacy help desk can be reached at 1-800-922-1557 to request override support or to ask questions.

  1. Most chronic medications will go through for a 90-day supply for both our Medicare and Medicaid patients.
  2. Quantity limits have been placed and refill too soon overrides do not apply for the following medications:
    1. Hydroxychloroquine
    2. Chloroquine
    3. Azithromycin 
  3. Sublocade: PA requirements have been lifted through 5/31/2020 for medical and pharmacy billing.
  4. Mail Order Options: Mail delivery options are available for members through the following pharmacies.  Contact pharmacies directly for additional information.  
    1. Medicaid – Rite-Aid, Walgreens Retail Stores, Walmart
    2. Medicare – CVS Retail Stores, Express Scripts, Rite-Aid, Walgreens Retail Stores

Behavioral Health

Is there specific guidance for Behavioral Health providers to track the billing and care delivery changes related to COVID-19?

Yes.  The HCA has released guidance for behavioral health billing guide that will be updated as changes are made.  Providers should bookmark this page and review periodically.

Immigrant and Refugee Information

Are there exceptions for people who do not meet the Medicaid citizenship and immigration status requirements?

In response to the public health emergency surrounding the outbreak of COVID-19, the Health Care Authority will now include the assessment and treatment of COVID-19 as a qualifying emergency for the Alien Emergency Medical program (AEM) which serves individuals who do not meet the citizenship or immigration status requirements of other Apple Health programs. More Information is available at the HCA.

CHPW Member Information

How can my patient get a phone for telehealth and other needs?

Community Health Plan of Washington (CHPW) Apple Health members can get a phone plan with monthly data and minutes – at no cost!

  • FREE 3GB data each month
  • FREE unlimited texts each month
  • FREE 350 voice minutes each month
  • FREE cell phone

These companies are offering free cellphone programs through the federal government’s Lifeline program. Call them for more information.

Assurance Wireless          |
Call: 1-888-321-5880
Online: assurancewireless.com 
COVID-19 additional benefit: Unlimited domestic calling & texting plus an extra 6GB data free through 5/20/2020. 

Safelink|
Call: 1-800-SafeLink (800-723-3546)
Online: safelinkwireless.com
COVID-19 additional benefit: Unlimited talk & text and an extra 5GB data free through 4/29/2020.

Some major wireless carriers such as T-Mobile, AT&T, and Verizon are also offering special deals and plan enhancements to Lifeline members during the COVID-19 crisis. Call your carrier for more information.

Small Business Assistance

Are there financial resources for small businesses?

The Washington State Department of Revenue (DOR) created a page dedicated to business relief during the COVID-10 pandemic. The federal Small Business Administration (SBA) may be able to provide assistance through the Economic Injury Disaster Loans program to businesses that have suffered substantial economic injury in an eligible disaster area. Congress approved up to $7 billion in low-interest disaster loans specifically to assist small businesses impacted by COVID-19. These loans can help small businesses meet financial obligations and cover operating expenses. Apply through SBA.

PREVIOUS PROVIDER BULLETINS

FAQs from 3/30/2020

HCA COVID-19 Information

Are there specific contacts at the HCA for provider concerns related to COVID-19?

Yes. In addition to the HCA COVID-19 Information page, HCA has developed 2 email boxes to directly respond to the following concerns:

CHPW Electronic Payment

Does CHPW provide an option for electronic payment if our staff works remotely?

Yes.  With the developing COVID-19 situation in the United States, we strongly encourage you at this time to consider enrolling in ACH electronic payments. This will allow us to issue payments in a timely manner, avoiding delays and disruptions.

We are pleased to continue our business relationship with you in this uncertain time. Please fill out the  Vendor ACH Enrollment form and return to accounts.payable@chpw.org.

Medicaid Billing

Can non-physician providers be reimbursed for telephone calls to patients?

Yes. Non-physicians can bill the existing (pre COVID-19) phone call codes. They range from 98966 to 98968, depending on time. They should consult the CPT guidance for the most appropriate code.  They can also bill their usual codes with the telehealth modifiers and place of service and be paid what they would have been paid if the member was seen in the normal place of service.

Telemedicine/Telehealth

Are there additional resources for my practice to develop a telemedicine program?

The Northwest Regional Telehealth Resource Center (NRTRC) provides technical assistance in developing Telehealth networks and applications to serve rural and underserved communities.  They have also developed a couple resources specifically designed for COVID program development.

Provider Credentialing

Does HCA have a new process to support CHPW’s rapid credentialing process?

Yes.  Providers should send the following information to the HCA at Providerenrollment@HCA.wa.gov:

To back-date providers for changes to their effective dates:

  • The desired effective date
  • their NPI,
  • provider name, and
  • identify this as a priority request due to the COVID-19 situation

To prioritize applications:

  • the NPI of the application submitted
  • provider name,
  • desired effective date and
  • identify this as a priority request due to the COVID-19 situation


Behavioral Health

Is there specific guidance for Behavioral Health providers to track the billing and care delivery changes related to COVID-19?

Yes.  The HCA has released guidance for behavioral health billing guide that will be updated as changes are made.  Providers should bookmark this page and review periodically.


CHPW Member Information

What are the CHPW Member options for pharmacy delivery?

CHPW has temporarily expanded home delivery options for medications for CHPW members. For compete information, click here.

Medicaid:

1. Walgreens Express
2. Walmart's Home Delivery Service
3. Mail order from select CHCs

If a member has been assigned to Healthpoint or Yakima Valley Farm Workers Clinic and get your care there, you can request home delivery of your prescriptions.

Medicare:

1. Express Scripts Pharmacy Delivery
2. CVS
3. Walgreens Express
4. Mail order from select CHCs

If you have been assigned to Healthpoint or Yakima Valley Farm Workers Clinic and get your care there, you can request home delivery of your prescriptions.

Will CHPW be sending preventive care reminders and outreach to members during the emergency?

No. CHPW is temporarily suspending member reminders and outreach for preventive care services.  This includes programs such as Member Birthday Cards, which reminds parents to schedule well-child visits. We will resume preventive care reminders and outreach efforts when primary care providers resume scheduling for preventive services.

FAQs from March 20, 2020

Utilization Management

Has CHPW changed Authorization processes to respond to the COVID emergency?

Yes.  CHPW is working to accommodate providers as much as possible to facilitate care for our members.  The following temporary changes have been put in place effective March 20, 2020.

  • Durable Medical Equipment: CHPW will approve any DME needed for discharge from an inpatient setting. DME that is rental will be approved for 10 days initially. Non-custom items for purchase (such as bath aids) are included, but this does not include custom DME items for purchase (such as a power wheelchair). Notification can be sent after discharge and will be approved. The DME must be a benefit under the Medicaid or Medicare program for which the member is eligible.
  • SNF/LTAC/Inpatient Rehab: CHPW will approve a minimum of 10 days for any SNF/LTAC/Inpatient Rehab stay needed to discharge a member from an acute inpatient setting. Notification can be sent after discharge and will be approved.
  • Hospital Transfers: All hospital lateral transfers can occur without approval of CHPW. As long as the member’s continued inpatient admission is medically necessary, facilities can transfer a CHPW member to another accepting facility. The accepting facility still needs to send notification to CHPW when they are admitted.
  • Home Health and Respiratory Care: CHPW is temporarily removing the requirement for prior authorization for the following services: Home Health, Ventilators, and CPAP/Bi-PAP. Prior authorization is not required for any respiratory supplies at this time. While prior authorization will not be required, it is requested that notification be sent to us as soon as possible that the service is being provided so we can support care coordination for our members requiring these services.
  • Prior Authorization: For all services that require prior authorization, CHPW will temporarily allow retro authorization requests.

Telemedicine

Provider Credentialing

Will CHPW allow providers licensed out of the state to join our practice to deliver covered services?
Yes. CHPW is following the HHS 1135 Waiver and will be reimbursing for all providers operating in the scope of their license.   Please notify CHPW at provider.credentialing@chpw.org if temporary or out of state providers will be joining your practice on a permanent basis.   

Behavioral Health

Care for Immigrants & Refugees

On 3/16/20, the HCA filed an Emergency Rule to expand coverage of the Alien Emergency Medical (AEM) program to include testing and treatment for COVID-19 in any office, mobile, or non-hospital based setting. 

  • AEM covers adults (age 19+) who:
    • have a qualifying emergency medical condition, and
    • would otherwise be eligible for Medicaid but do not meet the citizenship or immigration status requirements for Medicaid, including qualified immigrants who have not met the 5-year bar.   
  • AEM is a state-funded Medicaid program and is excluded from the public benefits considered under the new “Public Charge” rule.
     

FAQs from 3/18/2020

Medicaid Billing

Are there any changes to billing in response to COVID?
Review the HCA’s frequently asked questions about COVID-19 clinical policy and billing. CHPW has modified our systems to accommodate these new billing codes and requirements.

Please note, when billing the telephone and online digital evaluation and management codes, you will need to include modifier CR.

Is G2012 (Virtual Visit) available for Medicaid?
Yes. The referenced HCA guideline clarifies that this is now allowable for Medicaid as well as Medicare Advantage.

Will there be any delays in processing claims?
CHPW has strong work-from-home capabilities, and is not currently experiencing, nor expecting any delays in claims processing. We work to strengthen these capabilities daily to ensure we can handle the increase in claim volume.

Telemedicine

Will telemedicine services be reimbursed during the COVID response?
CHPW will allow telephone and telehealth for any covered service by any qualified provider operating within the scope of their license.

Do I need to use a HIPAA-compliant platform?
No. The HHS Office for Civil Rights (OCR) announced on March 17, 2020, that it will waive potential HIPAA penalties for good faith use of telehealth during the nationwide public health emergency due to COVID-19.  This exercise of discretion applies to telehealth provided for any reason, regardless of whether the telehealth service is related to the diagnosis and treatment of health conditions related to COVID-19.  There is not yet clarity related to services covered by 42 CFR Part 2. We’ll update you when there is additional information is available. 

Provider Credentialing

Is CHPW able to accommodate rapid credentialing of temporary providers?
Yes.  CHPW has an expedited process in place for credentialing temporary providers.  In addition to the agreement with CHPW, providers need a Core Provider Agreement (CPA) with the HCA.  When completing application for a CPA, providers will need to ask for a retro-effective date for the date that the provider started treating Medicaid members to accommodate HCA timelines for processing applications.  Contact provider.credentialing@chpw.org for additional questions and include “Rapid Credentialing Temporary Provider” in the subject line.

Utilization Management

Will CHPW allow a telemedicine visit to meet the requirement for a face-to-face visit for billing of Durable Medical Equipment? 
Yes.  CHPW will accept telemedicine or telephone visits by the provider as a replacement for the face-to-face requirement for a renewal of an already approved DME, such as CPAP.  Reference the CMS Guidelines for additional information.  

Will Prior Authorization (PA) be extended for longer approval dates?  
Yes. All pre-service authorization or inpatient elective procedures that are approved in 2020, will have the date range of the authorization officially extended until at least 12/31/2020.  There is no need to get updated authorization letters or request an extension.

Effective 3/17/2020 we will start authorizing these services with the extended approval date ranges. However, the member can have the service until the end of the year for any existing authorization in place for any date in 2020.

  Below are some important additional notes on this change:   

1)    For any service that has a date range of 12 months (some injectable medications, DME, etc.), those services will continue to be authorized for 12 months.

2)    For Behavioral Health and Medical inpatient acute admissions, there is no change to how those are entered or how the extensions are processed. The date ranges for these services remain the same. In addition, Behavioral Health Partial Hospital Program authorizations will not change.

3)    All other requests (pre-service outpatient authorizations and elective Inpatient procedures), are typically authorized for anywhere from 3-6 months depending on the service. All of these authorizations that originated in 2020 are now approved until 12/31/2020 regardless of the date on the authorization in Jiva.

4)    The unit limits on the authorization still apply. Example: A PT authorization approved for 12 units from 2/1/2020 until 5/1/2020 is now approved for 12 units from 2/1/2020 to 12/31/2020. If the member has been able to receive their 12 units and continue their care, then any additional services would require a new authorization.

Do I need to get a second authorization for in home ABA treatment for a patient currently in Day Treatment to prevent the transmission of COVID?
If you have an authorization for Day Treatment (H2020), you can bill for ABA services (97151-97157) during the time period of the Day Treatment authorization.  A second authorization is not required.

FAQs from 3/13/2020

PROVIDER WEBINARS:

HCA's Division of Behavioral Health and Recovery (DBHR) will host a COVID-19 related weekly webinar for providers of mental health, substance use, and problem gambling services on Tuesdays from 12-1 PM from March 17-April 1. Here is the registration link.

The National Consortium of Telehealth Resource Centers free webinar on Telehealth and COVID-19 on Thursday, March 19 at 11 AM. Here is the registration link.

Will CHPW pay for COVID-19 testing?
Yes, codes have been developed and CHPW is now using them. For CHPW members, we will process these codes based on the published HCA and CMS reimbursement rates.

Health care providers who need to test patients meeting CDC criteria for testing for novel coronavirus using the Centers for Disease Control and Prevention (CDC) 2019

Novel Coronavirus Real Time RT-PCR Diagnostic Test Panel may bill for the cost of the test using HCPCS code U0001. CMS developed the first HCPCS code (U0001) to bill for tests and track new cases of the virus. This code is used specifically for CDC testing laboratories to test patients for SARS-CoV-2. The second HCPCS billing code (U0002) allows laboratories to bill for non-CDC laboratory tests for SARS-CoV-2/2019-nCoV (COVID-19). 

Will Prior Authorizations be required for Home Health services?
No. CHPW is temporarily removing prior authorization requirements for home health services to support expedited transition coordination for members leaving an acute setting needed in response to increased demand for inpatient services. Home health services can be coordinated and start immediately without prior written approval from CHPW.

TELEMEDICINE

Medicare

Will CHPW cover any other types of virtual/remote patient interactions?
Yes. During the COVID 19 emergency period, CHPW will cover E/M services provided via telephone (CPT 99441 – 99443). Providers billing for these services for CHPW Medicare Advantage members should follow the same rules and process that applies for CHPW Apple Health members. Please note that CHPW is only able to cover these services during the COVID 19 emergency period, based on guidance from CMS. CHPW will notify providers of any changes

Medicaid

What about E&M services delivered via telephone (voice only)?
CPT 99441-99443 are available for telephone visits. Note that these cannot be billed if the patient is seen within 24 hours or next available urgent visit appointment of the phone call. Reference page 47 of the HCA Physician-Services Billing Guide for additional information. We are working to update and validate our systems for how to bill and how we will pay for telemedicine visits and will share that information early next week.

Will telemedicine services for Medicaid for behavioral health be reimbursed?
Yes, telemedicine services delivered with audio/video technology or store and forward (sharing electronic records) are billable for approved Medicaid services. This is currently available for established patients receiving services under the SERI Guide, but behavioral health intakes are currently are not billable as telemedicine services. We are awaiting HCA guidance on this.

The current version of the HCA Physician Billing Guide indicates the rules for telehealth/telemedicine billing, starting on page 85. This includes definitions, allowable locations for clients and required code modifiers.

Will telemedicine services for Medicaid for physical health be reimbursed?
Yes, telemedicine services delivered with audio/video technology or store and forward (sharing electronic records) are billable for approved Medicaid services. The current version of the HCA Physician Billing Guide indicates the rules for telehealth/telemedicine billing, starting on page 85. This includes definitions, allowable locations for clients and required code modifiers. Note that services can be delivered in a patient’s home or any location determined appropriate by the individual receiving service.

Does telemedicine require prior authorization?
Telemedicine alone does not require prior authorization. However, services that do require a prior authorization would continue to do so. Refer to the list of prior authorizations on the CHPW website.

Does CHPW require additional credentialing or privileging for delivering care via telemedicine?
It may, depending on the provider. If your organization is utilizing providers external to your organization to deliver telemedicine services this will require additional credentialing and privileging to be reimbursable. For internal providers to your organization, please reference your internal processes and procedures or contact credentialing@chpw.org.

Will my malpractice insurance cover telemedicine?
Providers should check to make sure that it is included, especially if delivering care in the home is new to the organization.

Do providers need additional training for delivering care via telemedicine?
Training is not required to report to CHPW, but you may develop internal procedures to ensure consistency in delivering care in this modality. You might also consider a formal approval process that requires this training before delivering services to support the billing process, like documentation standards and care delivery expectations. 

Can a physical exam be provided over telemedicine?
Yes, some levels of physical exam can be delivered via telemedicine without special technology including visual exam, temperature taken by patient, blood pressure, blood sugar or other measures that can be provided by the patient in their home. This can be combined with history, assessment and plan to complete a billable visit.

Do I need special documentation for visit delivered by telemedicine?
Yes, since the patient is receiving care remotely and you will be billing for a remote encounter, you need to identify the visit as such. You may do this by using a simple phrase at the end of your documentation that  should include the location of the patient and provider and anyone else present during the encounter. Other documentation of the encounter should be similar to a regular face-to-face encounter.

What technology can be used to deliver telemedicine?
There are many HIPAA-compliant platforms available with the capacity to deliver care with audio/video care technology. Some examples are Zoom for Healthcare, Skype for Business, Clocktree and doxy.me. Providers delivering telemedicine services are still responsible for compliance with applicable Privacy and Security Rules (i.e., HIPAA). 

Are there additional Telemedicine Resources?
The following are reputable organizations in telehealth that have a variety of resources for operational implementation:

Northwest Regional Telehealth Resource Center
Washington State Telehealth Collaborative – contains resources for implementing telehealth

National Telehealth Technology Assessment Resource Center
CMS Telehealth Services Guide – note that this is the standard guide, not incorporating COVID-19 exceptions
Center for Telehealth & e-Health Law

FAQs from 3/12/2020

Is CHPW staffed to respond to provider and member questions?
Yes, we are fully staffed and are not experiencing any delays in responding to provider or member questions or requests. All our regular operations, including claims processing, credentialing, and care management services, are continuing uninterrupted.

Are CHPW's partners (like the Nurse Advice Line and Pharmacy Benefits Managers) prepared to support members and providers?
Yes, CHPW has identified key business partners and are in regular communication to ensure consistent service availability.

The Nurse Advice Line for members for free medical advice is available 24 hours a day, seven days a week: 1-866-418-2920 (TTY: Dial 711).

What is CHPW doing to facilitate care for our members?
We immediately lifted “refill too soon” edits on prescriptions as soon as the Governor declared a State of Emergency. Our teams are also acting quickly to resolve any situations that providers identify as problematic. Please let us know right away of any issues and we’ll work to resolve them immediately.

We emailed our members for whom we have email addresses to provide information from public health on prevention, care, and our Nurse Advice line.

How is CHPW prepared to support providers and members?
CHPW is actively monitoring the current situation, working with the state Health Care Authority, to continue to be prepared.  We are working with our staff to ensure they are taking proactive steps to stay healthy and to be able to support our members and providers.

We are supporting and reimbursing telehealth visits to the extent allowable by law/contract, and looking for ways to enhance this offering. Meanwhile, we are partnering with associations and others to lobby both the state and federal government to allow visits to occur virtually and appropriately reimburse for them.

We are partnering with the state and other MCOs to expedite placement for all patients ready for hospital discharge to free up needed capacity.

How does my organization submit a claim for Medicaid for telemedicine?
The organization will submit codes for the distant site (provider location) and originating site (patient location) with telemedicine modifiers.  If the patient is located at “Home or any location determined appropriate by the individual receiving service” a claim would be submitted for the distant site only.

  • Distant Site: Use place of service (POS) 02 to indicate that a billed service was furnished as a telemedicine service from a distant site.
  • Originating Site: Add modifier 95 (via interactive audio and video telecommunications system) if the distant site is designated as a nonfacility.

Are there CMS resources for questions about Medicaid?
The Centers for Medicare & Medicaid Services (CMS) is posting Frequently Asked Questions (FAQs) to the Medicaid.gov website to aid state Medicaid and Children’s Health Insurance Program (CHIP) agencies in their response to the 2019 Novel Coronavirus (COVID-19) outbreak. 

A press release with further information can be found here:  https://www.cms.gov/newsroom/press-releases/cms-publishes-first-set-covid-19-frequently-asked-questions-faqs-state-medicaid-and-childrens-health

The COVID-19 FAQs for State Medicaid and CHIP agencies can be found here: https://www.medicaid.gov/state-resource-center/disaster-response-toolkit/covid19/index.html

To keep up with the important work CMS is doing in response to COVID-19, please visit the Current Emergencies Website.

MEDICARE SERVICES & BILLING

Are telemedicine services for CHPW Medicare members reimbursed?
CHPW MA plans cover telehealth visits consistent with applicable CMS guidelines.

For Medicare telehealth, the provider must be operating within the scope of their license, at an approved distant site, and using an interactive, real-time multimedia telecommunications (including web-based applications) system. Additionally, the patient must have received services from the provider within the last 3 years.

CHPW Medicare Advantage also covers virtual check-in services furnished through several communication technology modalities, including telephone (HCPCS code G2012) or captured video or image (HCPCS code G2010). Patients must provide verbal consent for the virtual check-in prior to using the service and a virtual check-in may not be related to a medical visit within the previous 7 days or result in a medical visit within 24 hours.

CHPW Medicare Advantage also covers certain doctor-patient communication via online patient portals. The individual communications must be initiated by the patient; however, practitioners may educate beneficiaries on the availability of this kind of service prior to patient initiation. The communications can occur over a 7-day period.

These services may be billed using CPT codes 99421-99423 (patient-initiated digital communication) and HCPCS codes G2061-G2063 (online assessment), as applicable.

Will CHPW cover any other types of virtual/remote patient interactions?
Yes. During the COVID 19 emergency period, CHPW will cover E/M services provided via telephone (CPT 99441 – 99443).  Providers billing for these services for CHPW Medicare Advantage members should follow the same rules and process that applies for CHPW Apple Health members. Please note that CHPW is only able to cover these services during the COVID 19 emergency period, based on guidance from CMS. CHPW will notify providers of any changes.