This page is dedicated to policy updates and resources related to the COVID-19 outbreak in Mississippi and the nation.
Coding “Cheat Sheet” for COVID-19 and Telehealth (supplied by the AMA)
Mississippi Division of Medicaid (DOM)
Effective through April 30, 2020, DOM’s Emergency Telehealth Policy will allow additional use of telehealth services to combat the spread of Coronavirus Disease 2019 (COVID-19). Details of enhanced services include the following:
- A beneficiary may access telehealth services from his or her home.
- A beneficiary may use his or her personal cellular device, computer, tablet, or other web camera-enabled device to seek and receive medical care with a qualified distant-site provider.
- The requirement for a telepresenter to be present with the beneficiary is waived when the beneficiary receives telehealth services in the home.
- Any limitation on the use of audio-only telephonic consultations is waived.
Any provider that is eligible to bill DOM for services is now allowed to serve as a distant site provider, including Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs).
These enhanced telehealth options will be available in fee-for-service Medicaid, Medicaid managed care, and the Children’s Health Insurance Program.
Additional information on policies, coding, and reimbursement related to the COVID-19 outbreak will continue to be added to a resource page on the agency’s website at https://medicaid.ms.gov/coronavirus-updates/.
Blue Cross and Blue Shield of Mississippi
Effective March 16 through April 30, 2020, the BCBSMS COVID-19 Pandemic Telemedicine Policy allows Healthcare Providers to provide medically necessary services that can be appropriately delivered via audio and/or visual consultation.
Specific guidelines are noted below:
- Telemedicine, in this Policy, is appropriate for visits for either low complexity, routine or ongoing evaluation and management for established patients, as well as addressing new and established patient needs related to COVID-19 symptoms.
- Member cost-sharing (co-pays, deductibles, etc) and benefit levels will apply according to the Blue Cross and Blue Shield Member’s Health and Wellness Benefit Plan.
- BCBSMS will waive the co-pay for all Network Provider covered telemedicine visits for fully-insured Members.
For routine evaluation and management of established patients, Healthcare Providers (MDs, DOs and professional Allied Providers, such as Nurse Practitioners) may bill for established patient evaluation and management codes up to a Level 3 (CPT codes 99211, 99212 and 99213) with a place of service 02 (Telehealth), regardless if provided telephonically or using visual equipment. Please note, however, providers should only bill for telephonic visits when the provider speaks directly to the patient. Providers should not bill BBSMS for services when only office staff and/or a nurse speaks with the patient, regardless if a provider was consulted.
To address new patient needs relative to COVID-19 symptoms, Healthcare Providers (MDs, DOs and professional Allied Providers, such as Nurse Practitioners) may bill for new patient evaluation and management codes up to a Level 2 (CPT codes 99201 and 99202) with a place of service 02 (Telehealth), regardless if provided telephonically or using visual equipment. Please note, however, providers should only bill for telephonic visits when the provider speaks directly to the patient. Providers should not bill BCBSMS for services when only office staff and/or a nurse speaks with the patient, regardless if a provider was consulted.
Behavioral Health Providers (Psychiatrists, Psychologists, Licensed Professional Counselors, and Licensed Certified Social Workers) may bill for established patient visits and evaluation and management codes as follows with a place of service 02 (Telehealth): -CPT codes 99211, 99212 and 99213 – CPT code 90832
All services must be medically necessary and documented as part of the Member’s permanent health record, to include the amount of time spent with the patient.
Patient must give consent to be treated virtually and/or telephonically and appropriately documented in the medical record prior to initiation of telemedicine.
This policy only applies to medically necessary visits that are patient-initiated or are replacing a previously scheduled visit.
UnitedHealthcare is waiving the Centers for Medicare and Medicaid’s (CMS) originating site restriction and audio-video requirement for Medicare Advantage, Medicaid, and Individual and Group Market health plan members from March 18, 2020 until June 18, 2020. Eligible care providers can bill for telehealth services performed using interactive audio-video or audio-only, except in the cases where we have explicitly denoted the need for interactive audio/video, such as with PT/OT/ST, while a patient is at home.
COVID-19 Testing-Related Telehealth Visits
From Feb. 4, 2020 and throughout this national emergency, UHC will waive member cost sharing for in-network and out-of-network COVID-19 testing-related telehealth visits, including both interactive audio-video and audio-only.
Cost Share Waived for In-Network Telehealth Services
UHC will also waive cost sharing for in-network telehealth services for medical, outpatient behavioral and PT/OT/ST services from March 31, 2020 until June 18, 2020 for Medicare Advantage, Medicaid, and Individual and fully insured Group Market health plan with opt-in available for self-funded employers.
For medical and outpatient behavioral telehealth visits, providers can utilize both interactive audio-video and audio-only. For PT/OT/ST provider visits, interactive audio/video technology must be used. For more details on PT/OT/ST telehealth, please click here.
Cost sharing will be waived for in-network telehealth visits. According to plan benefits, out-of-network providers also qualify for telehealth and member benefit and cost sharing will apply, if applicable.
Mississippi Board of Medical Licensure (MSBML)
The Mississippi Board of Medical Licensure created recent policy changes that are in effect during the Governor’s State of Emergency:
- Providers are highly encouraged to utilize telemedicine whenever possible for treating patients to avoid unnecessary clinic visits and possible exposure
- The Mississippi Board of Medical Licensure shall allow non-Mississippi licensed physicians to provide telemedicine within Mississippi
- Urine drug screens are not required for controlled substances, but use of the MPMP is still enforced.
Mississippi Board of Nursing (MSBN)
The Mississippi State Board of Nursing created recent policy changes that are in effect during the Governor’s State of Emergency:
- APRNs are highly encouraged to utilize telemedicine whenever possible for treating patients to avoid unnecessary clinic visits and possible exposure
- Non-Mississippi licensed APRNs with an unrestricted out of state licensure are allowed to provide telemedicine within Mississippi
- Point of service drug testing is not required for controlled substances, but use of the MPMP is still enforced.
Centers for Medicare and Medicaid Services (CMS)
Medicare will pay doctors and hospitals for a broad range of telehealth services on a temporary basis, effective March 6. The program will pay for office and hospital telehealth visits and include a wide range of providers including nurse practitioners, clinical psychologists and social workers. Telehealth visits will be reimbursed for the same amount as in-person visits.
Elimination of Geographic Restrictions
March 6, 2020, Medicare began temporarily paying clinicians to furnish beneficiary telehealth services residing across the entire country. In addition, the beneficiary generally could not get telehealth services in their home.
Services and Providers
Under this Section 1135 waiver expansion, a range of providers, such as doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers, can offer a specific set of telehealth services. The specific set of services beneficiaries can get include evaluation and management visits (common office visits), mental health counseling, and preventive health screenings. Beneficiaries can get telehealth services in any health care facility including a physician’s office, hospital, nursing home or rural health clinic, as well as from their homes.
Diagnostic Billing Code Tookit
CMS recently published a telehealth toolkit to assist providers in the new telehealth policies and diagnostic billing codes.
Rural Health Clinic Code Updates
Distance site telehealth visits for RHCs must be billed with HCPCS code G2025. For distant site services rendered between January 27th, 2020, and June 30th, 2020, RHCs must bill G2025 with modifier CG. After July 1, RHCs will no longer need modifier CG. Furthermore, modifier 95 is completely optional for all G2025 claims.
Audio-only services such as the audio E/M services 99441, 99442, and 99443, may now be billed as G2025 services.
RHC Telehealth Reimbursement Prior to June 30, 2020
All CMS G2025 claims prior to June 30, 2020 must be billed with modifier CG and will reimburse at the RHC’s all-inclusive rate. Beginning July 1, 2020 all these claims will be reprocessed to $92.03. After July 1st, the CG modifier is no longer needed, and these claims will pay $92.03 from the onset. Guidance has been provided that CMS may recoup the difference between the all-inclusive rate paid prior to July 1, and the $92.03 fee schedule.
Co-Pay Requirements Waives
The Office of Inspector General stated that if a provider wishes to waive collection of the 20% coinsurance, they can and the OIG will not consider this a violation of the antikickback rules. This is voluntary.
Hospital outpatient departments can now bill for certain Medicare telehealth services, and CMS is waiving limitations on the types of clinical practitioners that can provide Medicare telehealth services for the duration of the COVID-19 emergency.
Therapy Telehealth Services Now Allowed Through CMS
Physical therapists, occupational therapists and speech language pathologists are now able to provide telehealth services.
As part of the CARES Act, Congress has authorized Rural Health Clinics to be the “distant site” for telehealth visits. Until now, RHCs could only be the originating site for these visits. CMS is working on the guidance necessary to allow you to begin submitting claims for these visits but you can begin doing these visits as of March 27th Providers may need to hold these claims until billing guidance is issued.
The CARES Act establishes a $100 billion grant fund exclusively for health care providers who are enrolled in the Medicare and Medicaid program. The purpose of this fund is to provide grants to healthcare providers who have experienced a reduction in revenue due to the COVID19 pandemic.
The CARES Act creates the Paycheck Protection Loan Assistance program which expands and modifies an existing Small Business Administration (SBA) Loan program. What makes this “loan” program unique is that the government will be able to FORGIVE all or most of this loan if the business does not terminate employees during the pandemic. If the small business uses the loan to cover monthly expenses such as: payroll, continuation of health benefits for employees, rent, mortgage, utilities and interest on other loans you may have, then that portion of the loan will be forgiven.
Department of Health and Human Services (HHS)
During the COVID-19 national emergency, which also constitutes a nationwide public health emergency, covered health care providers subject to the HIPAA Rules may seek to communicate with patients, and provide telehealth services, through remote communications technologies. Some of these technologies, and the manner in which they are used by HIPAA covered health care providers, may not fully comply with the requirements of the HIPAA Rules.
OCR will exercise its enforcement discretion and will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules against covered health care providers in connection with the good faith provision of telehealth during the COVID-19 nationwide public health emergency. This notification is effective immediately.
This may include:
- Unencrypted Zoom / GoToMeeting, etc
This should not include:
- Facebook live
- Other publicly facing streaming services
Emergency Contact Information
|Office of the Governor of Mississippi
|Mississippi State Department of Health||(877) 978-6453|
|Centers for Disease Control and Prevention||(800) 232-4636|