*proposed update* STUDIES ON TELEHEALTH:
- Study the viability of audio-only telehealth for use within public health care programs. The study will assess the use of audio-only telehealth in supporting equitable access to health care and in eliminating barriers to accessing care.
- Study the long- and short-term impact of telehealth payment methodologies and of telehealth expansion on access (especially in rural areas), quality, value-based payments, and innovation for public and private payers. As part of this study, review criteria used for determining whether telehealth is medically appropriate and what methods are used to ensure that patients’ rights to choose telehealth (or not) are respected. This study group will also make recommendations on interstate licensing options for providers.
- Launch a task force to explore opportunities for improving service delivery through the use of a “common interoperable person-centered telepresence platform that provides HIPAA compliant connectivity and technical support to potential users.” Determine standards, statewide capabilities, and barriers for a single interoperable telepresence platform. The task force will report on their findings by Jan 15, 2022 (task force expires July 31, 2022 or after they submit the report).
*proposed update* Minnesota has several pending pieces of legislation that address overlapping portions of telehealth regulations in statute. See HF2128, SF1160, SF2360, HF1412, SF2049, SF481 & HF1040. Proposed changes include:
- The commissioner is no longer required to establish criteria to which health care providers must attest in order to demonstrate the safety or efficacy of delivery a particular service through telehealth. (Medical Assistance only)
- For mental health services delivered via telehealth, verbal approval of a treatment plan can be used in lieu of a signature. (Medical Assistance only)
- Medical assistance covers medically necessary Early Intensive Developmental and Behavioral Intervention services delivered via telehealth. (Medical Assistance only)
- Audio-visual telehealth may be used for face-to-face service requirements for reimbursement for FQHCs, RHCs, IHS, 638 tribal clinics, and CBHCs. (Medical Assistance only)
- PAYMENT PARITY: Health insurance carriers cannot limit reimbursement based on what type of telehealth equipment is used as long as it is HIPAA compliant and complies with industry standards.
- MENTAL HEALTH, SUBSTANCE USE DISORDERS:
- The exam required prior to prescribing for medication-assisted therapy or substance use disorders can be conducted via telehealth.
- If a client is receiving SUD treatment services via telehealth, verbal approval for treatment plan can be used in lieu of signature.
- Chemical dependency services can be provided via telehealth (including audio-only).
- A psychiatric care provider offering assertive community treatment (ACT) may offer services via telehealth.
- Intensive nonresidential rehabilitative mental health services delivered by a psychiatric provider can be provided via telehealth when necessary.
- MAT can be delivered via telehealth and into a patient’s residence.
*proposed update* Updating the definition of telehealth to include audio-only services (applies to Medical Assistance payers).
*proposed update* Keep certain COVID-19 waivers in place until June 30, 2021. These would expand access to telehealth for CHIP, Medical Assistance, and MinnesotaCare, allow telehealth as an alternative for school-linked mental health services, and expand telehealth in health care, mental health, and substance use disorder settings.
*proposed update* Reduce reimbursement for telehealth visits covered by Medical Assistance to 90% of the rate for the comparable in-person service.
*proposed update* Mental health targeted case management services can be conducted via telehealth (which includes audio-only services, per language in the same bill—HF1412). The commissioner maintains the right to limit telehealth for targeted case management services to audio-visual only. (Medical Assistance only)
*proposed update* In the Medical Assistance chapter of legislation, “interactive video” is replaced with “telehealth” (which includes audio-only services, per language in the same bill—HF1412) in the mental health section. Two other bills (SF481 and HF511) would allow mental health services covered under Medical Assistance to be provided via telehealth.
TELEHEALTH DEFINITION: “The delivery of health care services or consultations while the patient is at an originating site and the licensed health care provider is at a distant site.”
SERVICE PARITY: “A health carrier shall not exclude a service for coverage solely because the service is provided via telemedicine and is not provided through in-person consultation or contact between a licensed health care provider and a patient.”
PAYMENT PARITY: “A health carrier shall reimburse the distant site licensed health care provider for covered services delivered via telemedicine on the same basis and at the same rate as the health carrier would apply to those services if the services had been delivered in person by the distant site licensed health care provider.”
ORIGINATING SITES: Office of physician or practitioner, Hospital (inpatient or outpatient), CAHs, RHCs, FFQHCs, Hospital-based or CAH-based renal dialysis center (including satellites), SNFs, ESRD facilities, Community mental health center, Dental clinic, Residential settings (such as a group home, assisted living, shelter or temporary lodging), Home (a licensed or certified health care provider may need to be present to facilitate the delivery of telemedicine services provided in a private home), School, Correctional facility-based office, Mobile stroke unit
ELIGIBLE PROVIDERS: Physician, NP, PA, Nurse midwife, clinical nurse specialist, RD/nutrition professional, dentist/hygienist/therapist, mental health professional, pharmacists, certified genetic counselor, podiatrist, ST, OT, PT, audiologist, public health nursing organization
PREREQUISITES TO TELEHEALTH: Providers must complete the Provider Assurance Statement for Telemedicine
PROVIDER REQUIREMENTS: Providers must document “the provider's basis for determining that telemedicine is an appropriate and effective means for delivering service to the recipient”
NON-COVERED SERVICES: Connections using non-HIPAA compliant technology, Prescription renewals, Scheduling a test or appointment, Clarification of issues from a previous visit, Reporting test results, Non-clinical communication, Communication via telephone, email or fax, Day treatment, Partial hospitalization programs, Residential treatment services, Case management face-to-face contact
FQHCs & RHCs:
- PROSPECTIVE PAYMENT SYSTEM (PPS) REIMBURSEMENT STRUCTURE
- Most in-person services can be provided via telehealth and are reimbursed at the PPS/encounter rate
OTHER MN MEDICAID POLICIES:
MHCP reimburses for interactive audio/visual communications & asynchronous store-and-forward (to send information to a reviewing physician)
Payment for telemedicine services is limited to three per week for an MHCP member
Physician services may be delivered by telemedicine to provide intensive residential treatment services
Tele-home care is covered under the Elderly Waiver (EW) and Alternative Care (AC) Programs
- NON-COVERED SERVICES: Children’s day treatment, Partial hospitalization programs, Mental health residential treatment services, Case management services delivered to children
- ELIGIBLE PROVIDERS: Mental health professionals who are qualified under Minnesota Statute 245.462 Subd. 18 (qualified in psychiatric nursing, clinical social work, psychology, psychiatry, marriage and family therapy, licensed professional counseling, or allied fields)
Teledentistry: “Reimbursement for teledentistry is the same as face-to-face encounters. The distant site can bill for the services provided by a licensed dentist.”
Early intensive developmental and behavioral intervention: MHCP does not reimburse for connection charges or origination, set-up, or site fees
Additional originating sites for SUD treatment services: Drug court office, Correctional facility-based office (including jails), Substance abuse disorder treatment facility (residential or outpatient), Withdrawal management facility
Medication therapy management services: Available for members more than 20 miles from MHCP MTMS provider; Both originating and distant sites must be pharmacy/clinic/hospital/ambulatory care site; Connection must be audio/visual
Temporary COVID-19 Policies (MN Medicaid)
NEWLY ELIGIBLE SERVICES: Audio-only connection
WAIVED REQUIREMENTS: The first interaction with a provider no longer needs to be in person, limit of 3 visits per weeks is ended
TEMPORARILY ELIGIBLE PROVIDERS: Community Health Worker, Public Health Nurse Clinic, Doula (pre and postnatal care only), Physician extenders, Licensed Alcohol and Drug Counselors, Alcohol and Drug Counselors, Alcohol and Drug Counselor – Temps Recovery, Peers and student interns in SUD programs licensed under chapter 245G, Pharmacists enrolled to perform medication therapy management, mental health works across a variety of practice areas
- Any service that, when provided face-to-face that would generate an encounter if performed in person, will continue to generate an encounter if provided via audio-visual telemedicine
OTHER TEMPORARY MN MEDICAID POLICIES:
COVID-19 telemedicine services are exempt from cost-sharing
Billing for tele-Targeted Case Management is the same as for in-person services
Temporary coverage of telemedicine visits for SUD/mental health providers
- Billing for SUD treatment is the same as in person
- Additional SUD providers who can practice telemedicine: Licensed Alcohol and Drug Counselors, Alcohol and Drug Counselors, Alcohol and Drug Counselor - Temps Recovery, Recovery peers and student interns in SUD programs licensed under chapter 245G
- Telephone billing codes have been added
- FQHCs can bill for telehealth evaluation and management
- Not billing POS 02, just modifier 95
- There is a new provider assurance statement (6806) for telephone (audio-only) services
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