COVID-19 Quick Reference Guide: Telemedicine for Indiana Medicaid Providers

COVID-19: Telehealth for Indiana Medicaid Providers

In an effort to ensure access to healthcare during these uncertain times, CMS broadened Medicaid’s telemedicine coverage so that patients can see a provider without leaving their homes. All services delivered through telemedicine are subject to the same limitations and restrictions as they would be if delivered in-person. Appropriate consent from the member must be obtained by the provider prior to delivering services.

1135 Waiver

Through this waiver, CMS will pay for healthcare services provided to patient via telemedicine. Indiana’s Office of Medicaid Policy and Planning (OMPP) requested waiver approval on March 19, 2020, which CMS subsequently approved on March 25, 2020. The waiver includes many provisions, including the temporary suspension of Medicaid fee-for-service prior authorization (PA) requirements, extending pre-existing PAs, and the expansion of telemedicine services. This waiver is effective from March 1, 2020, and will terminate upon termination of the COVID-19 public health emergency, including any extensions.

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Medicaid Telemedicine & Telehealth

The Indiana Health Coverage Programs (IHCP) have revised the following definitions to accommodate the current COVID-19 public health emergency:

Telemedicine:  The use of technology which allows a healthcare provider to render an exam or other service to a patient at another location

Telehealth:  The scheduled remote monitoring of clinical data through technologic equipment in the member’s home.

The IHCP covers telehealth services provided by home health agencies to members who are approved for other home health services Telemedicine services may be provided using any technology that allows for real-time, interactive consultation between the patient and the healthcare provider. This includes the use of computers, phones, television monitors, and voice-only communication, but does not include non-voice communication such as emails or text messages.

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IHCP Telemedicine Facts

• Allowed under both traditional and managed care programs
• Healthcare providers must obtain consent from patient prior to service
• Covers telephone and telemedicine visits for in- and out-of-state healthcare providers o Providers and patients can be located in their homes during the time of service
• EXCEPTIONS: Surgical, radiological, labs, anesthesia, audiology, chiropractic, care coordination without patient being present, DME/HME providers, provider-to-provider consultations

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IHCP Documentation & Billing Requirements

Services can be provided via Audio & Video or via Audio Only

• Must indicate that services were rendered via telemedicine, whether those services were provided via audio/video conferencing or audio-only.
  • Include provider and patient locations in documentation
  • Include documentation of patient’s consent to telemedicine services

Documentation

• Must obtain consent from patient to treat via telemedicine. Verbal consent okay
• Notify patient that telemedicine visits are billable, therefore any copays, coinsurance, and/or deductibles may apply
• Document the following:
  • Locations of both the healthcare provider and patient
  • For Audio/Video Visits: # of minutes spent face-to-face with patient and/or patient’s family/caregiver
  • For Audio-Only Visits: # of minutes on the phone with patient and/or patient’s family/caregiver
• Be prepared for post-payment review
• Must include a valid CPT code with modifier
  • Use existing billing guidelines per IHCP's Telemedicine & Telehealth Services Provider Reference Module

Billing

• E&M Codes 99201 – 99215
• Place of Service (POS) & Modifiers:
  • If service codes are located in the Indiana Medicaid Telemedicine Service Code Table, use Modifier 95 + POS 02, Telehealth Services
  • If service codes are NOT located in the Indiana Medicaid Telemedicine Service Code Table, use Modifier GT + applicable POS indicating where patient is located (e.g. POS 12 to indicate patient’s home)

Modifier 95:  Synchronous telemedicine service via audio and visual telecommunication system

Modifier GT:  face-to-face encounter with audio and video telecommunication system

Any IHCP-covered service listed in the Indiana Medicaid Telemedicine Service Code Table – aside from the exclusions listed in BT202022 and speech, occupational, and physical therapies – can be provided through audio-only, given that the service can reasonably be provided through audio-only communication. Some services may be better provided through video, however, the IHCP acknowledges some patients may not have access to video communication.

Executive Order 2020-13 excludes speech, occupational and physical therapies from audio-only telemedicine.

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HIPAA and Telehealth Services

Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency. Healthcare providers should not use public-facing communication applications such as Facebook Live, TikTok, Twitch and similar applications.

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Opioid Prescribing

Per Indiana Governor Holcomb’s Executive Order 20-13, which allows a prescriber who is also a DEA-registered practitioner to issue prescriptions for all Schedule II-V controlled substances for patients for whom they have not conducted an in-person medical evaluation, provided:

• The prescription is issued for a legitimate medical purpose by a prescriber acting in the usual course of their professional practice; 
• The telecommunication is conducted using an audio-visual, real-time, two-way interactive communication system; and
• All other applicable state and federal laws are followed.

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Additional COVID-19 resources

IHCP resources for Indiana Medicaid healthcare providers:  

IHCP Telemedicine & Telehealth Services Provider Reference Module

IHCP Telemedicine Services Codes Table

IHCP Bulletin #BT202022:  Telemedicine Guidance for COVID-19  Issued 03/19/2020

IHCP Bulletin #BT202034:  Telemedicine FAQs  Issued 04/02/2020

Indiana-specific information:

Indiana State Dept. of Health (ISDH) COVID-19 Professional Resources

Indiana Board of Pharmacy COVID-19 Actions & Controlled Substances

Upper-Midwest Telehealth Resource Center (UMTRC) Indiana COVID-19 Resources

Other:

AAFP:  Using Telehealth to Care for Patients During COVID-19

AMA:  Quick Guide to Telemedicine in Practice

AMA:  Special Coding Advice During COVID-19 Public Health Emergency

AMA:  Telehealth Implementation Playbook

Indiana State Medical Association (ISMA): COVID-19 Telemedicine Billing Decision Tree