Hurricane Helene Policy Flexibilities to Support Providers and Members – Dec. 12, 2024

This bulletin has updated end dates & additional flexibilities for Behavioral Health, Care Management, Innovations, and Long-Term Services & Supports.

This bulletin applies to NC Medicaid Direct and NC Medicaid Managed Care

Note: The flexibilities in this bulletin are retroactively effective from Sept. 26, 2024, through Feb. 28, 2025 (unless otherwise communicated by DHHS). Additional updates will be provided as they become available.

NC Medicaid is committed to North Carolina's response to and recovery from Hurricane Helene. We are working with county and federal partners to make it faster and easier for beneficiaries to receive - and for health care professionals to provide - Medicaid care and services.

North Carolina Governor Roy Cooper issued Executive Order 315 on Sept. 25, 2024, which declared a State of Emergency for North Carolina in anticipation of potential severe weather caused by the approach of Hurricane Helene. On Sept. 28, 2024, United States Department of Health and Human Services (HHS) Secretary, Xavier Becerra, determined that a Public Health Emergency (PHE) exists in North Carolina for Hurricane Helene, retroactive to Sept. 25, 2024.

This bulletin contains several new clinical policy flexibilities which have been implemented to support providers and members due to the Hurricane Helene PHE. The flexibilities listed in this bulletin are intended to benefit those members and providers directly impacted by Hurricane Helene. These flexibilities are also intended to alleviate burden for providers who are supporting impacted members and/or have additional patients (patient surges).  

It is recommended that providers only leverage the below listed flexibilities to support impacted beneficiaries or while impacted facilities and staff are recovering from Hurricane Helene. Providers should return to normal business operations as soon as possible to be compliant with NC Medicaid Clinical Coverage Policies (CCPs). 

Critical Update for all NC Medicaid Helene Flexibilities

NC Medicaid is extending the Hurricane Helene Medicaid flexibilities, which previously were effective through Dec. 31, 2024.

Now, all NC Medicaid Hurricane Helene flexibilities will be effective from Sept. 26, 2024, through Feb. 28, 2025.

NC Medicaid Hurricane Helene flexibilities for CAP/C, CAP/DA and the Innovations Waiver programs will now be effective from Sept. 26, 2024, through June 30, 2025.  

Please review the below additional flexibilities and also review the Hurricane Helene Policy Flexibilities to Support Providers and Members - Oct. 11, 2024 bulletin for other flexibilities implemented. The following sections from the Oct. 11, 2024, bulletin are effective through June 30, 2025:

  • Community Alternatives Program for Children (CAP/C) and Community Alternatives Program for Disabled Adults (CAP/DA)
  • Innovations and Traumatic Brain Injury (TBI) Waiver
    • Note: This section has been replaced in this bulletin, please see the Innovations Waiver section in this bulletin for the updated flexibilities. 

Behavioral Health Services

This section applies to NC Medicaid Direct and NC Medicaid Managed Care

NC Medicaid, in partnership with the DHHS Division of Mental Health, Developmental Disabilities and Substance Use Services (DMHDDSAS) and the Division of Health Service Regulation (DHSR), is temporarily modifying its Behavioral Health and Intellectual and Developmental Disability clinical coverage policies to better enable the delivery of care to NC Medicaid beneficiaries impacted by Hurricane Helene.

Behavioral health services must continue to be provided at an intensity and quality that meet the needs of the beneficiary and be consistent with goals and the intended outcomes of the service being provided. In addition, the service must be provided by staff at a ratio (as relevant) and with the expertise and scope necessary to meet the needs of each beneficiary.

The flexibilities listed in this bulletin are intended to benefit those members and providers directly impacted by Hurricane Helene. These flexibilities are also intended to alleviate burden for providers who are supporting impacted members and/or have additional patients (patient surges). It is recommended that providers only leverage the below listed flexibilities to support impacted beneficiaries or while impacted facilities and staff are recovering from Hurricane Helene. Providers should return to normal business operations as soon as possible to be compliant with NC Medicaid clinical coverage policies (CCPs).  

Behavioral Health Services delivered via telehealth or telephonically must follow the requirements and guidance in CCP 1-H, Telehealth, Virtual Communications, and Remote Patient Monitoring, found on the NC Medicaid Program Specific Clinical Coverage Policies webpage. Services delivered via telehealth must have the GT modifier appended to the Current Procedure Terminology (CPT) or the Healthcare Common Procedure Coding System (HCPCS) code to indicate that a service has been provided via interactive audio-visual communication. Services delivered via telephonically must have the KX modifier appended to the CPT or HCPCS code to indicate that a service has been provided via telephonic, audio-only communication.

The flexibilities in this section override the information in the corresponding subsection of the Behavioral Health Services section of the Hurricane Helene Policy Flexibilities to Support Providers and Members - Oct. 11, 2024 bulletin.

Note: While Tailored Plans and Local Management Entities/Managed Care Organizations (LME/MCOs) provide all the services listed in this section Standard Plans only offer a subset of the below behavioral health services.

1915(b)(3) and 1915(i) Services

  • Supported Employment for Individuals with Intellectual and Developmental Disabilities:
    • Service may be provided by two-way, real-time audio and video, as well as telephonically.
  • Individual and Transitional Support:
    • Service may be provided by two-way, real-time audio and video as well as telephonically.
  • 1915(b)(3) In-Home Skill Building and 1915(i) Community Living and Support:
    • Service may be provided by two-way, real-time audio and video.
  • Supported Employment (Initial and Maintenance) for Individuals with Mental Health Needs (Individual Placement and Supports):
    • Service may be provided by two-way, real-time audio and video, as well as telephonically. 

Children’s Developmental Services Agency (CDSA)

CCP 8J

  • For CDSAs and applicable independent practitioners who provide individualized family service plan (IFSP) services on behalf of a CDSA, the following services can be provided via Telehealth.  
    • CPT/HCPCS codes: H0031, H0036, H0036-HI, H0036-HM, H0036-HQ, H0036-TL, T1017-HI.
  • CDSAs who provide outpatient specialized therapy services are also able to leverage the Helene Flexibilities listed in the Outpatient Specialized Therapies section of the Hurricane Helene Policy Flexibilities to Support Providers and Members - Oct. 11, 2024 bulletin.

Intensive In-Home

CCP 8A

  • Waive prior approval and reauthorization request.  
  • Waive staff training requirements within 30 and 90 days of employment, if unable to be obtained during the state of emergency.
  • Waive the two-hour per day minimum service provision and reduce to one-hour per day to bill the service.
  • Waive requirement that staff must be dedicated to the team.
  • Waive requirements that 60% of contacts should be face-to-face and 60% of staff time should be spent outside of the facility.
  • Waive team-to-family ratio of 1:12.
  • Allow for supervision by any licensed professional on the team or employed by the provider agency, within scope and training, if Team Lead is unavailable.
  • Service may be delivered via real-time, two-way interactive audio and video telehealth.
  • Service may be provided telephonically if telehealth is not accessible.
  • Allow for the 12 contacts required in the first month to be provided via telehealth if the provider is unable to provide the service in person. If the service cannot be provided via telehealth, the service may be provided telephonically.  

Innovations Waiver (effective through June 30, 2025)

This section applies to NC Medicaid Direct and NC Medicaid Managed Care 

The flexibilities in this section override the information listed in the Innovations and Traumatic Brain Injury (TBI) Waiver section of the Hurricane Helene Policy Flexibilities to Support Providers and Members - Oct. 11, 2024 bulletin.

The flexibilities listed below are intended for NC Innovations beneficiaries in NC Medicaid Direct and NC Medicaid Managed Care who were impacted by the hurricane, either directly or due to staff impacted and unable to provide services. These flexibilities are effective Sept. 26, 2024, through June 30, 2025, unless otherwise communicated by DHHS. These flexibilities are not intended to be utilized by every waiver beneficiary. Tailored Plans and LME/MCOs should assess the continued need for these flexibilities case-by-case.  

Note: Based on the impact of Hurricane Helene, and NC Medicaid confirming that there were no Traumatic Brain Injury (TBI) waiver beneficiaries who were impacted, the TBI Waiver flexibilities for Hurricane Helene were removed. 

NC Medicaid will seek approval for Appendix K authority for the following Innovations Waiver Flexibilities. NC Medicaid is evaluating the need for additional flexibilities and as more flexibilities are approved that information will be published via an updated NC Medicaid Bulletin.  

The flexibilities below are specific to beneficiaries directly impacted by Hurricane Helene. 

  • Allow Relatives of adult and minor waiver beneficiaries, as well as the Employer of Record (EOR) who reside in the home and out of the home to provide services.
    • Relatives of adult waiver beneficiaries and minor waiver beneficiaries may provide Community Living and Supports, Supported Employment and Supported Living. This should only be used for cases when direct support staff is impacted by Hurricane Helene and not able to provide services.
  • Additional services hours may be provided without prior authorization (PA) due to issues related to Hurricane Helene. This should only be in cases where additional hours are needed by the beneficiary because of the hurricane, and either the beneficiary could not reach the provider to notify them of this need or the provider did not have the time/ability to submit a PA.
  • Allow the replacement or repair of existing home and vehicle modifications damaged by Hurricane Helene, even when cost of repair or replacement will exceed the Innovations Waiver limit.
  • Innovations Waiver services may be provided out of state without PA by the Tailored Plan and LME/MCO when the Innovation Waiver beneficiary is displaced and requires out- of- state shelter. Respite services may also be provided out of state for individuals who have been displaced due to Hurricane Helene.
  • Allow direct service hours to be provided in alternatives settings: hotels, shelter, church, or alternative facility-based settings or the home of a direct care worker due to Hurricane Helene-related impact.
  • Allow respite to be provided when the beneficiary’s family is out of state due to evacuation or displacement, until they return home. 
  • Allow prior approval to be waived up to 60 days, when beneficiaries are displaced out of state by Hurricane Helene. Or the individual must transfer to a new provider for delivery of services.
  • Allow annual reassessments of level of care that exceeds the 60-calendar-day approval requirement, beginning on Sept. 25, 2024, to remain open, and services will continue for three months to allow sufficient time for the Tailored Care managers to complete the annual reassessment paperwork. Additional time may be awarded on a case-by-case basis when conditions from Hurricane Helene impedes this process. Annual reassessments of level of care may be postponed by 90 calendar days to allow sufficient time to complete the annual reassessment and accompanying paperwork.
  • Allow Community Living and Supports to be provided in acute care hospital or short-term institutional stay, when the waiver beneficiary is displaced from home due to injury from Hurricane Helene and the waiver participant needs direct assistance with activities of daily living (ADLs), behavioral supports or communication supports on a continuous and ongoing basis and such supports are otherwise not available in these settings.  
  • Allow beneficiaries to receive fewer than one service per month during this amendment without being subject to discharge.
  • Allow in person face-to-face monthly/quarterly Tailored Care Manager or Care Coordinator monitoring requirements with the beneficiary to be waived when the beneficiary is not physically accessible. In these cases, virtual and telephonic monitoring will be conducted in compliance with HIPAA requirements.
  • Allow Support Intensity Scale (SIS) to be waived. The SIS can be completed virtually when appropriate and accessible.
  • Waive the 25% cap and allow telehealth to be provided up to 100% for Community Living Supports, Day Supports, Supported Employment and Supported Living.
  • Allow approved services in the Individual Support Plan (ISP) to exceed amount, frequency, scope, and duration to plan the needs of waiver participants who were impacted by Hurricane Helene.  
    • The amount shall not exceed the Innovations cap/limit for services as noted in Clinical Coverage Policy 8P.  
    • If the QP (qualified professional), i.e., provider agency, is not able to sign the plan.  The Tailored Care Manager or Care Coordinator should make the best efforts to coordinate with QP (telephonically or virtually) to review ISP updates.
  • Allow a change from Day Support Group to Day Supports Individual without a change in the ISP or prior authorization for Waiver individuals impacted by Hurricane Helene. The ISP should be updated as soon as the provider is able to meet with the Waiver member either telephonically or virtually.
  • Allow utilization review of ISP and/or revised ISPs to be reviewed and approved retroactively to Sept. 25, 2024 (if the request meets medical necessity) for individuals impacted by Hurricane Helene.
  • Allow annual ISPs that are expiring and currently meeting a waiver participant’s needs impacted by Hurricane Helene to be extended by three months.  
    • The requirement to approve the plan by the last day of the birth month may be extended by three months after the birth month, provided that telephonic or virtual monitoring is conducted to ensure the plan continues to meet the participant's needs.
  • Allow replacement of existing Assistive Technology damaged by Hurricane Helene when cost of repair or replacement will exceed the Innovations Waiver limit.
  • Allow Utilization review and approval of ISPs only with Tailored Care Manager or Innovations Care Coordinator signature if QP (provider agency) is not able to sign the plan. The Tailored Care Manager or Care Coordinator should make the best efforts to coordinate with QP (telephonically or virtually) to review ISP updates.
  • Waive training requirements within 90 days of employment for new hires, if staff are unable to be obtained at time of employment during the state of emergency. Trainings specifically to ensure management of member health and safety (i.e., Seizure management, Behavioral health crisis management) are not waived.
  • Waive training requirements for existing staff for 90 days to continue providing services if staff are unable to obtain training during the state of emergency.
  • Allow Residential Supports in place of Community Living and Supports, when an individual requires out-of- home placement, and a relative as a Direct Support Provider or EOR is not providing services. Allow service transition without a change in the Individual Support plan or prior authorization for Waiver individuals impacted by Hurricane Helene. The ISP should be updated as soon as the provider is able to meet with the Waiver member/family telephonically or virtually.

Tailored Plans and LME/MCOs must provide an assessment of the health and well-being status of each impacted Innovations waiver beneficiary to NC Medicaid at the conclusion of the state of emergency. 

Tailored Care Management  

This section applies to NC Medicaid Direct and NC Medicaid Managed Care

The flexibilities listed below are intended for NC Medicaid Direct and NC Medicaid Managed Care beneficiaries who were impacted by the hurricane either directly or due to staff impacted and unable to provide services. The flexibilities are retroactively effective Sept. 26, 2024, through Feb. 28, 2025 (unless otherwise communicated by DHHS).

NC Medicaid will allow the following flexibilities for Tailored Care Management: 

  • Two-way instant messaging/texting between the Care Managers, Care Manager Extenders or Care Management Supervisor and the member/Legally Responsible Person.  
    • Tailored Care Management services provided via two-way instant messaging/texting will constitute a Qualifying Contact, as applicable, for members impacted by Hurricane Helene.  
    • Qualifying Contacts include two-way instant messaging/texting with a member or a legally responsible person/guardian when the member is displaced from home or when the Care Management Supervisor, Care Manager or Care Manager Extender is not able to travel to the member’s home because of their own impact, flooding, closed roads due to impact of the hurricane. To qualify as a qualifying contact, two-way texting/instant messaging requires a response from the member/legally responsible person/guardian.  
    • Contacts must be delivered in a manner that ensures the security of protected health information and are in compliance with all state and federal laws, including HIPAA and requirements related to records retention. Only encrypted (secure) transmission/texting of a member’s protected health information (PHI) is permissible.
  • Tailored Care Management Comprehensive Assessment and Care Plan Flexibilities  
    • Annual care management comprehensive assessments expiring and currently meeting a member’s needs may be extended by 90 days.  
    • During the Helene public emergency, Tailored Care Management providers should prioritize assessing the safety and immediate needs of the member. Providers can assist members with their immediate needs prior to completion of the care management comprehensive assessment and provide any urgent links/supports to address those needs.
    • The above flexibilities do not apply to members receiving Innovations or 1915(i) services whose Care Plan and ISP must be completed in accordance with federal time standards.  
      • Please refer to the "Innovations Waiver" flexibilities in this bulletin for details on care management flexibilities for Innovations Waiver members.
  • Care Manager Extender Functions Flexibilities  
    • To support Tailored Care Managers who may be over capacity due to the impact of the disaster, Care Manager Extenders may gather information for the completion of a care management assessment during this flexibilities time period.
  • Documentation of Service Notes  
    • Tailored Care Management documentation requirements for services rendered to members/guardians impacted by the Hurricane may be documented within 30 days of the completed contact.  
    • All contacts completed with a member or on behalf of member should be documented in the service record as soon as possible.  
  • Relax Training Requirements for Tailored Care Management Care Managers, Supervising Care Managers and Care Manager Extenders 
    • To increase capacity of care management teams during the timeframe of the Hurricane Helene PHE:  
      • Care Manager Supervisors, Care Managers, Care Manager Extenders may deploy to the field without completion of the core Tailored Care Management trainings.  
      • Tailored Care Management Supervisors, Care Managers and Care Manager Extenders may extend the due date for refresher trainings to 30 days following the end of the public emergency related to Hurricane Helene. 

Long Term Services and Supports (LTSS)

This section applies to NC Medicaid Direct and NC Medicaid Managed Care

The flexibilities in this section are additions to the information in the Long-Term Services and Supports section of the Hurricane Helene Policy Flexibilities to Support Providers and Members - Oct. 11, 2024 bulletin. 

LTSS Training Flexibilities

These flexibilities below are intended for NC Medicaid Direct and NC Medicaid Managed Care providers who were impacted by the hurricane either directly or due to staff impacted retroactively effective Sept. 26, 2024, through Feb. 28, 2025, (unless otherwise communicated by DHHS). NC Medicaid will temporarily waive staff training requirements for LTSS providers if those trainings are unable to be obtained during the Hurricane Helene PHE. 

Contact Information

Health Plan Provider Service Lines

Standard Plans

  • AmeriHealth Caritas: 1-888-738-0004 (TTY: 1-866-209-6421)  
  • Carolina Complete: 1-833-552-3876 - Option 3
  • Healthy Blue: 1-844-594-5072
  • United Healthcare: 1-800-638-3302
  • WellCare: 1-866-799-5318  

Tailored Plans and LME/MCOs

  • Alliance Health: 1-855 759-9700
  • Partners Health Management: 1-877-398-4145
  • Trillium Health Resources: 1-855-250-1539
  • Vaya Health: 1-866-990-9712

NC Medicaid Direct Contact Information

NCTracks Call Center: 1-800-688-6696
Provider Ombudsman: 1-866-304-7062, Medicaid.ProviderOmbudsman@dhhs.nc.gov 

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