Provider Questions & Answers
General Note: Network180 is not directing or advising individual providers on how to handle specific operational issues presented by COVID 19. The best responses may differ somewhat by agency and therefore decisions need to be made by those organizations. Providers should focus on balancing the service needs of the population with the need to take precautions and slow the spread of COVID 19. Providers are also expected to follow guidelines released by the CDC, MDHHS, LARA and the Kent County Health Department. To assist providers, Network180 is sharing basic considerations and, in some cases, the approach Networ180 has decided to take with its services, noting again that Network180 is sharing these approaches as examples and not dictates to others.
Q1: How should we handle the development of individualized plans of service?
A1: Individualized plans of service should be completed via telephone or other telehealth interventions whenever possible. We recognize that COVID 19 will present challenges for the person centered planning process and we encourage providers to reach out and share any issues they are encountering with completing and certifying plans.
Q2: Will providers who have nursing staff available to train on the topic of medication administration, required for staff to pass medications in direct care settings, be permitted to provide these trainings since Network180 has discontinued them for the time being?
Q3: How should consents that were obtained over the phone during telehealth interventions be managed?
A3: Attempts should always be made to obtain an electronic signature by scanning and emailing, signing with a stylus, or other electronic methods. If an electronic signature is not possible to obtain, it is up to the individual agency to determine the consent practice for their organization that best accommodates client needs and documentation requirements during the COVID 19 crisis. For what it is worth, Network180’s current practice is to enter N/A on the signature line of the form and note in the printed name field that consent was obtained telephonically.
Q4: Can Network180 suggest a few video platforms that are suitable for providers who want to do telehealth interventions?
A4: Due to the current COVID-19 pandemic, providers are looking to implement or expand telehealth to serve clients virtually whenever possible. Under HIPAA, covered entities such as healthcare providers are expected to follow the Security Rule and reduce the risk that electronic protected health information (ePHI) is breached during transmission.
All telephone interventions are HIPAA compliant.
To implement telehealth, a provider may also want to work with a video technology vendor. As a business associate, that vendor should be willing to sign a Business Associate Agreement (BAA) that confirms that the vendor will follow HIPAA and protect ePHI on behalf of the healthcare provider.
Network180 has agreed to the Microsoft BAA and subscribes to Microsoft's Office 365 services. This covers us to use Skype for Business and Microsoft Teams in a HIPAA-compliant manner. All Network180 staff have a Skype for Business application available for their use. Any telehealth session initiated by Network180 staff that then includes a Network180 client and another provider would be covered under our BAA with Microsoft.
Other providers that do not yet have a BAA should look for a telehealth vendor that is willing to sign one. Microsoft Office 365 with Skype for Business is one possible solution. Other general-purpose video conferencing vendors that are willing to sign BAAs include GoToMeeting, and Zoom (Zoom for Healthcare). There are also many videoconferencing vendors that specialize in telehealth.
A detailed discussion of HIPAA, the Security Rule, and exceptions to each, is outside the scope of this quick memo. Each healthcare provider must perform its own due diligence when deciding how best to serve its clients while remaining in compliance with HIPAA.
Q5 – How do providers document and bill contacts done through telehealth?
State Medicaid Bulletin MSA 20-12 "COVID-19 Response: Relaxing Face-to-Face Requirement" has made clear that providers should continue to serve clients despite the restrictions imposed by the COVID-19 emergency.
Network180's EHR vendor PCE Systems has explained how remote services will be billed through Nova in accordance with MSA 20-12. If a claim would have been telehealth by Michigan's rules prior to the COVID-19 emergency, then the same billing process remains in place. However, because MSA 20-12 relaxed rules to allow greater use of telemedicine/telehealth, the state has also added additional requirements for billing claims: (emphasis ours)
"During this time, providers may use telephonic, telemedicine and video technology ... for program functions that require in-person communication [with consent to the method]. ... The use of these alternative methods must be documented as a comment on the provider claim and in the beneficiary record, as appropriate."
When documenting the service in their own system, providers should remember the following:
- Verify that the service is billable as expanded telehealth by checking the state’s COVID19 Encounter Code Chart, available on the Network180 Web site COVID19 section.
- Find a place in your electronic record to record whether the service was provided over the phone (audio-only) or through telehealth (with video). For Network180's direct services, we make the designation in our service activity log (SAL) using custom places of service that will later be converted to 02 for reporting to the state. One custom place is telephone-covid19 and the other is telehealth-covid19. This lets us report the appropriate comment in our own billing.
Providers should consult with their vendors to determine how best to document the alternative method used.
When billing the COVID-19 telehealth service through Nova, the rules will be:
- Specify 02 as the place of service
- Include the GT modifier
- Include a comment on the claim indicating whether the service was phone (audio-only) or telehealth (video). This can be entered as a note on a manually-entered claim in Nova, or specified as a claim comment in the 837 EDI file.
- SERVICES PROVIDED VIA TELEPHONE UNDER COVID19 ALLOWANCE
- SERVICES PROVIDED VIA TELEHEALTH UNDER COVID19 ALLOWANCE
Billers or tech staff with Nova experience know that Nova requires start/stop times for many services. This is also reported as a claim comment. For example, the following is a claim comment that a service was provided from 10:01am to 10:19am
The following is a suggested claim comment for a phone-based COVID-19 service with a start/stop time. There are two spaces between SVCTIME and the time range, and two spaces from the time range to the phone/health comment.
NTE*ADD*SVCTIME 1001-1019 SERVICES PROVIDED VIA TELEPHONE UNDER COVID19 ALLOWANCE~
Q6 – How will providers remain financially viable if fee-for service activities are suspended?
A6 - For agencies that experience cash flow challenges, Network180 will be expanding its Advance policy to this situation. Advances should be expected to be repaid on or before September 30, 2020. Network180 understands that provider agencies are weighing the difficult line between financial losses and caring for consumers. We expect each provider implement its own operational protocol to address these challenges. Please continue to make Network180 aware of operational plans that may impact clients. The information you provide assists us when advocating for additional funding or service codes.
SEE: MDHHS Telepractice Memo 03.19.20
SEE: MSA 20-13
Medicaid Bulletin MSA 20-12 discusses COVID-19 Response: Relaxing Face-to-Face Requirement, and is issued on March 20, 2020.
Q7 - I just read the Governor's Executive Order 2020-7 on temporary restrictions on entry into health care, residential, congregate and juventile justice facilities. Our interpretation of this order is that we are not to allow visits by parents/guardians/foster parents. Do you have a similar interpretation?
A7 - Yes, Executive Order 2020-07 did rescind the 2020-06 order and facilities are not to allow visits by parents/guardians/foster parents unless the individual in the facility is 21 years of age or younger. There was an update to E.O. 2020-7 provided by MDHHS on Friday, 03/20/2020 further clarifying the E.O. 2020-7. You can read that here.