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Medicaid Policies
TELEHEALTH DEFINITION: “The delivery of health care services through the use of interactive audio and video." Telehealth does not audio-only, email, or fax communication.
SERVICE PARITY: Health policies “shall not discriminate between coverage benefits for health care services that are provided in person and the same health care services that are delivered through telehealth.”
PAYMENT PARITY: “Health care services provided through in-person consultations or through telehealth shall be treated as equivalent services for the purposes of reimbursement.”
PREREQUISITES TO TELEHEALTH: In person contact is not required as a prerequisite for payment for telehealth services
REMOTE MONITORING: Not covered
ORIGINATING SITES: The offices of physicians (provider types 02, 03) and other practitioners (psychologists, social workers, behavioral health providers, habilitation services providers, and advanced registered nurse practitioners (ARNPs)), hospital, CAH, RHC, FQHC, CMHCs, AEAs and LEAs (newly added 2020)
DISTANT SITES: Physicians, NPs, PAs, nurse-midwives, CNSs, CRNAs, clinical psychologists, CSWs, behavioral health service providers (independent social workers, master social workers, marital and family therapists, mental health counselors, certified alcohol and drug counselors), FQHCs
FQHCs & RHCs:
- PROSPECTIVE PAYMENT SYSTEM (PPS) REIMBURSEMENT STRUCTURE
- FQHCs are paid based on the PPS/encounter rate if the service is PPS qualifying. This is generally the same as the reimbursement process for in-person services
- FQHCs and RHCs can serve as originating sites, FQHCs can serve as distant sites
- Originating sites usually use HCPCS code Q3014 for facility fee -- FQHCs and RHCs do not bill Q3014 as a separate service because reimbursement for the related costs would occur through the annual cost settlement process.
OTHER IA MEDICAID POLICIES:
- Medicaid provider reimbursement: Generally, institutional types of providers such as hospitals and nursing facilities are reimbursed on a cost-related basis, and practitioners such as physicians, dentists, optometrists, and similar providers are reimbursed on the basis of a fee schedule
Temporary COVID-19 Policies (IA Medicaid)
SERVICES NEWLY ELIGIBLE FOR TELEHEALTH:
- Behavioral health, teledentistry, PT, OT, ST
- Audio-only telehealth services
- Codes established for REMOTE MONITORING of physiologic parameters, remote physiologic monitoring treatment management services
WAIVED REQUIREMENTS: “Established patient” requirement suspended
OTHER TEMPORARY IA MEDICAID POLICIES:
Providers can provide telehealth from their home
For medicaid managed care & fee for service:
- Redefines “distant” and “originating” sites as locations of provider and patient (can provide and receive services from home)
- Premiums/cost-sharing obligations suspended
- Expanded list of services and providers who can bill for them (including, but not limited to, physicians, physician assistants, dentists, physical therapists, occupational therapists, speech therapists, home health, hospice, behavioral health and home and community-based services (HCBS) providers)
Expanded teledentistry policy:
- Codes D9995 & D0140 can be billed, effective 3/13/20
Commercial Payer Policies
TELEHEALTH DEFINITION: “The delivery of health care services through the use of interactive audio and video. Telehealth does not include the delivery of health care services through an audio-only telephone, electronic mail message, or facsimile transmission.”
DEFINITION OF HEALTH CARE PROFESSIONAL: “A physician or other health care practitioner licensed, accredited, registered, or certified to perform specified health care services consistent with state law.”
SERVICE PARITY: Health policies “shall not discriminate between coverage benefits for health care services that are provided in person and the same health care services that are delivered through telehealth”
PAYMENT PARITY: Not explicitly required
PENDING LEGISLATION: A bill currently in senate, HF 2192, would amend the definition of telehealth to include all electronic interactive services provided regardless of the physical locations of the patient and provider (distant and originating sites). HF 2192 also establishes payment parity by requiring health carriers to reimburse providers for services in the same way that they would reimburse for the same services provided in-person.
Temporary COVID-19 Policies (IA Commercial Payers)
WAIVED REQUIREMENTS: The provision excluding audio-only telehealth is temporarily suspended
OTHER TEMPORARY IA COMMERCIAL PAYER POLICIES:
Medically necessary services delivered via telehealth must be reimbursed on the same basis and at the same rate as the health carrier would apply to the same health care services delivered in person (payment parity)
Medical Board Policies
TELEMEDICINE DEFINITION: Telemedicine includes asynchronous store and forward, remote monitoring, and real-time interactive services (including teleradiology and telepathology). Telemedicine does not include audio-only, email, or fax.
Providers must be licensed in Iowa to practice telemedicine
Physician-patient relationships may be established in person, via consultation with another provider, OR via telemedicine encounter
HIPAA-compliant technology must be used in telemedicine provision
Telemedicine abortions are allowed
Iowa Professional Licensure Compacts
Interstate Medical Licensure Compact
Temporary COVID-19 Policies (IA Medical Board)
Out-of-state licensed practitioners can practice medicine/telemedicine in Iowa
Rules establishing preconditions/limitations/restrictions are suspended
- The ban on audio-only telemedicine is suspended
- The provision requiring face-to-face interaction with health care providers for certain residential and outpatient substance use disorder treatment services (Iowa Admin. Code rule 653-13.11 and rule 641-155.2) is suspended
Recent medical school graduates can seek emergency licenses
Criminal background check for initial licensure suspended
Physicians with lapsed/expired licenses can continue to practice
CME requirements temporarily suspended
Mid-Level Providers
Circumstance where standard of care may not require personal interview/examination: If the NP or PA has examined the patient in person
Iowa’s mandatory nurse licensure law implies that nurses can practice telemedicine: It states that care could be provided via “telephonic, electronic, or in person means”
- IA license is not mandated for nurse in another compact state (eNLC)
Iowa Mid-Levels Professional Licensure Compacts
Enhanced Nurse Licensure Compact
NO Advanced Practice Registered Nurse Licensure Compact
Temporary COVID-19 Policies (IA Mid-Levels)
Granting emergency licenses for RNs, LPNs, APRNs who graduated within past 6 months
Suspending regulation prohibiting practice of PAs or nurses who have not yet gained initial license OR whose licenses have lapsed
Behavioral Health Providers
TELEMEDICINE DEFINITION: The delivery of health care services through the use of interactive audio and video. Telehealth does not include the delivery of health care services through an audio-only telephone, email, or fax.
DEFINITION OF HEALTH CARE PROFESSIONALS: Defined in 514C.34 (Health care services delivered by telehealth - coverage) as “a physician or other health care practitioner licensed, accredited, registered, or certified to perform specified health care services consistent with state law.”
- Delivery of telehealth services: “Health care services that are delivered by telehealth must be appropriate and delivered in accordance with applicable law and generally accepted health care practices and standards prevailing at the time the health care services are provided, including all rules adopted by then appropriate professional licensing board.”
Iowa Mental Health Professional Licensure Compacts
Legislation pending for the Psychology Interjurisdictional Compact (PSYPACT)
Temporary COVID-19 Policies (IA Mental Health Providers)
Psychologists licensed in other states can provide telehealth services to Iowans without obtaining an Iowa license
- There is currently no guidance about psychologists’ licensure during the emergency proclamation
Licensed mental health counselors and marital and family therapists in other states can provide telehealth services to Iowans without obtaining an Iowa license
- Licensees are not required to renew expired licenses for the duration of the Governor's emergency proclamation