COVID-19 Billing Guidelines

When billing for telehealth services, please note that South Country Health Alliance is following the below Centers for Medicare & Medicaid Services (CMS) billing guidelines:

• • • Bill using the Current Procedural Terminology (CPT)/Healthcare Common Procedure Coding System (HCPCS) codes and Place of Service (POS) you would normally bill for the service (i.e., office, outpatient, etc.)
    • A member can be in his/her home when receiving services
    • Use modifier 95 for professional claims
    • Use modifier GO in addition to 95 if the telehealth service was performed in relation to acute stroke
    • No billing changes for institutional claims
    • Critical Access Hospital (CAH) Method II claims should continue to have modifier GT

Documentation Requirements:
Individual Treatment Plans: *This policy change ended May 11, 2023
Providers may accept verbal consent in lieu of written consent for individual treatment plans during the COVID-19 Peacetime Emergency for the following services:

• Intensive Rehabilitative Mental Health Services
• Children’s Therapeutic Services and Supports (CTSS)
• Intensive Treatment in Foster Care (ITFC)
• Adult Rehabilitative Mental Health Services (ARMHS)
• Adult Mental Health Mobile Crisis Services
• Children’s Mental Health Mobile Crisis Services
• Outpatient Mental Health Services

Providers must document and maintain in the client file the name of the person providing consent, relationship to the client, and date verbal consent was obtained.

Over-The-Counter (OTC) COVID Test - This benefit will continue through September 30, 2024
South Country covers over-the-counter (OTC) COVID-19 tests. Tests must be billed as a Durable Medical Equipment (DME) and Supplies benefit. OTC tests can be dispensed by any qualifying provider that is eligible to bill South Country as a DME supplier (including any pharmacies that are enrolled). A prescription from a qualifying Provider is required.

South Country allows up to eight (8) tests to be dispensed per month per member. Tests may be dispensed on the same date; date span is not allowed. Bill on an 837P, for tests dispensed before July 1, 2022, use HCPCS code T5999, a pricing/invoice attachment is required for billing. Use HCPCS code K1034 for tests dispensed on or after July 1, 2022.

South Country will not reimburse members who purchased OTC COVID-19 tests. OTC COVID-19 tests must be billed to South Country at the time of dispensing.

• South Country Health Alliance follows the Centers for Medicare and Medicaid Services (CMS) and Minnesota Department of Human Services (DHS) billing guidelines for COVID-19. For detailed information, please review the COVID-19 Vaccinations information in this section.
• Effective January 1, 2020, and throughout the COVID-19 Federal Public Health Emergency until the last day of the calendar quarter in which it ends, South Country Health Alliance will provide a temporary increase of 6.2 percent to Targeted Case Management (TCM) rates for some Medical Assistance members. The temporary increase is available for TCM (T2023) services regardless of the modality of contact (for example face-to-face or by telephone). This will include Medical Assistance members that are: children; parents or guardians with children under age 19; individuals age 65 and older; and individuals with disabilities. The increase does not apply to adults without children. For detailed information on TCM Services, review our Provider Manual Chapter 22 Mental Health & Substance Use Disorders Services.

Following DHS MHCP and federal guidelines, South Country is taking the Consolidated Appropriations Act of 2023 phase-down approach to the elimination of 6.2% COVID FMAP. Please see table 1 below for the phase down timeline.
Table 1. CAA, 2023 FMAP Increase Phase Out

Remote Delivery of Qualified Professional Services*

This policy modification allows the following:

• • • QPs to provide in-person oversight via two-way remote delivery (e.g., phone or internet technology)
    • QPs to provide services remotely to people who are new to receiving PCA services or are transferring to the agency.

Remote service delivery for supervisory visits was approved retroactively to May 12, 2020, through the duration of the COVID-19 public health emergency for members in the PCA Choice model. The PCA traditional model was approved for remote supervisory visits retroactively to March 19, 2020, through the duration of the COVID-19 public health emergency. *The CV.53 waiver for remote delivery of QP visits ends on June 30, 2022.

• • Documentation Requirements

For services delivered remotely, the QP also must document the following:

• • • The QP visit is a COVID-19 remote QP visit
    • The method of communication (e.g., phone or internet technology).

Family Members of South Country Health Alliance enrolled PCA Members - This waiver has been temporary extended - The temporary extension allowance will now continue through November 11, 2023

South Country Health Alliance (South Country) will temporarily waive the restriction on allowing certain family members to provide and receive payment for personal care assistance services to South Country enrolled PCA members. The intent of this waiver is to reduce the spread of COVID-19 by reducing the need for additional PCA providers to enter the home to provide PCA services during the public health emergency.

This waiver, effective during the dates of December 1, 2020 through February 7, 2021 - this waiver was reinstated on July 1, 2021, until further notice, allows the following types of family members of individuals enrolled in South Country to receive PCA services to be eligible to provide PCA care:

• parents
• stepparents
• spouses
• legal guardians of minors

The family member must enroll using the same process as for other individual PCA providers to provide PCA services to their relative and receive payment for the care. PCA providers will inform the family members of the PCA members they serve that they can apply to provide PCA services during the waiver effective dates and instruct them on the enrollment process.

PCA providers must only seek to enroll a family member as a worker who is not the person’s responsible party. See the enrollment requirements outlined for individual PCA providers in the Provider Manual, Chapter 23 – Personal Care Assistant (PCA) Services.

Children's Therapeutic Services and Supports (CTSS) COVID-19 Billing Change

*This waiver benefit ended on May 11, 2023

There are two (2) billing changes effective on August 21, 2020, through the duration of the COVID-19 public health emergency for certified day treatment providers of CTSS.

1. Certified day treatment providers of CTSS may bill for psychotherapy for two or more individuals and individual or group skills training provided by a multidisciplinary team, under the clinical supervision of a mental health professional
2. A “temporary absence” includes an absence due to COVID-19

COVID-19 CMS Waiver for SNF Providers

Centers for Medicare and Medicaid Services (CMS)’s Skilled Nursing Facility (SNF) Benefit Period Waiver authorizes a one-time renewal of skilled benefits for an additional 100 days of Part A SNF coverage without first having to start a new benefit period (this waiver will apply only for those beneficiaries who have been delayed or prevented by the emergency itself from commencing or completing the process of ending their current benefit period and renewing their SNF benefits that would have occurred under normal circumstances.) There are some members that may have not been able to commence their 60 day break due to COVID-19. Providers should refer to the following guidance from CMS: https://www.cms.gov/files/document/se20011.pdf (external link)

For claims payment of the additional skilled benefit days, the provider shall:

1. Track the benefit days used in the benefit periods waiver spell and fax new/updated Nursing Facility Communication forms (DHS-4461-ENG) to Utilization Management notating on the form member is receiving additional Medicare benefit days related to the Public Health Emergency (PHE) waiver.
2. Fully document in members medical records the reasons member qualifies for the additional benefit.
3. Reference billing guidance per CMS in the above link for billing requirements including condition codes.

Things are changing rapidly, and we will be updating our website as new developments occur. Please check back frequently for updates.