April 16 th , 2020 COVID-19 Program and Billing Updates for ACT Teams Program Expectations, Documentation Changes & Minimum Billing Standards during the Disaster Emergency Division of Adult Community Care
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April 16th, 2020
COVID-19 Program and Billing Updates for ACT Teams
Program Expectations, Documentation Changes & Minimum Billing Standards during the Disaster Emergency
Division of Adult Community Care
2April 17, 2020
THANK YOU and all your staff members for all the work you do and continue to do for the folks in our communities!
First & foremost…
3April 17, 2020
• New York State is a crisis zone in the global COVID-19 pandemic• Community-based behavioral health providers offer a critical safety net to
New Yorkers during this time• OMH has worked closely with the Department of Health and the
Governor to secure waivers that will allow providers to deliver services in new and flexible ways, including through the expansion of telemental health
• The Program & Billing Guidance issued 04/13/20 is effective with the start of the declared disaster emergency, 03/07/20.
Background
4April 17, 2020
• OMH’s intent is to maintain quality services and continuity of care for participants, as well as to support agencies in maintaining current staffing levels
• Behavioral health providers should strive to provide a level of service, care, and support consistent with historic levels provided
• The intensity and frequency of service delivery should be appropriate to each individual’s needs
• All providers should continue to support each individual’s unique recovery goals during this crisis
• Essential service delivery must continue
Vision
5April 17, 2020
• Essential services are a set of core services that must be provided throughout the Disaster Emergency, based on individual need and practitioner scope of practice
• Delivery of essential services does not require an update of or revision to an individual’s Service Plan
• Essential services are person-centered, flexible, and intended to support individuals’ basic needs at this time
Essential Service Delivery
6April 17, 2020
1. Medication2. Individual counseling/ therapy3. Crisis de-escalation and crisis intervention4. Substance use services5. Dissemination of COVID-19 related information6. Support of emotional and physical needs
Essential Services
7April 17, 2020
• Teams will continue to conduct morning meetings, virtually or by phone, to review and ensure all recipients’ needs are met, allowing for daily response to changing needs.
• Teams must make a minimum of one (1) telephonic outreach effort to each enrolled recipient each week. The primary purpose of the contact is to engage the individual, assess needs and provide support. In addition, it is critical to ensure each individual has a list of important telephone numbers, local resources and a step-by-step plan for contacting appropriate stakeholders when needed. All outreach efforts must be documented.
• Prescribers should make a minimum of one (1) telephonic outreach effort to each recipient once a month. If recipients are due for review of medications or injection, additional outreach attempts must be made to ensure continuity of their medication regime. A determination should be made on the level of contact needed if telephonic is not sufficient.
ACT Team Expectations
8April 17, 2020
For existing ACT recipients during the disaster emergency period (effective 03/07/20), or until such time as supplemental guidance is issued: • Assessments and Service Plan reviews/ updates are not required and may be postponed
as needed. • Providers may work under existing service plans and provide additional services as
needed to ensure continuity of care and address mental health needs related to the disaster emergency.
Changes in Documentation Requirements
9April 17, 2020
For new ACT recipients during the COVID-19 disaster emergency period, or until such time as supplemental guidance is issued:• Initial service plans and assessments may be established via telehealth capabilities (see
OMH telehealth guidance; Admissions and Continuity of Care memo). • Specific timeframes for developing initial service plans are waived. Admissions should be
prioritized and established in the most efficient way possible given the current disaster emergency.
• Signatures, including that of the physician and the client on all required documentation can be obtained verbally and documented in the record.
• Assessments and initial service plans should be focused on presenting immediate needs of individuals including medication management, health and safety needs, acute psychiatric symptoms. Treatment should commence immediately.
Changes in Documentation Requirements
10April 17, 2020
Suspension of Utilization Review
Providers may suspend their internal, written utilization review procedures, as required by OMH regulations, for the duration of the disaster emergency. It is OMH’s expectation that this process will resume once the disaster emergency is over.
11April 17, 2020
• The new guidance establishes program expectations and a reduction or elimination of minimum billing requirements for specific ACT rate codes
• These are to be used for billing to be used during the Disaster Emergency (effective 03/07/20), or until such time as supplemental guidance is issued.
• This new flexibility in service delivery and billing are not intended to establish lesser standards for provision of services and support.
Program Expectations & Billing Requirements
12April 17, 2020
• All telehealth/telephonic and face-to-face individual contacts (any service) shall be a minimum of five minutes to count as one billable service.
• Reimbursement shall be made at the full payment rate (rate code 4508) for services provided to active clients who receive a minimum three contacts in a month, one of which may be a collateral contact.
• Reimbursement shall be made at the partial step-down payment rate (rate code 4509) for services provided to active clients who receive a minimum of one, but fewer than three contacts in a month. This contact may be with a collateral.
Reduction or Elimination of Minimum Billing Requirements:
13April 17, 2020
• Reimbursement for clients admitted to an inpatient facility (and anticipated to be discharged within 180 days) shall qualify for adjusted minimum contact requirements:
1. In the month of admission and/or discharge, full payment rate (rate code 4508) is permitted for any month in which three or more telehealth/telephonic and/or community-based contacts combined with inpatient telehealth/telephonic and or face-to-face contacts equals three or more total contacts.
2. In the month of admission and/or discharge, stepdown/partial payment rate (rate code 4509) is permitted when a minimum of one telehealth/telephonic and/or community-based and/or inpatient contact is provided.
3. Inpatient payment rate (rate code 4511) is permitted when a minimum of one inpatient telehealth/telephonic or face-to-face contact is provided in a month, regardless of the number of community contacts.
Billing (continued)
14April 17, 2020
During the declared COVID-19 disaster emergency,• If a service is still delivered in-person and existing minimum requirements are met, then
there is no need to use GT/95 (telehealth) or CR (Catastrophe/Disaster related) modifiers• If a service is delivered via telehealth and existing minimum requirements are met, then
the GT/95 (telehealth) modifier should be added to the claim• If a service is delivered via telehealth and existing minimum requirements are NOT met,
but the minimum requirement in the COVID-19 Flexibility Billing Guidelines are met, then the GT/95 (telehealth) + CR (Catastrophe/Disaster related) modifiers should be added to the claim.
Please note: OMH will review claims submitted during the emergency period and may recoup any funding received that is found to be in excess of historical revenues or actual cost.
Billing Modifiers
16April 17, 2020
OMH Guidance on COVID-19 [Website]CTAC Best Practices in Telehealth [Recorded Webinar]
Resources
17April 17, 2020
Thank you all for your continued support of clients and all New Yorkers during this public
health crisis.
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