Coronavirus: COVID-19 Provider FAQs

Please reference the DBHDD Provider Bulletin released on March 19, 2020.

• Table A Services should be submitted with the GT service (ACT is the only exception where U1 and U2 practitioners have the GT modifier, but other practitioner level codes do not)
• Table B Services should consider the following:
  • If there is a UK modifier within that Service Definition defined as applicable to telephonic intervention, then submit the Code with that modifier AND the Place of Service code 02;

If there is no UK modifier, submit the service code as normal (considering the telemedicine/telephonic claims as “in-clinic”/U6), only add the 02 code in the Place of Service for the claim submission to MMIS.

No. The 95 modifier is not a recognized modifier affiliated with the DBHDD/Medicaid billable behavioral health codes.  The addition of that modifier will yield a denial in the MMIS system.

There is currently no consideration of additional payment for telemedicine modality used in the provision of Community Behavioral Health Rehabilitation Services program through the Q – code-named above or through other mechanisms (as administrative costs such as telemedicine were considered and included in the reimbursement rate structure).

Telemedicine is the use of medical information exchanged from one secured site to another via electronic communications to improve a patient's health. Electronic communication means the use of interactive telecommunications equipment that includes, at a minimum, audio and video equipment permitting two-way, real time interactive communication between the patient, and the physician or practitioner at the distant site (defined in the DBHDD Behavioral Health Provider Manual, Glossary).  In response to COVID-19, Federal and State authorities are referencing the term “telehealth” which is a broad definition which encompasses phone, text, email, monitoring, and other modalities of interaction as being enabled.  Very specifically, DBHDD and DCH are enabling some telemedicine and telephonic options on accordance with this Provider Bulletin.

DBHDD is aware of the State of Georgia Rule and Regulation 135-11-01 and the rules governing Professional Counselors, Social Workers, and Marriage and Family Therapists on the use of a term called “telemental health.” “Telemental health” is defined in the regulation as a mode of delivering services via technology-assisted media, such as but not limited to, a telephone, video, internet, a smartphone, tablet, PC desktop system or other electronic means using appropriate encryption technology for electronic health information. TeleMental Health facilitates client self-management and support for clients and includes synchronous interactions and asynchronous store and forward transfers. The regulation requires that any licensee has obtained a minimum of six (6) continuing education hours before providing “telemental health.” Additionally, prior to the delivery of supervision via telemental health, the supervisor shall have obtained a minimum of nine (9) hours of continuing education to provide Supervision.

DBHDD heard your concerns regarding the continuing education requirements associated with telemental health and how the state regulations present a hindrance for some licensed staff who are eager to provide supports to individuals using telehealth functionality during this public health emergency. To support our providers and the individuals we serve, DBHDD approached the Georgia Board of Professional Counselors, Social Workers, and Marriage and Family Therapists to seek a waiver of the telemental health continued education requirements through the duration of the COVID-19 pandemic. More specifically, we sought a waiver of the regulation that requires licensees to obtain at least 6 continuing education hours before providing telemental health and the regulation which requires supervisors to obtain at least 9 hours of continuing education before providing supervision.

We recently learned that the Board opted not to waive the requirements. Like you, we are disappointed with the Board’s decision. The Board did vote, however, to allow all continuing education courses to be completed online. We urge all providers to abide by the regulations governing licensure. If additional continuing education is needed to deliver services, we request that providers work expeditiously to meet established requirements. Additional information regarding governing regulations can be found at the Secretary of State’s website.

The DBHDD will allow documentation of verbal agreement for an IRP via phone.  The Progress Note shall clearly indicate that all typical content associated with a face-to-face process of delivering Service Plan Development was met, including the engagement with the individual served as a full partner in that process.

The DBHDD will allow documentation of verbal consent via telemedicine or phone. The required consent as defined in the DBHDD BH Provider Manual is designed and promulgated by the Department of Community Health.  To access the Consent Form: https://www.mmis.georgia.gov/portal/; then click Provider Information > Provider Manuals > Telemedicine Guidance.  The documentation of the verbal consent in the progress note should include basic elements from the form in the absence of that signed document.

The DBHDD will allow documentation of verbal consent via phone.  Email consent would also be acceptable if the consent request is 1) sent through encrypted technology or 2) is generalist enough to transact without concern regarding HIPAA/42 CFR Part 2.  To access the Consent Form: https://www.mmis.georgia.gov/portal/; then click Provider Information > Provider Manuals > Telemedicine Guidance.  The documentation of the verbal consent in the progress note should include basic elements from the form in the absence of that signed document.

DBHDD does not constrict the “distant site” definition to be facility-based.  All providers and their associated practitioners MUST be cognizant of HIPAA and 42CFR Part 2 regulation, considering the distant site security as well.  Consider that having a Telemedicine session from a non-facility distant site (such as from a personal home with other family members within earshot) would not be permissible.  Your agency must still comply with all state and federal laws related to security and confidentiality.

The DCH Medicaid CMOs are not obligated to follow DBHDD guidance.  The DCH and CMOs will set their specific provisions for service access (if any).

The codes that will be billed must be identified as “telehealth services” by utilizing either a telehealth Place of Service (POS) code or a telehealth modifier (e.g., GT).  In the DBHDD Guidance dated March 19, 2020, for services in Table A, a provider would use the designated GT Modifier and bill the appropriate U Code for the particular practitioner level (no use of U6 or U7 as these codes are not currently programmed in the GAMMIS system).  For the services in Table B, they would use the POS code.

Please remember that the only service codes that can be billed are those currently identified in the DBHDD Community Behavioral Health Provider Manual.  If a provider tries to add any modifier to a base service code which is not identified in the manual, then it will deny.

No.  As specified in the DBHDD Guidance dated March 19, 2020, for services in Table A, a provider would use the designated GT Modifier and bill the appropriate U Code for the particular practitioner level.  For the services in Table B, they would use the POS code.

The Georgia DBHDD is aware of the State of Georgia Rule and Regulation 135-11-.01 and the rules governing Professional Counselors, Social Workers, and Marriage and Family Therapists on the use of a term called “telemental health.”  The scope of applicability for that regulation is specific only to Professional Counselors, Social Workers and Marriage and Family Therapists.  No other practitioner type recognized by DBHDD is required to take this training and therefore, those practitioners can proceed with delivering services as defined in the DBHDD March 19 correspondence.  Additionally, if the practitioner is governed by the Composite Board Rule and Regulation 135-11, they must complete the CEUs as defined by the Board before doing any telemedicine or telephonic service delivery.  Once the regulatory expectations of the Board are fully met by one of those practitioners, then he/she may begin service delivery.

 

Please see the notice posted by the DBHDD related to this here.  There is also a newly posted meeting announced on the Secretary of State website for April 3, 2020.

For initial intakes where an ID would typically be requested from an individual, the agency has the following alternatives, with the expectation that a physical copy will be made at the time of the next face to face meeting or, if that is not possible, that post-emergency period, this will be gathered for the health record:

• For a telemedicine intervention or other allowed visual platforms:
  • The person may show his/her ID to the practitioner.  The person should show the ID long enough for the agency staff to document the ID#.  That ID number should be documented in the record.
  • For Medicaid ID, a person’s Medicaid eligibility and number can be verified in the GAMMIS portal; however, if the agency staff does not have access to that portal in real-time, the card can be visually shown, number recorded, and then the agency can verify after that intervention through the agency billing office. 
  • Document that the ID was seen by the staff and note the identifying information in the medical record.
• For an audio mode of service delivery:
  • The person may tell the intake staff what type of ID he/she has (e.g. State of Georgia Driver’s License) and then provide that license number to be documented in the medical record.
  • For Medicaid ID, a person’s Medicaid eligibility and number can be verified in the GAMMIS portal; however, if the agency staff does not have access to that portal in real-time, the ID number can be read by the presenting person to the intake staff, the number recorded, and then the agency can verify eligibility and billing detail after that intervention through the agency billing office.
  • Document that the ID information was requested and document any identifying information in the medical record.

In terms of taking a photo of an ID via screenshot, DBHDD does not recommend this as phones/cameras and email have varying degrees of security, and therefore vulnerabilities for data breaches, security risk, identity theft, etc.

The Crisis Intervention service has been allowed to be provided via telephone for many years.  Just as with a face-to-face crisis intervention, the practitioner should more to a quick situational assessment; active listening and empathic responses to help relieve emotional distress; effective verbal and behavioral responses to warning signs of crisis related behavior; assistance to, and involvement/participation of the individual (to the extent he or she is capable) in active problem solving planning and interventions; facilitation of access to a myriad of crisis stabilization and other services deemed necessary to effectively manage the crisis; mobilization of natural support systems; and other crisis interventions as appropriate to the individual and issues to be addressed. 

If the individual has family or other natural supporters in the home, request and document verbal consent to engage those individuals in monitoring and supporting the person.  As always, the Mobile Crisis network, Crisis Stabilization Units, Georgia Crisis and Access Line, and emergency responders are options when there is no other clinical alternative; however, we call upon the DBHDD Provider Network to use those resources prudently, using your best skill possible to stabilize the individual remotely to protect that individual from the need to be exposed to face-to-face service in a larger group setting.

When available either through the agency’s EHR or through the individual, an individual’s existing crisis plan should be utilized by the supporting practitioner when it is appropriate to the presenting situation. When a crisis plan does not exist, the practitioner will engage the individual/family/caregivers in a therapeutic plan that fosters a return to pre-crisis level of functioning and connect or reconnect the individual to treatment services and other community resources. Also, when available and offered by the individual, a Wellness Recovery Action Plan (WRAP) shall be utilized by the practitioner to support the individual’s preferences. For individuals with a co-occurring IDD, an individual’s behavior support plan shall be referenced during the crisis assessment and intervention process. 

Also, depending on which code is used, note that the Crisis Intervention service can be provided between 2-3 hours in a day, so a practitioner can spend an extended time or make multiple calls to an individual in a single day to create an in-home stabilization plan.  Family Training can also be quickly engaged by the same practitioner to work with those individuals on what to monitor.  If there are no in-home family members, consider friends or neighbors who may be supporters to the individual, using Case Management for adults or Community Support for youth to engage those other released parties in a supporting crisis/safety plan.

At this time, we are unable to provide guidance related to the Shelter in Place order as it has not been signed by Gov. Kemp or released. We have been told that additional details about the order will be released today and this information will be available on the Department of Public Health (DPH) website as this order is being developed in concert with DPH:  https://dph.georgia.gov/novelcoronavirus.  

Additionally, DBHDD is not able to provide documentation to provider agencies as they are responsible for creating their own documentation regarding travel to and from work for essential personnel.  DBHDD encourages you to review the Governor’s order once it has been signed to ensure that your agency meets the definition of “essential worker”. 

At this time, the only training that has been adjusted to date is for CPR and CPI.  This was distributed in a Provider Relations special bulletin on 3/31/20.  Any future allowances that are made will be communicated via the Provider Relations Special Bulletins.

Due to Covid-19, DBHDD understands that some fingerprinting sites have reduced hours or are closed. Therefore, during Georgia’s Public Health State of Emergency, the “attestation” process set forth in the DBHDD policy - COVID-19 2020: DBHDD Community Behavioral Health Services Policy Modifications – 3/26/2020 and can be found at the following link to PolicyStat:  https://gadbhdd.policystat.com/policy/7845537/latest/

The State of Georgia Rule and Regulation 135-11-.01 and the rules governing Professional Counselors, Social Workers, and Marriage and Family Therapists on the use of a term called “telemental health” are only applicable to Professional Counselors, Social Workers, and Marriage and Family Therapists.  No other practitioner type recognized by DBHDD is required to take this training and therefore, those other practitioners can proceed with delivering services as defined in the DBHDD March 19 correspondence. 

     For any of the licensed practitioner noted above that is governed by the Composite Board Rule and Regulation 135-11, they must complete the CEUs as defined by the Board before doing any telemedicine or telephonic service delivery.  Once the regulatory expectations of the Board are fully met by one of those practitioners, then they may begin service delivery.  Even though the Board did note vote to waive this requirement completely, they did vote to allow all continuing education courses to be completed online.

There is no provision for “billing” for attempts at engaging individuals in an intervention.  Only interventions directly with the individual (or collateral as indicated in a specific service definition) are billable.

The agency should first consult its own CST Organizational Plan which requires the following to be met:

CLINICAL OPERATIONS, Item 13:  The organization must have an CST Organizational Plan that addresses the following:

• Organizational Chart, staffing pattern, and a description of how staff are deployed to assure that the required staff-to-consumer ratios are maintained; including how unplanned staff absences, illnesses, and emergencies are accommodated;

If the agency relies on another agency nurse to fulfill the role of the CST nurse, then that nurse is acting as a CST staff and should bill under the CST code.  He/she should also be participating as a team member to the best of the agency’s ability during this COVID-19 crisis.

DBHDD considers the title Nursing Assessment and Health Services as an umbrella naming convention for all of the Nursing Services included in the BH Provider Manual.  Therefore, the Special Conditions are applicable to this group as a whole.