COVID-19 ReimbursementModels such as telephone-based crisis intervention have been the foundation of the emergency safety net for decades. Now with COVID-19, many rely on their telephone skills to maintain treatment with clients and patients. Yet, most clinicians haven’t learned basic best practices for using the telephone for their every-day practices. They also haven’t learned the classic telehealth telephone-based models.

Reasons for using the telephone rather than video at this time of mass adoption in telehealth include a variety of situations. Some professionals have been unable to establish a video-based practice; clients or patients refuse to use video; clients or patients have voiced a clear preference for using the telephone; and with everyone in quarantine, clients and patients may be willing but unable to set up video conferencing sessions without help. The usual support network of family and friends is unavailable.

The clinician may not be skilled enough at using video to be able to help them or have other reluctances due to clinical or privacy aspects of someone’s care.

Regardless of your reasons for using a telephone, this article helps navigate the laws and telehealth reimbursement resources during COVID-19. In this brief review, we 1) look at state-specific regulatory change and offer a few exciting telehealth-related resources to answer many of your questions. 2) We’ll also look at insurers and what they’ve been doing, including Medicare and Medicaid. 3) Below you will also find recent updates to telehealth billing codes for all of the telehealth, including a list of appropriate telehealth modifier codes. 4) If you have been using the incorrect code, this article points you to instructions for how to correct the errors caused by their change of codes.

The reality of Medicare’s dramatic shift to reimbursing not only telehealth for the general population but also for using telephones at the discretion of the provider is evidenced by the image on the lower portion of this web page. It was sent to medicare beneficiaries on April 8, 2020. In the lower portion of the second paragraph, Medicare clearly instructs beneficiaries to speak to “contact your provider to see if your appointment can be conducted over the phone.”

State-Based Telephone Telehealth Reimbursement Rulings for COVID-19

Many states have included telephone service in their definitions of telehealth over the years. However, most have not required telehealth reimbursement by insurance plans. Many other states have expressly stated that telephones do not meet the definition of telehealth. In many states, COVID-19 has forced the decision-makers to reconsider, given the dismal alternatives.

Center for Connected Health Policy

For a regularly updated and detailed list of state-based news for telehealth in particular, we encourage you to visit the website for the Center for Connected Health Policy. They receive federal funding to help advance telehealth by providing telehealth-specific resources for stakeholders. Their COVID-19 RELATED STATE ACTIONS webpage gives you a regularly updated overview of state-based regulatory changes related to relevant laws for each state. They include the approval of telephone use for health care professionals within each state and telehealth reimbursement during COVID-19. Some states ruling that telephones are a permissible telehealth technology have worked with health plans in their states to reach an understanding for all payors in the state.

NOTE: TBHI suggests that you be leery of people compiling resources and asking to register to see their information. The Center for Connected Health Policy does not require that you give your email address to access their information.

State-Based Listings for Behavioral Healthcare

Another recently-released resource for behavioral practitioners is the University of Texas at Austin’s Counseling and Mental Health Center’s State-by-state guide to the rules/laws about telehealth services across state lines for Mental Health Professionals. While you will not find a specific category for telephone coverage in this document, you will find information as provided by relevant state boards related to physicians, psychologists, social workers, marriage and family counselors and licensed professional counselors. Several other issues of interest with regard to state differences are detailed, and important web addresses for other resources are provided.

The University of Texas at Austin’s Counseling and Mental Health Center does not require that you give your email address to access their information.

Medicare Telehealth Reimbursement during COVID-19

In a March 30 update to its Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19, Centers for Medicare and Medicaid Services (CMS) announced a number of additional CPT codes intended to benefit Medicare beneficiaries seeking telehealth reimbursement from Medicare services for telephone-for-COVID-19.

Of particular note regarding telehealth reimbursement of audio-only telephone services, these clarifications apply, among others:

    • CPT codes (98966-98988) are for “telephone assessment and management services” provided to an established patient
    • Codes may not originate from a related assessment and management service provided within the previous 7 days
    • The codes may not lead to an assessment management service or procedure within the next 24 hours or soonest available appointment
    • Codes are to NOT be used for traditional psychotherapy by telephone
    • The codes apply only when the patient calls the provider
    • “Assessment and management” does not mean formal testing

4-7-2020 Update:

The Centers for Medicare and Medicaid Services Administration (CMS) webpage linked above suggests the following :

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), follow these procedures:

  • CPT Code Modifier is now “95” (place in two boxes after the CPT code on the “1500 form”), indicating that the service rendered was actually performed via telehealth.
  • Place of Service Code is now “11”. Previously, telehealth claims were billed using POS “02”. This is no longer true. THE “02” CODE SHOULD NO LONGER BE USED.
  • The telehealth reimbursement rates will be the same as your usual in-office rate.

Other Non-Telephone, CMS documents for COVID-19

Medicaid Telehealth Reimbursement during COVID-19

Medicaid information about COVID-19 billing for services delivered by telephone as well as in general is most reliable by going to the federal website at Medicaid.Gov. More specifically, this Medicaid Tool Kit of Resources may be helpful to watch for updates regarding changes related to COVID-19 in your state of licensure and service delivery.

For more COVID-19 telehealth information that is specific to telebehavioral health, the Telebehavioral Health Institute offers you a listing of other legislative changes HERE: Telehealth Primer for COVID-19.


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COVID-19 Reimbursement

Marlene M. Maheu, PhD has been a technologist-psychologist and pioneer since 1994. She has served various organizations to assist with the development of technology-focused standards and guidelines, including the American Telemedicine Association, the American Psychological Association and the American Counseling Association. She has overseen the development and delivery of telehealth training to more than 26,000 professionals worldwide and consulted with hundreds of hospitals, clinics, agencies, groups and independent practitioners seeking start-up guidance.

Dr. Maheu serves as the Founder & Executive Director of the Telebehavioral Health Institute, which offers over 64 hours of both basic and advanced telehealth training online and offering two Micro Certifications Telehealth. She is the CEO for the non-profit Coalition for Technology in Behavioral Science (CTiBS). She has authored five telehealth textbooks, including the Telebehavioral Health: Foundations in Theory & Practice for Graduate Learners (2020); the APA-published, A Practitioner’s Guide to Telemental Health: How to Conduct Legal, Ethical and Evidence-Based Telepractice (2016), and Career Paths in Telemental Health (2016).

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