Provider Alert! Telehealth Services – PT/OT/ST Providers and COVID-19
Date: September 2, 2021
Attention: All providers.
Effective Date: September 7, 2021
Providers should monitor the Texas Children’s Health Plan Provider Portal regularly for alerts and updates associated to the COVID-19 event. TCHP reserves the right to update and/or change this information without prior notice due to the evolving nature of the COVID-19 event.
Call to action: Texas Children’s Health Plan (TCHP) supports the delivery of telehealth (non-physician-delivered) distant site services to its members, and we have implemented special waiver provisions for its use during this disaster declaration.
New information effective September 7, 2021: Physical therapy delivered by telehealth after a telehealth initial evaluation or face to face evaluation may be approved for up to six months at a time.
- If a member is in need of therapy, and telehealth is not an option or cannot be delivered to an equivalent standard of care as in-person interaction, therapists should contact TCHP case management at 832-828-1430 or the member’s service coordinator. This way a plan of care and alternatives can be discussed to ensure the health and safety of the member.
- Access to free or low-cost internet service is available for under-served communities, including individuals over 65 and SNAP beneficiaries, if lack of internet presents a barrier to audiovisual interaction with a provider.
- Telehealth requires consent from the member, approved caregiver, parent, guardian, or Legal Authorized Representative (LAR). Verbal consent is permissible and should be documented in the member record.
- The Office of Civil Rights (OCR) has relaxed HIPAA requirements for telehealth to allow for the use of additional video capabilities to deliver services via telehealth. Texas Medicaid will recognize OCR’s HIPAA enforcement discretion as it relates to telehealth platform requirements. Please visit the OCR for the latest guidance: https://www.hhs.gov/hipaa/for-professionals/special-topics/hipaa-covid19/index.html
- Clinical evaluations required for the provision of new complex rehabilitation technology, such as power mobility and adaptive seating systems or augmentative communication devices, require the physical presence of the speech-language pathologist, occupational therapist, or physical therapist and should not be delivered via telehealth unless exceptional medical circumstances exist.
- Therapy assistants may provide telehealth within limits outlined in each discipline’s rules. Providers should refer to State Practice rules and National guidelines regarding supervision requirements for each discipline and practice accordingly.
- Telehealth for Physical, Occupational, and Speech Therapies:
The Health and Human Services Commission (HHSC) has given certain latitude to Medicaid Managed Care Organizations (MCOs) related to the flexibility they have to allow for remote delivery of medically necessary and appropriate covered services. These are stated in the HHSC notice to MCOs titled “Implementation of S.B. 670 to Impact Medicaid MCOs” (originally released Aug. 22, 2019, and re-released March 9, 2020).
In accordance with this guidance, TCHP extends its telehealth services policy at this time to Occupational, Speech and Physical Therapy providers under certain conditions defined below. Providers may provide covered, medically necessary services in a synchronous audio-video format so long as the telehealth services are provided within the scope, practice and limitations of the practitioner’s license. Services must be provided in accordance with the Texas Medicaid Program benefit rules as stated in the Texas Medicaid Provider Procedures Manual (TMPPM). TCHP will update providers as to how long this waiver will be in place in future communications.
Physical, Occupational and Speech Therapy services provided via Telehealth may be done under the following conditions due to the COVID-19 event:
- Providers are to clearly document in the Member’s medical record the format of the interaction and all appropriate record content of the visit.
- The provider must also specify in their visit note the appropriateness of remote delivery for the member.
- Telehealth may be provided via synchronous audio-visual format only.
- Audio-only visits are not permitted for speech, occupational and physical therapy services.
- For members under 13 years of age or with a diagnosis of intellectual and developmental disabilities, the entire Telehealth visit must be attended, supervised and supported by an approved caregiver, parent, guardian or LAR.
- Initial evaluations and re-evaluations may be conducted via telehealth synchronous audio-visual format with an appropriate practitioner.
- Speech therapy and occupational therapy delivered by telehealth after a telehealth initial evaluation may be approved for up to six months and physical therapy delivered by telehealth after a telehealth initial evaluation may be approved for up to six months.
- Providers with existing authorizations do not need an additional authorization to provide the eligible service via telehealth unless as stated otherwise in this Alert.
- Provider Reimbursement for Telehealth services
TCHP will reimburse providers for appropriately billed Telehealth services (see the Texas Medicaid Provider Procedures Manual (TMPPM)) at an equivalent rate of a face-to-face visit.
TCHP follows the Medical Policy for Telemedicine and Telehealth Services as written in the current Texas Medicaid Provider Procedures Manual – Telecommunication Services Handbook. Please reference http://www.tmhp.com/manuals_pdf/tmppm/tmppm_living_manual_current/2_Telecommunication_Srvs.pdf for additional information. Providers should verify that correct billing processes are in place including proper coding. Providers should use the modifier 95 on claims to indicate remote delivery and place of service 02.
Next steps for providers:
Providers are reminded to use appropriate coding as defined by Medicaid, or in the above-specified guidance for billing of Telehealth services.
If you have any questions, please email Provider Network Management at: firstname.lastname@example.org.