SPECIAL BULLETIN COVID-19 #95: HIV Case Management Policy Allowances

Friday, June 5, 2020

NC Medicaid will allow temporary changes to Clinical Coverage Policy 12B for Written Physician Orders, Use of Remote Technology and Signature Requirements. These temporary changes are effective March 30, 2020 and will end the earlier of the cancellation of the North Carolina state of emergency declaration or when this policy modification is rescinded. 

Written Physician Orders

In accordance with Clinical Coverage Policy (CCP) 12B, Section 5.4, the HIV Case Management (CM) provider is required to obtain a physician’s or attending practitioner’s written order that details the need for initiation of HIV Case Management services. An additional written physician’s order from the beneficiary’s PCP must also be obtained to attest to the medical necessity of ongoing case management services beyond two consecutive months. In order to ensure the continued appropriateness for HIV CM services, if the beneficiary continues to have unmet needs, then the provider shall obtain a physician’s written order from the PCP annually. NC Medicaid shall accept the order of a physician, nurse practitioner or physician assistant in the determination for initiation or continuation of HIV CM services in accordance with G.S. §90-18.3 of the Physician Practice Act

Temporary COVID-19 Allowance(s): 

During the North Carolina state of emergency, NC Medicaid will permit the acceptance of electronic signatures for these purposes. 

Core Components: Assessment, Care Planning, Monitoring and Follow-Up Activities, and Reassessments (Use of Remote Technology and Flexibilities on Signature Requirements)

For the initial assessment, Case Managers shall screen and evaluate the prospective beneficiary’s status to determine the need for initial case management services. This is accomplished through an information gathering and decision-making process, which consists of intake and assessment. CCP 12B, Section 5.6.1 requires that the Case Manager’s signature is included on the assessment tool. The documentation in the assessment must contain observation of the beneficiary’s physical appearance and behavior during the assessment interview. 

CCP 12B, Section 5.6.2 requires that the care plan must be completed with the initial assessment, at the annual reassessment, and as needed, secondary to unanticipated events or changes in a beneficiary’s status. The care plan must be signed and dated by the Case Manager, and beneficiary or the beneficiary’s legally responsible representative. The Case Manager’s signature shall constitute their legal signature, consisting of first and last name with title or initials (if applicable), indicating licensure or certification.

CCP 12B, Section 5.6.4 requires that monitoring and follow-up activities consist of activities and contacts that are necessary to ensure that the care plan is effectively implemented and adequately addresses the needs of the beneficiary. Monitoring and follow-up activities are to be conducted monthly, but at least quarterly, and as frequently as necessary to fulfill these purposes.

CCP 12B, Section 5.6.5 requires the HIV CM provider to conduct a reassessment to determine the continued appropriateness of services and the continued need for services. The reassessment is conducted at least every 12 months and as needed, secondary to unanticipated events or changes in the beneficiary’s physical, mental or social status. Care plan progress, changes, and mutually agreed-upon goals must also be addressed in the care plan completed at reassessment.

Temporary COVID-19 Allowance(s):

During the North Carolina state of emergency, HIV CM providers may use remote technology/telemedicine as appropriate for intake and assessment, care planning, monitoring and follow-up activities, and reassessments, communications and other related activities that would normally occur on an in-person basis. Remote technology/telemedicine is defined as the use of two-way real-time interactive audio and video to provide care and services when participants are in different physical locations. If remote technology is used, the platform must be of a type consistent with one described by the HHS Office for Civil Rights. Additionally, during this period, if a written consent cannot be attained, a “verbal signature” or “verbal concurrence” from the beneficiary or legally responsible person may be obtained. The provider organization should maintain a record of the verbal signature or concurrence that clearly documents who took part in the verbal agreement, both at the provider organization and the beneficiary/legally responsible person. All assessment, care planning, monitoring and follow-up activities, and reassessment timelines should be followed in accordance with CCP 12B.


Medicaid Contact Center: 888-245-0179