SPECIAL BULLETIN COVID-19 #76: Telehealth and Virtual Patient Communications Clinical Policy Modifications - Behavioral Health Service Flexibilities – (b)(3) Services

Effective April 30, 2020, NC Medicaid in partnership with the DHHS Division of Mental Health, Developmental Disabilities and Substance Abuse Services (DMHDDSAS), is temporarily modifying its Behavioral Health and Intellectual and Developmental Disability (I/DD) Clinical Coverage Policies to better enable the delivery of care to NC Medicaid, NC Health Choice and State-funded individuals in response to the COVID-19 Pandemic. 

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the earlier of the cancellation of the North Carolina state of emergency declaration or when the policy modification is rescinded. When the temporary modifications end, all prior service requirements will resume.  

During the North Carolina declared state of emergency, services must continue to be provided at an intensity and quality that meet the needs of the individual, consistent with the individual’s goals and the intended outcomes of the service. In addition, the service must be provided in the most appropriate way to meet the needs of each individual.  

Throughout this bulletin, “telehealth” means two-way real-time interactive audio and video to provide care and services when participants are in different physical locations. Telehealth does not include telephonic provision of services; when telephonic provision is permitted, it is specifically noted below. 

• Providers must ensure that services outlined in this bulletin can be safely and effectively delivered using telehealth or telephonic modalities. 
• Providers must consider an individual’s behavioral, physical and cognitive abilities to participate in services provided using telehealth or telephonic interventions. 
• The individual’s safety must be carefully considered for the complexity of the services provided. In situations where caregivers or facilitators are necessary to assist with the delivery of telehealth or telephonic services, their ability to assist and their safety should also be considered when the individual needs physical assistance. 
• Delivery of services using telehealth or telephonic interventions 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 relevant Practice Acts and Licensing Board rules.

Table 1: Behavioral Health (b) (3) Emergency Flexibilities by Service

*For information on flexibilities for Supported Employment for individuals with Mental Health needs, please see SPECIAL BULLETIN COVID-19 #60: Fidelity Reviews Delayed for Current Individual Placement and Support (IPS) and Assertive Community Treatment (ACT) Teams

** For NC Innovations waiver flexibilities, please see the following bulletins:

• SPECIAL BULLETIN COVID-19 #55: NC Medicaid Receives Approval for Expanded Flexibilities for Home and Community-Based Services
• SPECIAL BULLETIN COVID-19 #23: NC Innovations and NC TBI Waivers Community-Based Services (HCBS) Flexibilities for Waiver Beneficiaries Enrolled in 1915(c) HCBS Waivers

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 two-way real-time 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. 
• Detailed guidance on modifiers by procedure code is included in the table below. 

Table 2: Behavioral Health (b) (3) Emergency Flexibilities Modifier Guidance

*** For modifiers applicable to NC Innovations waiver flexibilities, please see SPECIAL BULLETIN COVID-19 #75: Telehealth and Virtual Patient Communications Clinical Policy Modifications - Behavioral Health Service Flexibilities – Innovations and TBI Waivers Appendix K and Developmental Disability State Funded Benefit Plans

Billing Unit

Provider(s) shall report the appropriate code(s) used which determines the billing unit(s).

Place of Service

Telemedicine and telepsychiatry claims related to COVID-19 shall be filed following the guidance of the LME-MCO.

Additional Resources

• NC Medicaid Telehealth Billing Code Summary Chart
• NC Medicaid Telehealth Resources website
• NC Medicaid COVID-19 Resources website