SPECIAL BULLETIN COVID-19 #35: Telehealth Clinical Policy Modifications – Enhanced Behavioral Services

Important Notes to Bulletin #35

SPECIAL BULLETIN COVID-19 #35 replaces in its entirety SPECIAL BULLETIN #20 – Enhanced Behavioral Services.

Please note the change to Place of Service: Telemedicine and telepsychiatry claims should be filed with the provider’s usual place of service code per the appropriate clinical coverage policy and not Place of Service (POS) 02 (telehealth).

Background and General Guidance

NC Medicaid, in partnership with the DHHS Division of Mental Health, Developmental Disabilities and Substance Abuse Services (DMHDDSAS), has temporarily modified its Telemedicine and Telepsychiatry Clinical Coverage Policy to better enable the delivery of remote care to Medicaid and State-funded beneficiaries. These temporary changes are retroactive to March 10, 2020, and will end the earlier of the cancellation of the North Carolina state of emergency declaration or when the policy modification is rescinded, unless noted otherwise below. When the temporary modifications end, all face-to-face service requirements will resume.

Providers must ensure that Medicaid services outlined in this and other telehealth COVID-19 clinical policy bulletins can be safely and effectively delivered using telehealth in alignment with relevant NC Medicaid clinical coverage policies. Providers must consider a client’s behavioral, physical and cognitive abilities to participate in services provided using telehealth. The beneficiary’s safety must be carefully considered for the complexity of the services provided.

In addition, in situations where a caregivers or facilitators are necessary to assist with the delivery of telehealth services, their ability to assist and their safety should also be considered. Delivery of services using telehealth must conform to professional standards including but not limited to ethical practice, scope of practice, and other relevant federal, state and institutional policies and requirements including Practice Act and Licensing Board rules.

NC Medicaid has considered the recommendations of related licensing boards and associations and conducted a close evaluation of in-person service codes to develop the policy modifications outlined in this bulletin.

NC Medicaid and DMHDDSAS continue to evaluate telehealth policies and will release temporary flexibilities and guidance as needed throughout the state of emergency.

Modified Enhanced Behavioral Health Policies

8A. Enhanced Mental Health and Substance Abuse Services
- Intensive In-home Services
- Multisystemic therapy
- Mobile Crisis Management
8A-1. Assertive Community Treatment (ACT)
8A-6. Community Support Team (CST)
8G-1. Peer Supports Services (PSS)

The following protocols should be employed for the community based behavioral health services listed below unless the beneficiary refuses an in person visit:

1. Beneficiary should be screened either over-the-phone or in-person from 6 feet away for symptoms of COVID-19 (i.e., fever, cough, shortness of breath) and for close contact with a person diagnosed with COVID-19 in the past 14 days. If screen is negative, then proceed with an in-person visit, as clinically indicated. See Center for Disease Control Guidance for Risk Assessment and Public Health Management of Person with Potential Coronavirus Disease.

2. If beneficiary screens positive, assist the beneficiary in connecting to an appropriate medical provider if not already done. Then, as clinically appropriate, offer a HIPAA-compliant, real-time, two-way interactive audio and video telehealth appointment to proceed with the behavioral health intervention(s). (Note: please see OCR guidance relaxing technology requirements). If that option is not available, offer a non-HIPAA audio and video telehealth appointment with documented beneficiary or legal guardian consent. If two-way audio-visual options are not accessible to the beneficiary, offer a telephonic appointment. Eligible technologies are described in Special Bulletin COVID-19 #34: Telehealth Clinical Policy Modifications – Definitions, Eligible Providers, General Services and Codes.

3. All visits, regardless of modality of communication, must be clinically necessary to work on treatment goals as outlined in the Person-Centered Plan and to support beneficiary stabilization, safety and coordination of care.

4. Visit documentation must include the modality of communication used, the rationale for that modality, duration of intervention and that the beneficiary or legal guardian provided informed consent.

5. Interventions performed via these alternate modalities (i.e., not in person) may be provided by any treating staff within their scope and with appropriate and clinical supervision as required by treatment service definition.

HCPCS Codes

Code	Service
H2022	Intensive In-Home Services
H2033	Multisystemic Therapy
H2011	Mobile Crisis Management
H0040	Assertive Community Treatment (ACT)
H2015 HT, HO/HF/HN/U1/HM	Community Support Team (CST)
H0038	Peer Supports Services (PSS)

Modifiers

Provider(s) shall follow applicable modifier guidelines.

Modifier GT must be appended to the CPT or HCPCS code to indicate that a service has been provided via interactive audio-visual communication. This modifier is not appropriate for services performed telephonically or through email or patient portal.
Modifier CR (catastrophe/disaster related) must be appended to all claims for CPT and HCPCS codes listed in this policy to relax frequency limitations defined in code definitions.