Covid-19 and Telemedicine Billing Recommendations for Mental Health Professionals
We have been watching the Covid-19 (A.K.A “novel coronavirus”) outbreak closely as it’s grown. Now with the World Health Organization’s designation of the Covid-19 outbreak as a Pandemic as well as some of the steps taken by local, state and federal government in recent days, we’ve been getting a lot of questions from our BreezyNotes and BreezyBilling customers about telemedicine setup, billing and reimbursement.
Below we will share what we can to help mental health professionals as you work with your clients to make sure they get the care they need while you and your providers also stay safe as well as get reimbursed for your work.
Quick Links
- Attestation Requirements by Payer
- Telehealth Place of Service (POS)/Modifiers by Payer
- Billing and Reimbursement
Updates
Update January 2024: Since Covid first started, nearly all insurance companies are processing claims with no modifiers and Place of Service (POS) = 02 (Telehealth while client is NOT at home) or POS = 10 (Telehealth while client is at home). We struck through previous recommended POS and modifier combinations. Always confirm with any payer regarding their telehealth billing policy before submitting claims in order to avoid denials.
Update 05/21: Updated POS/Modifier Table with PrimeWest info (11/95). Posted Reopening Your Behavioral Health Practice During COVID-19 about considerations for seeing clients in-person. After a phone call with Ucare, changed the Note in the POS/Modifier Table regarding reprocessing of underpaid claims – Ucare will now reprocess without the provider resubmitting.
Update 05/14: Ucare is requiring POS = 11 and 95 modifier for all claims going back to March 1 if you want to get paid the full amount (link). The Optum Family of payers are now denying claims with the GT modifier present.
Seeing clients out of state? Person Centered Tech put together a state-by-state listing of requirements for the big four therapy licensures. Click here.
Update 04/22: Some payers require Attestations before they will process your telehealth claims. Many of those that do are waiving those requirements temporarily or giving providers a workaround. The bottom line is check our table below (link) and get them in.
Update 04/13: Medicare and Cigna both release updated telemedicine billing guidelines. We converted our payer list with specific billing instructions into a table for easier reading (Click Here).
Update 03/27: Many payers are following CMS’ lead and waiving the video requirement in order to be reimbursed for telehealth. Some are also waiving the HIPAA-compliant video platform, too. Here is a list of payers and their policies. If you have anything new to add, please contact us with a link to the update.
- BCBS MN
- BCBS IL
- Cigna
- Has very unique billing requirements. See “General billing guidance for non-COVID-19 related services” and “Important Notes” sections in the link. Also see billing guidelines below.
- Cigna Behavioral Health
- Use a 95 modifier.
- HealthPartners
- Medicaid MN (DHS)
- Federal approval of waivers received for phone calls and more than 3 telemedicine visits per week, but it’s still unclear if programs like ARMHS are included in this waiver. Note that a “telemedicine agreement” must be in place. See CV16 after clicking link.
- Medicare
- Optum/Medica/UnitedHealthare
- PreferredOne
- Ucare
- Still only address Medicare and Individual & Family Plans
- Aetna
- Not covering phone calls for Behavioral Health
These waivers are all temporary. Most are applicable as long as we are in a state of national emergency. Some have assigned end dates. Please read each policy carefully to see when telephone and originating site waivers are removed.
Update 03/24: Cigna Behavioral Health requires the 95 Modifier, but indicated they’d still accept the GT Modifier.
BCBS is now saying they will not cover telehealth on plans that did not already have it included as a benefit.
Update 03/21: DHS given the go-ahead to relax rules.
Governor Tim Walz released Emergency Executive Order 20-12 relaxing the laws guiding DHS rulemaking and allowing for DHS to modify or waive rules around many, many items under its purview including telehealth.
The Bottom Line – We still need to see exactly how DHS responds to the order, but this could pave the way for serving Medicaid and PMAP clients via non-HIPAA compliant video OR even over the phone.
Update 03/19: We need to state very clearly that we are sharing information and interpretations of information being put out by various agencies and government. Telemedicine is changing rapidly in Minnesota, and until it is written into law there are no guarantees that doing anything different will be covered or reimbursable. It is up to our lawmakers to make these changes and then enforce them with the insurance carriers to change their coverage policies.
With this update, we cleaned up a few things, consolidated what we know and made some important distinctions:
- Changed term “telehealth” to “telemedicine” to match state definitions
- The 03/18 22:33 CDT update did not clearly indicate the conditions required when a client is at home for it to qualify as telemedicine
- The 03/17 02:14 CDT applies at the FEDERAL LEVEL ONLY. This does not apply at the state level where the state requires HIPAA-compliant video services to be for telemedicine and various payers require HIPAA-compliant video services to be used for telemedicine.
NOT every Minnesotan is covered for Telehealth with SF4334 passed into law on 03/18.
The law only applies to clients who have plans with MN-based carriers. It does not apply to carriers based out of state or Self-Insured plans.
Based on our read and checking with some of the local MN associations, Article 3, Section 1.3 requires MN-based insurance carriers to cover telemedicine through February 1, 2021. It also clarifies that the client can be at home when they receive the service, however does NOT indicate what conditions must be met at the home for it to be a reimbursable telemedicine visit. Here’s the specific language:
ARTICLE 3, SECTION 1.(c) Under Minnesota Statutes, section 62A.672, subdivision 2, a health carrier shall not exclude or reduce coverage for a health care service or consultation solely because the service or consultation is provided via telemedicine directly to a patient at the patient’s residence.
Here is a link to SF4334.
The HHS/OCR waiver on HIPAA penalties only applies at the Federal Level.
You still need to follow state law and likely individual payer policies as many payers require the use of HIPAA-compliant software for telemedicine reimbursement. All this means is that you will not be fined or sanctioned by the OCR for a HIPAA violation when using non-compliant video services for Covid-19 related telemedicine. This only applies at the Federal Level.
Setting up BreezyNotes and Submitting Claims for Telemedicine
The primary requirement for sending a telemedicine claim is a Service Facility with Place of Service = 02. Most payers also require you to use a Modifier on your Billing code.
To learn how to set up your BreezyNotes software for telemedicine billing, click here.
Billing and Reimbursement
IMPORTANT NOTE: There are many different requirements for billing telemedicine that vary from payer to payer and seem to change from month to month. We cannot guarantee the accuracy of any of the following information, but offer it to you as general guidance and best practices based on the experience of our BreezyBilling team as of March 2020.
- Check eligibility and find out each PLAN’S specific requirements before billing for telemedicine.
- If you have a high volume of clients, consider having them call their insurance company and ask specifically if their plan covers “telemedicine” (not “teledoc”). Make sure to give them the billing code or codes you intend to use, and have them ask if there are any special location requirements for the provider or the client.
- There are many caveats on how to bill and get reimbursed by payers, but here is a general outline:
- Payers and plans that typically cover telemedicine:
- Optum/Medica/UnitedHealthcare
- HealthPartners
- State Plans like PMAPs and straight Medicaid – Some States require a telemedicine assurance statement.
- In our home state of MN, DHS requires that each individual provider complete a telemedicine assurance statement (link).
- MN Payer Ucare also requires a copy of the form for each provider (see Ucare Bulletin).
- Payers that typically DO NOT cover telemedicine:
- Blue Cross Federal
- Bind
- For all others, contact the payer to ask about your client’s specific plan (or BreezyBilling Customers submit a benefits check request).
- Other things to be aware of:
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- Some plans cover a limited number of sessions. If you think you’ll go over three sessions, contact the payer and see if you need an authorization.
- Some payers require that the client be in a HIPAA Compliant Facility.
- If you are doing a Diagnostic Assessment (billing a 90791) contact your client’s plan.
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- Payers and plans that typically cover telemedicine:
Make sure you use the correct Billing Codes and modifiers:
UPDATE January 2024 – Nearly all payers are now accepting Place of Service 10 or 02 with no modifiers for all telehealth claims. As such we are striking out previous POS and Modifier details.
| Carrier | Place of Service (POS) | Modifier | Updated | Notes |
|---|---|---|---|---|
*Medicaid MN requires a processed Provider Assurance Statement for every NPI submitting claims. It is taking them 45 days to process the statements. If you submitted your Provider Assurance Statement less than 45 days ago, DHS recommend that you submit with Place of Service 11 (Office), a standard billing code, and then document in the note that it was a telemedicine visit.
If you’re unsure or it’s your first time billing a telemedicine claim to a payer, call them.
Attestations
Some payers require Attestations before they will process your telehealth claims. Many of those that do are waiving those requirements temporarily or giving providers a workaround. The bottom line is check our table below and get them in.
| Payer | Attestation Required? | Additional Notes |
|---|---|---|
| Aetna | No | |
| BCBS (MN) | No | |
| Cigna | Yes (link) | Details here. |
| HealthPartners | No | |
| Medicaid (MN) | Yes (link) | |
| Optum/Medica/UBH/Etc | Yes (link) | |
| PreferredOne | No | |
| Ucare | Yes (link) | All providers with NPIs must have a form on file with Ucare, however a group can complete one form and include a spreadsheet of all providers and their NPIs. Details here.
Use Medicaid’s form, but fax to 612-676-6501–ATTN: CLAIMS SUPPORT (details here) |
- Documentation
- We also recommend putting a sentence or two about medical necessity of the telemedicine visit in your progress note.
- Here are the state requirements: MN Statute 265B.0625, Subdivision 3B, Section C. Most Payers request that your notes include the following, but check with each payer’s reimbursement policy to confirm your documentation requirements:
- Session Start Time
- Session Stop Time
- Location of Client (Originating Site)
- Location of Therapist (Distant Site)
- Modality Used (specific name of tool like “Google Meet,” “Doxy” or “Telephone”)
- Medical Necessity – Why you are using this technology.
If you have heard anything new or have anything to add to this conversation, please contact us. Given the changing nature of the response to Covid-19 and telemedicine in general, the more we communicate the more accurate we can be.
Additional Telemedicine Resources:
- APA’s sample Informed Consent
- APA’s sample Telehealth Technology Checklist
- NAMI’S updates on the Corona Virus and working with people with mental illness.
- State Telemedicine documentation requirements.
Additional Coronavirus Resources: