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COVID-19 Practice and Telehealth Updates

Thursday, March 19, 2020  
Posted by: Jamie Klufts
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COVID-19 Practice and Telehealth Updates

 
We want to acknowledge the upheaval and challenges you have all experienced over the past weeks, and how this is impacting clinical practice in multiple ways.
 
Clinicians are having to make difficult decisions, based on ever-changing circumstances, while balancing safety concerns and best interests of themselves, clients, and the greater community. We are impressed with what we have observed and heard from you, in terms of the strength, flexibility, and creativity shown in a time of crisis and change. And there has been an inspiring sense of shared purpose and generosity in our social work and NASW community. Thank you for the work you are doing and will continue to do during this time.
 
Below is information that we have gathered over the past week that may be helpful to you in planning your practice during this time, and will work to you keep you updated as time goes on.Information below covers:
  • Safety Considerations
  • Telemental Health
  • Upcoming CE Webinars Related to COVID-19
  • Chapter-wide COVID-19 Bulletins
 
As many of you move into telemental health for this period of time, we want to be a source of information and support, and will continue to keep you updated on shifts and changes to guidance and regulations.
 
Note: we are using the terms telehealth, telemental/tele-mental health, and teletherapy interchangeably.
 
SAFETY CONSIDERATIONS
 
We recommend folks follow theguidelines from the CDC, as well as directives and guidelines from state and local governments, which are changing sometimes on a daily basis. We cannot tell you what to do with your practices, other than to encourage you to follow guidelines from the CDC to the best of your ability and use sound judgement.
 
Highlights From CDC Include:
  • Use telework (in your case, teletherapy) as often as possible
  • Putdistance between yourself and otherpeople(the virus can spread between people who arewithin about 6 feet of one another)
  • Encourage clients who are sick,seniors, or those with significant underlying conditions (conditions related toheart, lung, kidney disease; diabetes; and conditions that suppress the immune system) to stay home, when possible
  • Practice good hand hygiene by washing hands frequently, for at least 20 seconds at a time, using soap and warm water. When not feasible, use a hand sanitizer that contains at least 60% alcohol.
  • If seeing clients in person, disinfect surfaces in between sessions
  • Make hand hygiene supplies readily available in workplaces, including in waiting rooms
  • Avoid handshakes and other forms of physical contact
  • Avoid touchingyour eyes, nose, and mouthwith unwashed hands
  • Cover your mouth and nosewith a tissue when you cough or sneeze or use the inside of your elbow, then discard used tissues and practice hand hygiene
  • Clean and disinfect frequently touched surfaces daily (doorknobs, light switches, tables, desks, keyboards, handrails, chair arms, etc.)
  • Increase ventilation by opening windows or adjusting air conditioning
 
TELEMENTAL HEALTH
 
As the situation has evolved, many clinicians have moved to incorporate tele-therapy in their practice, in part or fully. Some have used this medium already, and many are utilizing it for the first time. Below is information we hope is helpful to all at this time.
 
LICENSING CONCERNS
  • Per the Social Work Licensing Board, regulationsgenerally requirethat you be licensed in thestate where theclient isphysically located at the time ofservice.
  • A waiver may be available, but you need to contact the Board in other states to inquire aboutpossible exceptions.
  • National NASW is working to compile a master document with updates on relaxed licensing regulations and reciprocity during this time.
  • On March 17, 2020, Governor Baker issued an Executive Order that permits telehealth across state lines for college students.See order hereand additional details below:
  • The order includes the following language: "During the state of emergency, no Massachusetts board of registration shall prohibit any licensed nurse,social worker, psychologist, or medical doctor in good standing from providing services using telemedicine across State lines to their established patients who during the 2019-2020 academic year have been enrolled in a college or university located in Massachusetts."
  • Please note that we are not entirely certain about the scope of this yet and are awaiting further guidance from the Social Work Licensing Board and others
  • Our understanding is that you will not be reprimanded by the MA licensing Board if conducting telehealth across state lines with your pre-established college student clients
  • We still advise that you be in touch with the Board(s) in state(s) your college student client(s) currently reside/s until further guidance is issued. Some states have relaxed their regulations in this regard.
  • We would also advise consulting your liability insurance company
 
MALPRACTICE INSURANCE
  • Review your malpractice insurance policy regarding provisions around telehealth and where it is provided (for example, from your home in the event that you cannot use your office due to any quarantine or containment requirements in your area)
  • On March 17, 2020,NASW Assurance Services issued a bulletinto policyholders reminding them that the RRG professional liability policy provides coverage for tele-therapy as long as it is an accepted practice conducted according to the individual practitioner’s state regulations, state licensing board requirements, and HIPAA privacy standards which vary by state and are continually evolving
 
INSURANCE PLAN COVERAGE AND UPDATES (EXCLUDING MEDICARE)
  • For the current COVID-19 State of Emergency, many temporary policychangeshave been putinto place. The following are the changes that are in place as of March 19. We expect further changes and will keep this pageperiodically updated.
  • On March 15, 2020,Governor Baker issued an Emergency Order Expanding Access to Telehealth Services. Highlights from this Order:
  • Mandates commercial insurers to cover video and phone treatment, and to cover these services at rates equal to in-person treatment
  • Note that the mandate covers only in-network providers, and does not apply to "self-insured" plans, although theDivision of Insurance has issued instructions for insurersto encourage those plans to follow these mandates.
  • Also in March,MassHealth issued a Bulletin regarding Coverage and Reimbursementwhich applies to all its plans. Highlights from this include:
  • Permits qualified providers to deliver clinically appropriate, medically necessary MassHealth-covered services to MassHealth members via telehealth (including telephone and live video)
  • MassHealth is not imposing specific requirements for technologies used to deliver services via telehealth
  • Rates of payment for services delivered via telehealth will be the same as rates of payment for services delivered via traditional (e.g., in-person) methods
  • Providers must include Place of Service Code 02 when submitting a claim for services delivered via telehealth
  • Providers will be able to bill MassHealth for these services delivered via telehealth beginning April 1, 2020, for dates of service beginning March 12, 2020
  • Commercial insurancepolicytemporary changes(Note: this is not an exhaustive list. More updates will be provided as they become available.):
  • As of March 17, 2020,Cigna:
  • Is not requiring attestations
  • Is still requiring that providers use a HIPAA-compliant video platform for telehealth
  • Is allowing providers to conduct telephonic sessions when other technology is not available
  • For billing, enter “02” for Place of Service and “95” modifiers
  • Additional Cigna-specific information here
  • As of March 18, 2020,Blue Cross Blue Shield Massachusetts (BCBS-MA):
  • Is expanding the definition of "Telehealth" to include Telephonic sessions for all BH codes
  • Has added a Telehealth (and therefore Telephonic) benefit to all BCBS-MA plans, even those that didn't have it before
  • Is removing the HIPAA-secure requirements for Televideo platforms for the duration of the COVID-19 crisis
  • For billing, GT or 95 modifiers should be used
  • Additional BCBS-MA information here
  • As of March 19, 2020,Tufts Health Plan:
  • Will compensate providers at 100% of the in-office rate as specified in their provider agreements or fee schedules for telehealth.
  • Is allowing all Tufts Health Plan contracting providers to provide telemental health, including by telephone
  • Additional Tufts Health Plan information here
  • HIPPA:
  • On March 17, 2020, HHS issued a notification announcing it will "waive potential penalties for HIPAA violations against health care providers that serve patients through everyday communications technologies during the COVID-19 nationwide public health emergency." Full text ishere.
  • We advise caution with this, and to utilize HIPAA-compliant platforms if at all possible, or consult your liability insurance company.
  • Typically, you need to choose a HIPAA-compliant platform. Some are free, and some involve a cost, especially for full HIPAA compliance.
  • You may need to sign up with a Business Associate Agreement (BAA) for true HIPAA compliance. Read the platform policies carefully.
  • Some available platforms are listed below. None are endorsed by NASW. The first two listed have been recommended by a number of NASW members.
  • doxy.me
  • www.vsee.com
  • www.simplepractice.com/telehealth
  • www.vidyo.com
  • www.polycom.com
  • https://zoom.us/healthcare
  • www.securevideo.com
  • https://oncallhealth.us/
  • https://www.regrouptherapy.com/
  • https://www.wecounsel.com/
  • https://www.thera-link.com/
  • Attestations:Some plansrequire that you goto their website andattestto having anappropriate platform (Note: some are temporarily waiving this requirement)
  • Informed Consent:Some insurers may require a signedtelehealth informed consent form
  • This is good practice regardless of whether or not the insurers you work with require it
  • Here is aTelemental Health Informed Consent templatefrom NASW that you can use
  • Billing:Billing isgenerally done in thesame way as in-person sessions
  • Use same CPT codes as for in-person treatment
  • Most plans require amodifier of GT
  • Place of service code is 02
  • For reference, under typical circumstances, the following may be true:
  • Phonesessionsare notcovered by anyinsurance plans
  • Reimbursement for video telehealth varies dramatically; policies for each plan need to be checked
  • Reimbursement rates may be lower for telehealth as compared to in-personsessions
 
MEDICARE
  • On March 17, 2020, Medicare issued new guidelines that allow for reimbursement for telemedicine. It clearly covers video treatment; we are unclear as yet about telephone, and are continuing to investigate.
  • AMedicare Telemedicine Health Care Provider Fact Sheetis available from CMS
  • On Monday, March 23, 2020, National NASW is offering a FREE webinar exploring key developments in telehealth for Medicare.Learn more and register here.
 
ADDITIONAL GUIDANCE AND CONSIDERATIONS
 
Information regarding telemental health is changing rapidly.We're continuously advocating for clinical social work members at the federal and state level through all channels possible to make telemental health just as convenient as in-person therapy. Check our website frequently.The link above will be updated periodically. Note the date at the top which indicates when this telehealth guidance was last updated.
 
COVID-19 WEBINARS
 
We are offering a series of webinars during this time, the first of which will address topics directly related to the current situation, including telemental health.
 
 
We're constantly adding new web-based continuing education option to get you through this time. Check ourwebsite calendarfor new offerings.
 
CHAPTER-WIDE COVID-19 BULLETINS
 
In case you missed it, we also want to make you aware that NASW-MA has now sent 3 Bulletins to the entire membership with updates on COVID-19, social work practice, and our advocacy work for social workers and the clients and communities you serve. A fourth bulletin is forthcoming. See the 3 Bulletins that have already gone out below:
 
 
Sincerely,
Barbara
 
Barbara Burka, LICSW
Director of Clinical Practice
Director of Therapy Matcher
 
Information like this is only possible because of our members. If you found this helpful and are not yet an NASW-MA member,please join here. We look forward to counting you in our ranks... after all, we're stronger together.


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