April 17, 2020
COVID-19 Program and Billing Updates for Adult CDT and PHP
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 Treatment/ 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
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Adult Continuing Day Treatment (CDT)
8April 17, 2020
• Programs must make a minimum of five (5) telephonic outreach efforts to every enrolled program participant each week (at least one per day). Programs should continue efforts to engage those participants who are difficult to reach.
• All outreach efforts must be documented.• 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.
• For individuals receiving services from a psychiatrist or nurse-practitioner, medication management must be provided at least once per month. This may be done telephonically.
CDT Program Expectations
9April 17, 2020
For existing CDT clients during the disaster emergency period (effective 03/07/20), or until such time as supplemental guidance is issued: • Treatment plan reviews are not required and may be postponed as needed. • Providers may work under existing treatment plans and provide additional services as
needed to ensure continuity of care and address mental health needs related to the disaster emergency.
• The need for additional services which were not already documented in the treatment plan should be documented in a progress note and approved by a physician at the earliest practicable time during or after the disaster emergency.
Changes in Documentation Requirements
10April 17, 2020
For new CDT clients admitted during the COVID-19 disaster emergency period, or until such time as supplemental guidance is issued:• Initial treatment plans and assessments may be established via telemental health
capabilities.• Specific timeframes for developing initial treatment 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 treatment 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
11April 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.
12April 17, 2020
• The new guidance establishes program expectations and a reduction or elimination of minimum billing requirements for specific rate codes within the CDT programs.
• These are to be used for billing to be used during the Disaster Emergency, 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
13April 17, 2020
During the declared disaster emergency (effective 03/07/20), or until such time as supplemental guidance is issued: • Providers may use the full day 41-64 cumulative hours rate code (4317) for any contact
with the individual of at least five minutes. • If an outreach is unsuccessful or the contact is less than five minutes, providers may bill the
half day 41-64 cumulative hours rate code (4311), however:• Programs must include clear documentation of the outreach attempt in the client
record.• Contacts with collaterals are also reduced to the five-minute minimum but the collateral rate
code (4325) must be used.
Reduction or Elimination of Minimum Billing Requirements
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
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Partial Hospitalization
16April 17, 2020
• Programs must make a minimum of five (5) telephonic outreach efforts to every enrolled program participant each week (at least one per day). Programs should continue efforts to engage those participants who are difficult to reach.
• All outreach efforts must be documented.• 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.
• Practitioners may use telephone contact to update assessments, treatment plans, safety plans, etc.
• For individuals receiving services from a psychiatrist or nurse-practitioner, medication management must be provided at least once per month. This may be done telephonically.
PH Program Expectations
17April 17, 2020
During the declared disaster emergency (effective 03/07/20), or until such time as supplemental guidance is issued:• Assessments and service plans should still be completed to the extent possible. • Signatures will not be required at this time, but agreement obtained from the client and
others involved shall be documented. • Service plans should continue to focus on the recipients’ recovery and goals. In these
current circumstances, services and interventions may be provided outside of those outlined in the service plan when it relates to COVID-19 response and need.
Changes in Documentation Requirements
18April 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.
19April 17, 2020
• The new guidance establishes program expectations and a reduction or elimination of minimum billing requirements for specific rate codes within the PH programs.
• These are to be used for billing to be used during the Disaster Emergency, 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
20April 17, 2020
During the declared disaster emergency (effective 03/07/20), or until such time as supplemental guidance is issued:• Providers may use the six-hour rate code (4351) for any contact with the
individual of at least five minutes. • Contacts with collaterals are also reduced to the five-minute minimum but the
collateral rate code (4353) must be used.
Reduction or Elimination of Minimum Billing Requirements
21April 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
23April 17, 2020
OMH Guidance on COVID-19 [Website]CTAC Best Practices in Telehealth [Recorded Webinar]
Links
24April 17, 2020
Thank you all for your continued support of clients and all New Yorkers during this public
health crisis.
