Within this page are a series of topic oriented questions and answers which will provide information on how operations and procedures have changed during the COVID-19 outbreak.

Select a provider topic below to display the frequently asked questions specific to that topic.

Have a question for Partners? Click here to email us directly.

Although service authorization request (SARS) are temporarily waived, is the limit still 270 managed and 64 unmanaged?

(Answer posted April 17, 2020) Because SARS are temporarily waived, service units will remain the same.  All will be unmanaged with no authorization needed.

What about clients with PSR SARs due to them requiring more than the pass-through limits?

(Answer posted April 9, 2020) All units are unmanaged from March 19-April 30, 2020.  Members can continue their current level of service during this period.  They do not require an authorization.

Will prior authorization be required?  

(Answer posted March 25, 2020) Effective March 19, 2020, Partners is lifting the requirement to obtain prior authorization for member services until April 30, 2020. Providers can continue to deliver and bill for services. (Source: Partners Communication Bulletin #103)

Will current authorizations for care be extended?

(Answer updated April 15, 2020) Partners has now extended this period through May 31, 2020. Providers can continue to initiate, continue to deliver, and bill for services.

  • The number of units that were approved in the most recent authorization will stay the same.
  • All services should reflect Medically Necessary care.
  • Upon the first concurrent authorization after this period, all documentation must be submitted to Utilization Management according to the Service Definition and additional guidance from NC DHHS.

Services billed during this period for dates of service prior to March 19, 2020 are subject to pre- or post-payment review.  Claims may be denied/recouped due to no authorization. (Source: Partners Provider Alert COVID-19 #17)

(Answer posted March 25, 2020) Effective March 19, 2020, Partners is lifting the requirement to obtain prior authorization for member services until April 30, 2020. Providers can continue to deliver and bill for services.

  • The number of units that were approved in the most recent authorization will stay the same.
  • Medical Necessity will still apply.
  • Upon the first concurrent authorization after this period, all documentation must be submitted to Utilization Management according to the Service Definition and additional guidance from NC DHHS. (Source: Provider Communication Bulletin #103)

Do hospitals need to still call Utilization Management if authorization numbers aren’t going to be given? 

(Answer posted March 25, 2020) For providers of acute services (Inpatient, Facility Based Crisis, Partial Hospitalizations) a Service Authorization Request (SAR) is not required for Dates of Service (DOS) with start dates of March 19, 2020, and end dates before April 30, 2020. SARs submitted with start dates of March 19, 2020, and end date before April 30, 2020, will be reviewed as Unable to Process (UTP) because no SAR is required. Medical Necessity criteria will still apply to services during this timeframe. SARs will be required when services extend beyond April 30, 2020. However, dates (in a Length of Stay) before the end date of April 30 will continue to be unmanaged.

Some providers have received adjusted authorizations for I/DD members who did not utilize the COVID-19 Appendix K flexibilities for the NC Innovations and TBI waivers; these authorizations include increased units, dates shortened, etc.  When this was brought to the attention of Care Managers, they were not sure why the authorizations were being adjusted. Will these adjustments occur for all members?

(Answer provided during the August 5, 2020 Provider Information Session.) An administrative solution by Partners has been implemented to correct the problem in the AlphaMCS system during the non-authorization period of flexibility.  This has been explained to Care Managers; however, it can be confusing, especially as some cases were not able to be administratively addressed. We appreciate your patience. If you continue to see information that causes you to question what is in the system, please call Partners’ Utilization Management (UM) workgroup at 704-842-6434.

For EOR Training we are receiving new authorizations for Community Navigator with a U1 modifier. It was previously a U2. Is this a mistake?

There are three different codes for a community navigator.  It’s possible for an error to be made. Please reach out via email if you have a question for a specific authorization or member.

Will members utilizing FL modifier receive an authorization with FL modifier listed? 

(Answer provided during the August 5, 2020 Provider Information Session.) Utilizing FL modifiers indicates Appendix K flexibilities are being utilized and no authorization is needed.

What are the reporting requirements should one of our staff or members served test positive for COVID 19?  What would our next steps be if a test is positive? Must we shut down services?  

(Answer posted March 25, 2020) Partners is clarifying guidance from NC DHHS. Typically, if a member is ill, Innovations calls it a service break, not suspension of services. Partners anticipates further guidance as DHHS continues to provide guidance on flexibilities in this area. However, Partners requests that if you have questions you should refer to the NC DHHS website regarding COVID-19 updates. Partners asks that you follow the Center for Disease Control and Prevention and NC DHHS information for health care providers.

Will there be any flexibility or changes to the credentialing process?  

(Answer posted March 25, 2020) No changes to requirements for clinician credentialing have been made at this time.

Partners is working with the other LME/MCOs collaboratively around any changes that may be helpful for providers. If you have questions about the status of a credentialing application, please contact us at credentialingteam@partnersbhm.org or 704-842-6483.

Are the In Lieu of Services (ILOS) only for Medicaid recipients, not state funded?

(Answer part of April 21, 2020 PSR Specific Provider Information Series) Yes, this service is only for Medicaid members. https://providers.partnersbhm.org/service-definitions/

Could you clarify ILOS documentation?  Should we put all service contacts in a daily note or weekly note?

(Answer part of April 21, 2020 PSR Specific Provider Information Series) We want to give you the flexibility in reporting.  The provider will need to show the minimum requirements of the flexibilities are met. We do not recommend a checklist check list.

What are the traditional PSR flexibilities?

(Answer part of April 21, 2020 PSR Specific Provider Information Series) Please see Special Bulletin 46 Behavioral Health Service Flexibilities

When will provider contracts be updated to include H2017 U5?   

(Answer part of April 21, 2020 PSR Specific Provider Information Series) The new codes should already be in AlphaMCS.  We are not updating paper contracts with every change currently due to the demand.  If you don’t see that codes have been updated in AlphaMCS for your agency or have questions, please reach out to your account specialist.

Do we use CR codes with In Lieu of Service Definitions?

(posted April 14, 2020) We have received clarification from the State that we should not use the CR modifier on in lieu of service definitions.  The CR modifier is for the State’s use and for codes they identify not for our own definitions.  So, they are saying we cannot use the CR modifier.   Please use the modifier U5 on the PSR in lieu of definition.  H2017 U5.

For In Lieu of PSR, will H2017 be available after COVID 19?

(posted April 14, 2020) We will probably have periods of time that the Division may require we use this again if public health warrants us to do this due to another state of emergency requiring social distancing or resurgence of a pandemic.   This service is written in lieu of PSR so that providers can deliver this service in the community and still meet member needs.

Is individual (one to one) IRCS limited to 10 hours per week?

(posted April 14, 2020) In order to be cost neutral, IRCS is limited it 10 hours per week.

What is the place of service for IRCS?

(posted April 14, 2020) Any natural setting

What place of service code should be used for IRCS?        

(posted April 14, 2020) “Other “can be used as a valid code.  Specifically, it is listed as Other Unlisted Facility

What would be the best way to indicate that PCP or CCA has been cross walked to IRCS?

(posted April 14, 2020) You can cross walk the service in the PCP Progress Update note if the PCP comes due during this time. (to avoid needing to create a new PCP with the new In Lieu of Service Definition).

When can we initiate the IRCS services?     

(posted April 14, 2020) Now. Retro back to March 10, 2020.

When will this In Lieu of Service Definition be statewide?

(posted April 14, 2020) This has been shared with other LME/MCO’s. For now, it is just Partners. Each LME/MCO would need to choose to adopt it.

Can we offer members PSR and some IRCS?

(posted April 14, 2020) Yes, if each member gets one or the other. You cannot alternate between both services for one member.

Is this similar to case support services?

(posted April 14, 2020) Yes, it is similar.

Can we have 90 days to get training done if staff have something due?

(posted April 14, 2020) We currently are giving a 30-day extension for mental health services.  We have extended this to May 31, 2020.

Can you publish the rates again? Are they negotiable?

(posted April 14, 2020) PSR In lieu of is billed in 15-minute units

$8.22/ unit

This service is to be:

  • Minimum of one unit per day, five days per week is delivered
  • Maximum of 10 hours per week, five days per week hours per day
  • May be provided on weekends or in the evening
  • The number of hours that participant receives IRCS services are to be specified in his or her Person Centered Plan (PCP)

Can we provide IRCS for Members in ALFs with more than 16 beds?

(posted April 14, 2020)

Service Exclusions:

  • ACTT
  • Psychosocial Rehabilitation Services
  • Partial Hospitalization
  • Day Treatment
  • Residential Treatment
  • Intensive In-Home
  • Family Centered Treatment
  • Multisystemic Therapy
  • Young Adults In Transition
  • High Fidelity Wrap Around

The intention is that you can use virtual options to provide care. What is excluded is the ability to walk into the excluded location and offer face to face care. You can call to check on them. You can use tele options to do sessions and interventions.

Do we know when these codes will be gone?

To date, we have been working with the State regarding any phasing out of codes and flexibilities. Those have not been fully decided or the timing of those decisions.  We will ensure that the providers have adequate lead time to be able to adjust to phasing out any of the flexibilities in place.

Can you show the In Lieu of Service Definitions rates and units in a grid format?

In lieu of Service Definitions Rates and Units Information:

Service Name

Service Code

Benefit Plan

Rate

Unit Type

Individual Rehabilitation, Coordination & Support Services H2017U5 Medicaid $450/unit Weekly Unit
Virtual Psychiatric Intensive Outpatient H0035U5 Medicaid $737.73/unit Weekly Unit
SUD- Comprehensive Outpatient during Disaster H2035U5 Medicaid $867/unit Weekly Unit
SUD- Intensive Outpatient Programming during COVID H0015U5 Medicaid $400/unit Weekly Unit

Services in Alternate Settings

Can Supported Employment be completed in the licensed facility?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Supported Employment can be provided in an alternate location and these locations include the member’s home, the home of the direct support professional or the residential home.  Supported Employment can be provided in a licensed residential home.

If Supported Employment is done by another agency and the residential program has no visitation in place, can the plan be changed for the residential provider to do the SE and submit on the form?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) The residential provider can deliver Supported Employment to the member.  The service would need to be documented and the claim submitted by the residential provider for the service.

Can a member who was attending a day program, that resides in a group home, get Day Supports in the group home now? If so, who gets paid to do that?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Day Supports can be provided in an alternate location and these locations include the member’s home, the home of the direct support professional or the residential home.

The provider who delivers the service will be the provider paid for the service, even if this is not the provider currently authorized for the service.

The YMCA is closed, I have a member who goes there to swim once per week, can this member use that time to do a different activity with the units that are already approved?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) There are several services which can be delivered in alternate settings – Day Supports, Community Networking and Supported Employment.  If the service being received to support member at the YMCA is one of these, this service can be delivered in the member’s home, in the home of the direct support employee or in the residential setting.

Can day supports be provided in alternative locations other than the community and the actual day program? If so, what locations would Partners consider suitable for services? 

(Answer posted March 31, 2020) Appendix K indicates that Day Supports can be provided in the home of the member, the home of the direct care worker, or the residential setting. There also are some provisions for the delivery of services in temporary settings such as hotels or shelters if the member is displaced because of COVID-19 related issues.

Can community networking services be delivered in the individual’s home as listed in Appendix K?

(Answer posted March 31, 2020) Yes, Community Networking is one of the services listed in Appendix K which can be delivered in an alternate setting such as the member’s home.

Can respite be provided out of the home if the member is out of the state? (We have (Direct Support Professionals) DSPs that live in SC.)

(Answer posted March 30, 2020) Currently, policy does not allow services out of state without prior approval by LME-MCO and does not allow for Respite to be provided out of state. The flexibility requested in Appendix K is to waive prior approval for individuals who are displaced and allow for Respite to be provided out of state only when family is out of state due to evacuation/displacement until they return home.

Can respite be provided in the member’s home for over 30+ consecutive days?

(Answer posted March 30, 2020) Respite can be provided for up to 30 consecutive days. After a minimum one-day break, another 30 consecutive day period can begin.

Can respite out of home be provided for 30 days plus+ consecutive days?

(Answer posted March 30, 2020) One flexibility requested in Appendix K is to allow out of home Respite to be provided in excess of 30 days on a case by case basis.

What notification is needed for location changes to where the periodic service is being provided?

**Answer Updated** (Answer part of April 2, 2020 I/DD Specific Provider Information Series) The service delivered must be documented.  Documentation of service provided in alternate location should include the location and note COVID-19.

(Answer posted March 30, 2020) We are finalizing notification process and will provide more information soon.

What notification is needed for location changes to where residential service is being provided?

**Answer Updated** (Answer part of April 2, 2020 I/DD Specific Provider Information Series) The service delivered must be documented.  Documentation of service provided in alternate location should include the location and note COVID-19.

(Answer posted March 30, 2020) We are finalizing the notification process and will provide more information soon.

If a member goes to the hospital, what is the process to send a Direct Support Professional (DSP) into the hospital with the individual?

(Answer posted March 30, 2020) Appendix K does include request for service to be provided in acute care hospital or institutional setting. However, only CLS can be provided and only “when the waiver participant is displaced from home because of COVID-19 and the waiver participant needs direct assistance with ADLs, behavioral supports, or communication supports on a continuous and ongoing basis for three or more hours per day.” Respite was not approved by CMS. It is highly unlikely that an acute care hospital would allow a DSP to be present. If a provider believes that CLS in these settings is indicated, the provider should call UM to discuss.

If hospital personnel do not understand the need for the DSP to be with the member at all times, what is the liability of the DSP in this case?

(Answer posted March 30, 2020) It is highly unlikely that a DSP would be allowed to be present in an acute care hospital with a member who has been hospitalized with COVID-19 symptoms. The hospital can refuse entry.

If Supported Employment isn’t feasible during this time, what is the process to implement other services in its place?

(Answer posted March 30, 2020) The I/DD Care Manager should be contacted to discuss alternative service and location for same. NC Medicaid is currently working on a second Appendix K and the intent is to provide additional services, inclusive of Supported Employment, to be delivered in alternate settings.

Day Supports Group vs. Individual Services

Are providers supposed to bill individual services in alternative Day Support settings even if the member was receiving group services before?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) The service which most closely matches the support being provided can be provided.  If the service is being provided in a group, Day Supports Group is most appropriate. If the service is provided with one on one support, Day Supports Individual would be the most appropriate.

Can you provide a service that is not in the ISP? For example, if a member has Day Supports Individual but, due to staffing, is in a group setting, can we get authorized for Day Supports Group?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) If Day Supports Group most closely matches the support being provided, the provider can submit claim for Day Support Group even if that is not the intensity of service in member’s plan.

In regard to the June 30 end date for extensions to existing ISPs that need to be updated, has there been any news regarding extension?

For extensions to current authorizations: we plan to review requests to services effective July 1. We have not currently processed revisions not related to COVID-19.  Those should go on to revision forms but do not have to be submitted to UM until July 1. We are in process of educating our Care Managers about the decision to begin reviewing authorizations as of July 1.  So this is a new process decision.  Keep in mind that we have instructed Care   Mangers to continue to add updates to plans, even though the updates are not being submitted to UM, so that documentation is accurate.

Is there any updated guidance from the state of how to reopen day program services? The last one was 4/24.

Partners will be offering training on guidance offered for opening day programs during our June 10, 2020 Quarterly Provider Forum from 1-3pm. NCDHHS has published two guidance documents so far. April 23, 2020 document titled “BH/IDD Day Program and FBC Guidance” as well as May 27, 2020 “Interim Coronavirus Disease 2019 (COVID 2019) Guidance for Day Camp or Program Settings Serving Children and Teens.

Services Not in Contract

If a provider is not contracted with Partners to provide a service, the member needs can we still bill that service?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) If the provider of authorized service is not able to deliver the service, another provider may be needed.  If the provider who is able to deliver the service is not contracted for that service, a decision will need to be made on a case by case basis. Examples

  1. If the provider able to support member is contracted for another service which could be provided in the setting, the provider should provide the service in their contract. This will allow the provider to submit claims for the service, even if the service is not currently in the members plan or authorized.
  2. If the provider able to support member is not contracted for any of the services which can be delivered in the setting, the provider can deliver the non-contracted service currently included in the member’s plan.

Health and Safety Checks

Are requirements for the agency’s health and safety checklist for services being provided in the staff’s home being waived temporarily, if services that are not usually provided in this setting? 

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Providers should make best effort to assess the environment through means other than a face-to-face visit.  These could include the use of interview with DSP, video and/or pictures.  Providers need to maintain documentation of methods used.

Can services be allowed in a DSP home that has not yet had a Health and Safety inspection?

(Answer posted March 30, 2020) Quality Management is still conducting Home and Safety Reviews when requested by providers via Skype/FaceTime or photos sent in for review.

Alternative Family Living (AFL) Settings

Can Day Supports, Supportive Employment and/or Community Networking be provided in the AFL residential setting by someone else who is also an employee of the provider agency that lives in the same AFL home but, is not the designated residential provider (primary AFL worker)?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Yes

If there is another resident of the AFL home who could provide services, can we hire that household member without a background check or training?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) The ability to allow service delivery in absence of background check and training is limited to relatives of the member at this time.

Can Supportive Employment and Community Networking be delivered in the AFL home?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Both Supported Employment and Community Networking are services which can be delivered in an alternate setting, inclusive of the residential setting.  However, the primary AFL worker cannot deliver these services to the member.

Can one DSP provide multiple services in the home? (For example: can a DSP that is providing AFL Residential Supports also provide Day Supports and/or Community Networking?)

(Answer posted March 30, 2020) One Direct Support Professional can provide multiple services with one exception. The Primary AFL worker cannot deliver any other service to the same member. Waiver of this was not included in Appendix K but is now under consideration to be requested in a future request.

Are there any options being considered for AFL providers to have relief? Such as CLS or CN to be provided in home instead of SE?

(Answer posted March 30, 2020) One of the flexibilities requested in Appendix K is to allow service to be provided in alternate setting. Specifically, Community Networking or Day Supports can be provided in member’s home, the home of a direct support employee or in the residential setting. One of these two services could be provided in the AFL setting but not by the primary AFL worker.

Can a residential provider be allowed to provide more than the AFL service? For example: CLS or CN?

(Answer posted March 30, 2020) The residential provider agency can deliver more than Residential Supports-AFL. However, the primary AFL worker cannot deliver services other than Residential Supports-AFL.

If an individual gets group services versus one on one, can the residential provider deliver group service to the one individual in the home?

** Answer Updated** (Answer part of April 2, 2020 I/DD Specific Provider Information Series) The service which most closely matches the support being provided can be provided.  If the service is being provided in a group, Day Supports Group is most appropriate. If the service is provided with one on one support, Day Supports Individual would be the most appropriate.

(Answer posted March 30, 2020) There is the option for the residential provider agency to provide service to an individual. They become a group of one. If the individual resides in an AFL, the primary AFL worker cannot deliver the service.

Has there been a rate increase for AFL services? Which services have been approved for a rate increase at this time?

(Answer part of April 15, 2020 I/DD Specific Provider Information Series) At this time, there have been no rate increases for Innovations services.  For Innovations services, the ability to provide services such as Day Supports in alternate settings (including the residential placement) is a way that residential providers are able to receive additional funding to support increased costs.

We understand that one pressure point for providers who operate Alternative Family Living (AFL) homes is that the waiver does not allow the primary AFL worker to deliver other services to the member. NC Medicaid is requesting CMS approval for the primary AFL worker to deliver other services in the second Appendix K waiver request.

Provider Supervision of Staff

Are provider agencies allowed to do telephonic supervision for agency staff?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Supervision can be conducted via telephone or other means such as Zoom unless there is a health/safety concern which requires a face-to-face.

Can all Direct Support Providers (DSP) supervision be conducted via Zoom during this time period, this would include Relative as Direct Support Employee (RADSE) and DSP supervisions, not just Residential service providers?

(Answer posted March 31, 2020) Supervision can be conducted via Zoom unless there is a health/safety concern which requires a face-to-face meeting.

Are phone calls and video monitoring appropriate for the agency as well as care coordination? (the bullet before contact person)

(Answer posted March 30, 2020) Yes, provider agencies can use phone calls and video monitoring at this time unless health/safety issues require face-to-face contact.

Relatives of Members

Can you hire a relative of a member without a background check AND having current trainings?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Relatives of adult members who reside in the home and out of the home can be hired to provide services prior to background check and training for 90 days.

If a relative is already providing Community Living and Supports through another agency, can they also provide Day Supports?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) A relative of an adult member can provide both services and can be employed by two different agencies.

Do providers have to complete a RADSE form to allow RADSEs to provide new services such as Day Supports, Supportive Employment, or Community Networking?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) You do not have to obtain prior approval from Partners for the RADSE to deliver more than 40 hrs/week of service or to provide service other than the typical CLS.  Provider agencies need to report their use of this flexibility using the reporting form reviewed and maintain documentation in their record regarding the short-term increase in hours and/or services and justification.

In what instances would a RADSE not be allowed to provide services in the home?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Some of the reasons a relative living in the same home with member would not be allowed to provide service in the home include

  • the member is a minor child
  • there is an available direct support professional that is not a relative living in the same home as adult member
  • the relative is not qualified to deliver the service

Is there a cap on the number of hours a RADSE can deliver? Example – if a RADSE is currently doing 45 hours of Community Living and Supports and they need to pick up day supports hours, is there a limit to the hours they can work per week?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) There is no limit at this time.

Can family members provide more than 40 hours per week each, if living in the same home?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) There is no limit at this time on the number of hours of service a relative living in the home with an adult member can provide or how many relatives living in the home can provide service.

Can an RADSE deliver other services besides what they are currently approved for without a written approval? What would be the circumstance to allow this to occur?

(Answer posted March 31, 2020) Appendix K expanded the services an RADSE is allowed to provide and these now include Community Networking and Supported Employment for 90 days. The RADSE should deliver the service only if no other staff is available to do so.

What if diploma/GED issues arise for parents providing services after COVID-19 pandemic subsides?

(Answer posted March 30, 2020) A relative or guardian cannot be hired to deliver service to the member if they do not meet qualifications, inclusive of having a high school diploma or G.E.D. The flexibilities established in Appendix K do not waive qualifications. If a relative/guardian is hired during this emergency with the understanding that they do meet qualifications and it is later discovered that the relative/guardian does not meet qualifications, delivery of service by that relative/guardian must end immediately.

Does the family member still need to be completely trained during the first 90 day period?

To the best of your ability, you should try to get as much of the requirements as possible. We know that some things must be face to face and you just cannot get now (example: CPR).  This has been communicated to DHB and we are hopeful that they will be able to revise flexibility to reflect that the face-to-face training components can be delayed further than 90 days as necessary.

Do the flexibilities in Appendix K start at 90 days from the hire date of the relative or 90 days from the start of Appendix K?

(Answered in May 14, 2020 I/DD Info Series) The flexibilities related to the hiring of relatives without background checks or training begins 90 days from when the relative is hired.

Can a relative outside of the home be hired to work with an Innovations participant?

(Answered in May 14, 2020 I/DD Info Series) Yes, the waiver allows relatives outside of the home to be hired for most services, and Appendix K allows for these relatives to be hired without background checks or initial training for 90 days.

Retainer Payments

When will more information become available regarding Retainer Payments?

**Answer Updated** On April 22, 2020, Partners published Provider Alert COVID-19 #19—Modifications to Retainer Payment Process with additional information about retainer payments.

(Answer posted April 7, 2020) We are continuing to work with the State on the process to ensure consistency across LME/MCOs.  Partners will alert providers as soon as this is resolved and will ensure that providers understand the process.

Please explain retainer payments.

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Retainer payments are payments made to providers to help them retain Direct Support Professionals who are regularly scheduled to deliver service but are unable to do so due to COVID-19.  Retainer payments only apply to services which are habilitative in nature and the expectation is that the provider pays the DSP his/her normal pay rate.

Will retainer payments be considered for Supportive Employment?

**Answer Updated** On April 22, 2020, Partners published Provider Alert COVID-19 #19—Modifications to Retainer Payment Process with additional information about retainer payments.

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Retainer payments apply to habilitative services which cannot be delivered.  Supported Employment is a habilitative service.

If the retainer payment is given does that prevent the staff from being able to draw unemployment?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) A retainer payment should not be requested if the DSP is receiving unemployment or is otherwise receiving compensation for the time not worked.

Would staff be able to receive retainer payments if we have staffed their member with another DSP person while they are unable to work?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) There will be some situations in which one of the applicable services is delivered by alternate staff due to the unpaid leave (e.g. illness of the DSP or perhaps illness in that DSP’s household) of the regular DSP. In this situation, the service will be paid for and the retainer payment can be requested.

If a RADSE is providing services can hours be increased as needed without authorization? Can retainer payments be made to the other staff?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) There will be some situations in which one of the applicable services is delivered by a relative living in the home of the adult member instead of by the regularly scheduled DSP. In this situation, the service will be paid for and the retainer payment can be requested.

Please explain bullet point ( j ) around retainer payments in Appendix K-2

(Answer posted March 30, 2020) We received additional information from NC Medicaid on Friday, March 27, 2020, and will be working on this process of retainer payments for habilitative services.

Will Retainer Payments be retroactive back to March 13, 2020 for employees who meet criteria?

**Answer Updated** On April 22, 2020, Partners published Provider Alert COVID-19 #19—Modifications to Retainer Payment Process with additional information about retainer payments.

(Answer part of April 15, 2020 I/DD Specific Provider Information Series) Yes, please see (https://providers.partnersbhm.org/covid-19-provider-forms/ and https://providers.partnersbhm.org/covid-19-18-appendix-k-retainer-payment-requests/) for further information on requesting retainer payments.

When the Retainer Payment request form is made available would we need to submit it twice for those employees who have been out of work since March 13, 2020 for reasons associated with COVID-19, since we can only submit in 30-day increments?  

**Answer Updated** On April 22, 2020, Partners published Provider Alert COVID-19 #19—Modifications to Retainer Payment Process that includes a link to the updated form and instructions for submission. The form is located at https://providers.partnersbhm.org/covid-19-provider-forms/.

(Answer part of April 15, 2020 I/DD Specific Provider Information Series) The form instructions indicate that a form should be submitted on Monday for prior week.  However, we understand that providers will need to submit several weeks on the initial submission.  We have created the form in such a way that you can include multiple members, multiple services and multiple service dates on same form.  It is important to understand that retainer payments can be paid for only 30 days and there must be at least a one-day gap before another 30-day period begins

Can a form be submitted for Retainer Payments for the same member but, more than one service i.e. Day Supports and Supported Employment?

(Answer part of April 15, 2020 I/DD Specific Provider Information Series) Yes

Where can the Retainer Payments request form be found?

**Answer Updated** On April 22, 2020, Partners published Provider Alert COVID-19 #19—Modifications to Retainer Payment Process that includes a link to the updated form and instructions for submission. The form is located at https://providers.partnersbhm.org/covid-19-provider-forms/.

(Answer part of April 15, 2020 I/DD Specific Provider Information Series)  https://providers.partnersbhm.org/covid-19-provider-forms/

Are the Retainer Payments for employees who do not currently have cases? I have a member’s family who does not want the DSP to come to the home until the COVID-19 pandemic has cleared. I have assigned this worker to another case to get some hours but not all. Is this staff eligible for retainer payments?

(Answer part of April 15, 2020 I/DD Specific Provider Information Series) The retainer payment is for employees who provide regularly scheduled services and are not currently working due to COVID-19.  In your example, the employee could receive retainer payment only for the hours not already covered. For Example: Employee was providing 20 hours/week of service to member 1 prior to the Stay-At-Home order and the member’s family has requested that no one come into their home during this time.  You have been able to reassign employee to member 2 but only for 15 hours/week.  Retainer payment can be requested for five hours.

Will the Retainer Payments be provided at the same rate of the typical service?

(Answer part of April 15, 2020 I/DD Specific Provider Information Series) Yes

If your agency has kept employees working by doing other jobs such i.e. cleaning, organizing, etc. would the agency still be able to request retainer payments?

(Answer part of April 15, 2020 I/DD Specific Provider Information Series) Yes, the agency can request retainer payment.

Is the expectation that the direct care worker submits the COVID19 grid for retainer payments does the QP submit on their behalf?

(Answer part of April 24, 2020 Provider Info Session) Provider agencies and EOR(s) are required to maintain documentation (as usual) via the required service Grid by entering COVID-19 on the Grid with QP signature/EOR signature and date. It would most likely be the QP/EOR who is completing the service grid with member information, service date, service name, service code, “COVID-19” and then signing.

With the flexibilities, how often does the QP need to sign off on the grid?

(Answer part of April 24, 2020 Provider Info Session) The DSP completed a daily service grid.  The intent is to substitute the grid that is usually done daily with the service grid now titled COVID 19 for the retainer payment.  It should be signed by the QP or employer of record.

Where in the rule/regulation is it stated that the QP must sign off on the note? If the QP writes the note on behalf of the staff, does that contradict the requirement for person providing the service to write the note?

(Answer part of April 24, 2020 Provider Info Session) NC Medicaid has not yet published their policy on Retainer Payments but much of the language we used in our communication comes directly from state level policy guidance.  Guidance received from Medicaid includes” provider agencies and EOQ(s) shall maintain documentation (as usual) via the required service grid by entering COVID-19 on the grid with QP signature/EOR signature and date.”  This QP/EOR signature is basically in lieu of the normal process sin which DSP would sign.

The actual form is confusing. The Innovations Staff Retainer form has nothing about the employee. Is it correct to just list the hours the person is NOT able to receive services due to the employee not being there?

(Answer part of April 24, 2020 Provider Info Session) On the form, you do not have to enter the employee’s name. You are required to have a Retainer Agreement with each employee, and you need to maintain this in your record. On the form, you are listing the service/service units which were authorized as of March 13, 2020 and for which the Direct Support Professional has been unable to deliver the service as he/she is regularly scheduled to do.

If we have requested a retainer payment and been paid for those hours and now the staff is saying she may not come back to work. How do we handle that?

Follow your pre-written agreement with the staff person. If you want us to walk through the situation with you, please email retainer@partnersbhm.org

Would retainer payment information suffice for notification of staffing lapses in lieu of incident reporting for back up staffing?

Retainer payments do not apply if the member is available to receive service but your staff member is not available. Retainer payments are applicable, now that there is no Stay-At-Home Order, only if the member is not available to receive service due to medical issues/risk.  If the member is available to receive service and the provider is unable to deliver the service, this is a back-up staffing incident and should be reported.

What if a family wants the DSP to start providing some of the hours again, but not all of them? A relative is providing some of the hours and the DSP is getting a retainer payment for those hours they are still not working?

It is important to investigate the rationale for the decision and assure it is COVID-19 related. If the member can safely receive service from the regular DSP, this is what should be occurring.  The flexibilities are to be implemented only as long as necessary, inclusive of hiring of relative to deliver the service.

If a direct care worker works with two individuals, and they continue to work with one individual, but they are not able to provide for the second individual, can we submit retainer payment for their hours for the second individual?

(Answer part of April 24, 2020 Provider Info Session) Yes, retainer payments can be submitted per member up to the normal regular hours that the DSP would have worked with the second individual.

If a DSP has agreed to receive the retainer payment instead of unemployment but then later decides they would rather receive unemployment, would the agency be on the hook for paying that money back to Partners or would it be solely the responsibility for the DSP?

(Answer part of April 24, 2020 Provider Info Session) The agency would have to pay it back. This is one reason the state is requiring the Retainer Agreement, to help avoid or minimize situations like this.

If the employee received a federal economic recovery check or state unemployment check due to COVID-19, should that employee also receive retainer payments? If no, then how do we account for the payments the employee may have received?

(Answer part of April 24, 2020 Provider Info Session) The state has clarified that employees can receive retainer payments, or they can receive unemployment benefits, but not both. This is why the state is requiring that you have a Retainer Agreement with the employee. Doing so will help ensure that employee understands that unemployment benefits cannot be received for the same service hours.

How are providers supposed to disperse funds we receive as retainer payments?

(Answer part of April 24, 2020 Provider Info Session) It is an expectation that you are paying your employees their normal hourly rate.

If the primary DSP received the retainer payment and the parent provides services during this period, is there not a “double billing’ issue for the same individual?

(Answer part of April 24, 2020 Provider Info Session) The modifiers were added to the service codes for retainer payments so that it will be clear that it is not submitting duplicate billing for the same service units. It is understood that there will be situations in which a service claim and a retainer claim is submitted for the same service hours.

If we ask today for claims before April 22, do we do a claim (retainer payment) and send the spreadsheet or just send the spreadsheet?

(Answer part of April 24, 2020 Provider Info Session) Both the claim and spreadsheet are required. The claim will trigger payment.

Is the retainer payment available for residential support (AFL) providers if needed?

(Answer part of April 24, 2020 Provider Info Session) Yes, if the member is not receiving Residential Support Services-AFL.

Will retainer payments be reimbursed at the normal rate of the Appendix K innovations services? 

(Answer part of April 24, 2020 Provider Info Session) Yes, we have not adjusted any of the rates to be lower than they are currently.

Will the retainer service code be added to every site listed in Alpha?

(Answer part of April 24, 2020 Provider Info Session) Yes.

If a staff member has possibly been exposed to COVID-19, and is quarantined until receiving an all-clear from the viral test, are they eligible for retainer payments?

[Please note that our response to this question during the August 5 provider information session was incorrect, and this is the correct information.]
Appendix K states, “The State confirms that retainer payments are for direct care providers who normally provide services that include habilitation and personal care but are currently unable to due to complications experienced during the COVID-19 pandemic because the waiver participant is sick due to COVID-19; or the waiver participant is sequestered and/or quarantined based on local, state, federal and/or medical requirements/orders.”

However, in the state’s Retainer Payment Policy it states “Providers and Beneficiaries may utilize retainer payments because of state of emergency requirements, staff sickness, staff unavailable due to caring for sick family member and/or member sickness, sickness in the beneficiary’s home or the need to limit staff from coming into member homes and creating health and safety concerns due to member’s increased risk of sickness.”

We contacted DHB staff to discuss this scenario and confirmed that the staff member is eligible for retainer payments because he/she is ill with or potentially exposed to COVID-19 and will return to work once cleared.

Can retainer payments be billed for one staff person (day supports provider) if the service is temporarily being provided by a different provider?

(Answer provided during the August 5, 2020 Provider Information Session.) If the service authorization (prior to 3/13/2020) is maintained with the initial provider, and the other agency-initiated service under no prior authorization/COVID-19 flexibility, then the retainer payment does apply. However, once the authorization is no longer active, the agency initially providing the services, on or before March 13, 2020, is no longer eligible for retainer payments.

Documentation of Services

When employees document services, do they need to indicate where the service was performed if not in the usual location?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) The service delivered must be documented.  Documentation of service provided in alternate location should include the location and note COVID-19.

If a service not currently in the ISP is delivered, should the service documentation include any special notation?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Any service documentation for which a flexibility is used should be marked COVID-19

What are the expectations for the following list of documents as they may need revising during this pandemic?

    1. Annual Assessments
    2. Individual Support Plans
    3. Preference Assessments
    4. Skills Assessments
    5. Updates to Behavioral Support Plans Goals

(Answer posted March 30, 2020) We will continue to develop annual plans to extent possible. SIS assessments are waived but other assessments should be completed, telephonically or using other technology such as Zoom.

How essential is documenting paperwork at this time? (For example: if the DSP is out of datasheets, what is essential for agencies that are not fully electronic?)      

(Answer posted March 30, 2020) Service documentation is required. Providers could drop off forms at DSP’s home or mail forms to DSP.

Signatures have been obtained usually by phone for plans and consents. When this crisis has subsided, will those signatures continue to suffice for the year or will they need to be updated with real signatures?

The signatures that you are gaining will suffice. However, it is best practice to get physical signatures to accompany the verbal approval, if able.  After the crisis has subsided, providers will need to go back to the regular process.

Will Care Management do plan updates later to reflect the Appendix K FL requested/used, so that our records will match?

(Answer provided during the August 5, 2020 Provider Information Session.) No, the intent is for the Appendix K reporting form to be an addendum to the member’s plan.

Increased Hours of Service Without Prior Authorization

With being able to provide increased hours, what do providers need to do when they run out of units? What do providers need to do if they receive denials because of a restriction in the authorization?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Prior authorization is not required at this time. This means that the claim will be paid even if there are not authorized units of the service remaining.

How will service hours be increased if no authorization is needed?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) If the member needs additional service hours due to COVID-19 related issues, the provider would deliver the increased number of service hours without obtaining prior authorization.  The provider must document the service and maintain justification for the increased number of service hours.

Is Specialized Consultative Services included in services that can be increased as needed without authorization?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Any service can be increased, as needed, without authorization at this time.

If an individual is currently approved for 15 hours per week of Community Networking services, can we increase the hours to 40 hours per week if the person has never been approved for this level of service? If so, can we have requests be retroactive to March 13, 2020?

(Answer posted March 31, 2020) The number of service hours can be increased based on COVID-19 needs without prior approval.

Can RADSE be done above the 56-hour waiver limit?

(Answer posted March 30, 2020) This flexibility was not initially requested in Appendix K. However, NC Medicaid has now confirmed with CMS that Innovations Waiver Beneficiaries who have RADSEs providing their services can temporarily go over the typical limits. RADSE staff can work with their relative the hours currently approved in the individual’s plan of care.

Providers do not have to obtain prior approval during this time to increase to RADSE’s hours. However, the provider must maintain documentation to justify why this short-term increase in hours was needed.

In Provider Alert #24 it addresses claims processing for services without authorization. Stating claims submitted after June 30, 2020 will deny. Does this apply to the services that have been provided outside the current authorization?  Ex: increased DS Individual hours.

If the service requires an authorization, one will need to be entered into Alpha for claims to process. More information regarding service requirements can be found in Provider Bulletin #106.

Are there parameters you can share on “medical necessity” for providers notifying the MCO of additional hours during COVID19?

(Answer from April 21, 2020 Info Session) Any increase in hours of service should be based on need and this should be documented, both the “why” behind the increase and how the service was increased. Increased service hours cannot be based on desire for DSP to have more hours or provider convenience; they must be based on member needs.

If a RADSE participant is receiving 30 hours of CLS in the home and also 30 hours of Day Supports now provided by the RADSE, can an additional 10 hours be added to CLS if needed?  Is it at the Provider’s discretion to determine if the additional 10 hours are needed? 

(Answer from April 21, 2020 Info Session) Right now, there is no prior authorization required, but you would need to assure the decision is based on need or medical necessity. If there is a justification or rationale to increase hours, you can increase the hours without prior approval at this time. If there is no justification or rationale to increase hours, the hours of service should not be increased.

School Week vs. Non-School Week

Will the weeks that schools use official vertical learning continue to be counted as non-school weeks?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) These will be considered non-school weeks.

Several care coordinators have said that providers can allow individuals to use summer hours/service units now and deviate from what is listed in the person’s ISP. As we all know, the school year is uncertain. What if the person continues to utilize the hours and services now, which would have been delivered over the summer and they run out of units before there is a decision made about returning to school? Will Partners approve more units to align with what is listed in the ISP for the individual’s summer hours? Will Partners submit an auth request and update the individual’s ISP?

(Answer posted March 31, 2020) School is not currently in session, so these are unanticipated “non-school weeks.” Individual Support Plans will be revised, and authorizations updated prior to the summer, as needed, to ensure adequate number of units to cover the expected non-school weeks.

What is the authorization and tracking process for billing during non-school time?

(Answer posted March 30, 2020) Between the dates of March 19, 2020 and April 30, 2020, the requirement for prior authorization has been lifted. Service Documentation, however, remains a requirement. Through documentation, providers will track their units to bill. We are currently finalizing a notification process and will provide more direction soon.

Has a decision been made by the state about school age children and services?

(Answer provided during the August 5, 2020 Provider Information Session.) NC DHHS staff have met with the Centers for Medicare & Medicaid Services (CMS) and are to meet with the Department of Public Instruction on this subject. State funded (b)(3) and Innovations services cannot be used for transportation to/from school and/or to support students with virtual learning. This and additional information will come out via a Joint Communication Bulletin soon.

Reporting

Does Appendix K Reporting Form need to be completed and emailed prior to providing the increase in service hours?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) It can be submitted prior to, on same day or shortly after.

When are exception forms due?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) They should be submitted as you implement flexibilities.  It is not required that Partners have the reporting form prior to your implementation of the flexibility.

The Temporary Disruption to Service form is only if we are having to stop services. Correct?

(Answer part of April 24, 2020 Provider Info Session) The intent of the form is to communicate some of the change providers had to rapidly put into place.

If we are changing the location of service delivery, do we complete the Temporary Disruption of Service form?

(Answer part of April 24, 2020 Provider Info Session) No, if the service is essentially the same and you are only moving to alternate location as allowed by Appendix K, then you do not have to complete the form.

There is an Appendix K Reporting Form. Is this a one-time form?

(Answer part of April 24, 2020 Provider Info Session) You may find yourself having to submit this form more than once. It will depend on if the services offered to the member changes. Each change will mean a new submission. This is supposed to be a fluid form that tracks flexibilities implemented per member.

Can we wait to submit the Appendix K motivation justification form, so we only have to complete once?

(Answer part of April 24, 2020 Provider Info Session) We really need to know in more real time what is occurring with the member. The state has said they will ask for interim reports and data.  The only way we can do that is if we have real time information.

Does incident reporting for backup staffing need to continue?

Back up Staffing reports are waived during the COVID-19 state of emergency.

Do providers need to still need to submit an Appendix K reporting form?

Yes, we are asking that providers need to continue to submit

Employers of Record

How will Employers of Record receive these new reporting forms?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) The Community Navigator who supports the Employer of Record and Partners will need to work together to ensure that the EORs receive needed support.  Partners will reach out the Acumen, the Financial Supports Agency, to educate them about the flexibilities and required reporting process. An EOR’s Community Navigator provider can assist the EOR with understanding the flexibilities, obtaining the reporting form and ensuring proper reporting is completed for any flexibilities the EOR implements.

Other

Can goals and yearly consents be acknowledged via phone call like signatures on plans?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Providers can obtain verbal consent and follow-up by obtaining signatures when possible, either via mail or face-to-face contact.

Members are having difficulty obtaining the required letter of medical necessity to submit Assistive Technology funding requests due to COVID-19, do you have any suggestions?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series)

Please contact the Regional Manager for Care Management to discuss this situation.

  • Cleveland, Gaston, Lincoln, Rutherford: Rachael Jerzak, rjerzak@partnersbhm.org
  • Burke, Catawba, Iredell, Surry, Yadkin: Wyatt Bell, wbell@partnersbhm.org

Are any rate adjustments for residential supports being considered?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Rate adjustments are not being considered at this time. However, residential providers are being given options for delivery of other services in the residential setting.

For members who were planning to move in mid-April, the HCBS and health and Safety reviews have not been completed and will not be until May, can we go ahead with the move in plans?

(Answer part of April 2, 2020 I/DD Specific Provider Information Series) Prior authorization is not required, and the members can move if all members of the team are in agreement.

Considering the COVID-19 pandemic, is Partners willing to waive getting a physician’s signature on the required Protective Devices Physician Approval and Consent Form for I/DD Innovations Waiver recipients at this time? We complete this form annually whether any new devices have been prescribed or not.

(Answer posted March 31, 2020) Efforts should be made to gain the signature. If this is not possible, then document the reason in the file.

If we run background checks during this crisis period and it comes back as a safety risk, do we have to stop services or continue to let them provide for the duration of the crisis period?

(Answer posted March 30, 2020) If a provider agency has knowledge of a known safety risk, this must be addressed.

What support and guidance will provider agencies be offered if a high school diploma or evidence of GED is not able to be obtained for emergency staffing situations?

(Answer posted March 30, 2020) A relative or guardian cannot be hired to deliver service to member if they do not meet qualifications, inclusive of having high school diploma or G.E.D. The flexibilities established in Appendix K do not waive qualifications.

If we have an enhanced rate approved will the end date be extended during this process?

(Answer posted March 30, 2020) Yes. During the COVID-19 Crisis period, we will use a report to extend Enhanced rates through April 30, 2020 or the end of the crisis period.

Can team meetings be delayed? And if they are delayed, will authorizations automatically be extended?

(Answer posted March 30, 2020) Team meetings for Innovations will be conducted, to extent possible, using Zoom or telephone. However, as necessary a member’s Innovations plan can be extended by up to three months and services in that plan continue. We do not anticipate having to use this flexibility.

Is there an expectation for us as an agency to go into homes where the members of the home do not believe to themselves to be sick?

(Answer posted March 30, 2020) It is important to follow CDC guidelines.

Can training that requires a RN trainer, such as medication administration training or training on a particular health skill technique (i.e., g-tube care, colonoscopy bag care, etc.) be offered via FaceTime or some other form of video conferencing platform? If not, will these trainings need to be suspended?

(Answer posted March 30, 2020) During the COVID 19 State of Emergency, Partners would accept video training during this time as acceptable. This flexibility would expire at the end of the State of Emergency.

What is the expectation for admission of new members and new services?

(Answer posted March 30, 2020) Appendix K includes several flexibilities regarding the location of services and RADSE delivery of services. This may ultimately result in some provider agencies having new members or existing member receiving new service. We will have to handle these on case by case basis.

What is the expectation for provider agencies when DSPs haven’t completed all required trainings?

(Answer posted March 30, 2020) There are two items included in Appendix K which appear to relate to this question.

  • Allow relatives of adult waiver beneficiaries who reside in the home and out of the home to provide services prior to background check and training for 90 days. It is understood that the background check will be completed by the agency as soon as possible after the service begins and training will occur as soon as possible without leaving the beneficiary without necessary care.
  • Allow for existing staff to continue to provide service, for 90 days, when CPR and NCI recertification has lapsed.

A relative (living in the home or out of the home) of an adult Innovations member could be hired and provide services prior to background check and training for 90 days. However, non-relatives of adult members are not included in this flexibility.

If Appendix K is approved as is, will everything in Appendix K be honored as appropriate effective March 13, 2020?

(Answer posted March 30, 2020) The effective date will be March 13, 2020.

Will IT computer systems be reset to allow more hours so billing claims will not be denied?

(Answer posted March 30, 2020) Between the dates of March 19, 2020 and April 30, 2020, the requirement of prior authorization has been lifted. In addition, Appendix K requested flexibilities regarding temporary increase of services when additional support is needed during this crisis period. Exceeding the limits on sets of services, however, was not included. IT/Claims systems have been set to allow the flexibilities needed up to the limits on sets of services.

Regarding Innovations, can we provide monitoring by telephone/Skype?   

**Answer Updated** (March 30, 2020) Audio/visual can be used unless the member’s condition and circumstance require face to face.

(Answer posted March 25, 2020) CMS approval is pending. NC Medicaid anticipates receiving approval this week. Partners is working on guidance for providers and will post as soon as finalized.

Do you know when the second Appendix K will be released?

(Answer part of April 15, 2020 I/DD Specific Provider Information Series) It has not been submitted by the state to CMS for approval at this time.

The Division stated that State-funded services will now follow similar allowances as Appendix K, except for authorizations as that money is limited. Will Partners have guidelines regarding those allowances?

(Answer from April 21, 2020 Info Session) Yes, we can put some guidelines together around that. It is contingent upon state funds. Will try to have a response for you by Friday on the Provider Council call.

Any suggestions to help with getting hand sanitizer?

Partners has had good experience with several resources. Chris Mabry, Kennedy Office, 704-786-4677. Bruce Short, Brame, 704-975-0625.

What if we don’t have all of the hand sanitizer, etc. that we need and are using homemade substitutes?

(Answer part of April 24, 2020 Provider Info Session) Contact your accreditation body and seek guidance. Document what you are doing.

What do we do about authorization if we have a new referral or transfer from other company?  

(Answer part of April 24, 2020 Provider Info Session) Authorizations are not required during this time period, under an unmanaged period for the state of emergency. A member/LRP may choose to change providers during this time and there is not an authorization required for the provider to bill for the new member.  The Care Manager will hold a treatment team meeting and develop an Update to ISP but will not submit it to UM until after the end of the Non-Managed period.

Can providers go ahead and begin the flexibilities with IPRS services, or do we need to wait on guidelines from Partners?

(Answer part of April 24, 2020 Provider Info Session) Flexibilities can be applied to state services to extent that no additional money is required.
Examples: CPR and first aid for existing employees can lapse for 90 days, ADVP can be provided in alternate location (home of member, home of direct support professional, residential setting) Providers can contact their account specialist with any questions.

Will DHHS and MCOs seek similar flexibilities as Innovations app k for B3 Services?

(Answer part of April 24, 2020 Provider Info Session) Yes, it is Partners’ understanding that the State is seeking those flexibilities and a bulletin should be forthcoming.

The DHHS bulletin from April 16, 2020 state expanded flexibilities for HCBS and said it covers telephonic contact with waiver beneficiary. I guess we are waiting for guidance from Partners?

(Answer part of April 24, 2020 Provider Info Session) The flexibility outlined in Appendix K is very specific to Care Coordinators. It does not address any other things about telephonic. There are discussions with the state regarding telephonic intervention with members or staff. We have received verbal confirmation that providers can provide supervision with staff or a RADSE over the telephone. Providing direct service care still stands as needing to be face-to-face, but today we received information from NC Medicaid that they are working on providing additional guidance regarding Innovations services being delivered via telehealth. It appears that they will be outlining under what circumstances telephonic support can be offered “if it is in the best interest of the individual and the member can benefit from telephone intervention.” If providers have situations in which they believe telehealth would be appropriate, we encourage them to staff the case with Rachael Jerzak or Wyatt Bell at Partners. We can seek additional guidance from NC Medicaid if necessary.

Are Service Stability requests a one-time thing? Where are the forms located and where do I submit them?

Yes, there is a link on our website. Visit https://providers.partnersbhm.org/partners-service-stability-program-special-cares-act-resources/. Those requests are more of a one-time request for specific costs or situations you may be incurring. We will probably have a limited time that this may be available.

What is the status of the 20-21 contract?

We are in the process of finalizing and intend to have these out within the next couple of weeks for the upcoming fiscal year.

Is there any guidance on allowing group home residents to go on family leave?

You may want to consider developing protocols for leaving and returning to assure due diligence for minimizing risk of having COVID-19 enter the facility.

When do the extra flexibilities start for the new Appendix K?

Effective date is retro-active to April 30, 2020.

Are there recommendations for having residents coming from a group home to a day program and back to the group home? The concern is more about when the residents can come out of congregate settings as opposed to day program operations. Is this expected in phase 2 or phase 3 of the reopening plan? The concern is more about when can the residents come out of congergrate settings as opposed to day program operations.

(Answered in May 14, 2020 I/DD Info Series) This is a great question and one shared by many in North Carolina. Our understanding is that NCDHHS is working on additional guidance specific to small congregate settings such as behavioral health and I/DD group homes. We will share any additional information we receive from NCDHHS.

Is the state coordinating with LME/MCO’s to get PPE out to residential programs, or do we work directly with the state? 

(Answered in May 14, 2020 I/DD Info Series) Information can be found and requests can be made through https://covid19.ncdhhs.gov/information/health-care/requesting-ppe. Requests will be filled as quantities are made available based on the prioritization schedule. If you have questions about how to put in a PPE request, email OEMSSupportCel@dhhs.nc.gov. As another resource, you can check with the emergency management departments in your local county.

Have Care Managers or Partners sent out information about Appendix K to families?

(Answered in May 14, 2020 I/DD Info Series) It was or intended that all individual and families receive this information. We are doing some follow-up with our Care Managers to ensure that this has occurred.

Could you list the online “state approved” Alternatives to Restrictive Interventions trainings?

(Answered in May 14, 2020 I/DD Info Series) A complete list of approved trainings are listed at https://files.nc.gov/ncdhhs/documents/files/APPROVED-CURRICULA-11-6-19.pdf. You will need to contact providers to determine if there is an online version.

I have seen no telehealth accommodations made for Day Activity which is the group service authorized for some of our participants. YM580 Day Supports can be provided via telehealth. What are your thoughts about moving individuals to this service that may benefit from telehealth?

(Answered in May 22, 2020 Provider Council) If YM580 Day Supports meets an individual’s service needs, that member could be moved into that service without prior authorization. As another option, Partners has been approved for Long Term Case Support. This service can be provided as an alternative to Day Activity.

Is it true that Long Term Community Supports will not start until July?

(Answered in May 22, 2020 Provider Council) An implementation date for Long-Term Community Supports Levels 1, 2 and 5 has not yet been determined. We have previously stated that it would be July 1 at the earliest. However, we have not yet received approval for implementation. LTCS Levels 3 and 4 have been implemented and will continue.

Are Care Managers being informed of all the new billing codes so that they understand what to look for? For example, three separate billings in one day may be appropriate due to flexibilities, retainer payments and regular billing.

(Answer provided during the August 5, 2020 Provider Information Session.) Care Managers are receiving training; however, they may not be as familiar with retainer payment codes yet.

Will deadlines for staff training be waived or extended? 

(Answer posted July 6, 2020): #JCB368 – Compliance with Alternatives and Restrictive Intervention -Re-Certification and Initial Certification-Training Requirements and CPR and First Aid Training Requirements During the COVID-19 Pandemic (PDF)

(Answer posted March 30, 2020) Partners will be extending deadlines for staff training by 30 days. 
(Source: Provider Alert COVID-19 #6 published on March 24, 2020)  

Will we still be held to Timely Follow Up expectations? 

(Answer posted March 25, 2020) Partners Hospital Account Specialists and Care Coordination is working directly with agency providers and hospitals individually to collaborate on responses to these questions. 

Manpower/Staffing: If we need to combine group homes due to staffing issues, will licensing be flexible? 

(Answer posted March 25, 2020) Please refer to the Division of Health Service Regulation (DHSR) website (https://info.ncdhhs.gov/dhsr/) for specific guidance related to licensure requirements and flexibility. Please email PNAS@partnersbhm.org if you need additional guidance.   

Monitoring Site Visits  

(posted April 15, 2020) The decision to suspend all routine monitoring, including virtual monitoring will be extended to May 31, 2020.  We will reassess as conditions are changing daily.  This includes unlicensed Alternative Family Living, post payment reviews and site visits for credentialing (initial and recredentialing).  Providers have the opportunity to virtually complete any reviews that the Partners Quality Management (QM) Monitoring department currently has in process.  If the provider cannot complete the review at this time, providers will be offered the opportunity to reschedule. (Source: Partners Provider Alert COVID-19 #17)

(Answer posted March 25, 2020) Partners has made the decision to suspend all routine monitoring, including virtual, for the next 30 days. We will reassess after 30 days as conditions are changing daily. The suspension includes unlicensed Alternative Family Living, post-payment reviews and site visits for credentialing (initial and re-credentialing). Partners will offer providers the opportunity to virtually complete any reviews that the Partners Quality Management (QM) Monitoring department currently has in process. If the provider cannot complete the review at this time, the provider will be offered the opportunity to reschedule. (Source: Provider Communication Bulletin #103)

Care Plan Signature Requirements: Will Partners be modifying the requirements for signatures?   

(Answer posted March 25, 2020) Partners recognizes the challenges providers are experiencing in obtaining signatures from members for clinical documents. At this time, in recognition of the realities of the current pandemic situation and based on guidance from the NC Department of Health and Human Services (NC DHHS) and the U.S. HHS Office for Civil Rights, Partners will accept a qualified professional/paraprofessional or clinician signature in place of the member or legally responsible person’s (LRP) signature, along with a notation that the member/LRP gave consent for the provider representative to sign the document on his or her behalf. These signatures can be electronic, within your Electronic Health Record systems.  

The provider should document whether such consent was made via telephone, email or other means (e.g., through a window). Any provider relying upon email consent should follow up via telephone call with the member/LRP to secure verbal consent if possible.   

To verify you are speaking with the member/LRP, the best practice is to ask for another identifier (besides name and date of birth), such as a Social Security number or Medicaid number. Always try to obtain express consent for disclosure of any substance use information. Member/LRP consent or approval should be clearly documented in the service note. (Source: Provider Communication Bulletin #103) 

How will Partners manage “bridge funding” to assist providers who are facing hardship and want to avoid closure/ending of services? For IPRS providers, have provisions made to contracts is we cannot maximize services?

(Answer posted March 30, 2020) Partners is committed to supporting the provider network in this midst of the State of Emergency related to COVID 19. Partners has received some flexibility from the state to consider specialized, stability funding for providers to ensure continuity of care for our members. If you anticipate financial obstacles to the continuity of care as a result of COVID-19, please submit the Service Stability Funding Request Form to PNAS@partnersbhm.org.

(Source:  Provider Alert COVID-19 #7 published on March 25, 2020)

Are In Lieu of Service Definitions being considered?

(Answer posted March 30, 2020) Partners is working with our fellow LME/MCOs and the North Carolina Department of Health and Human Services (NC DHHS) to develop and implement In Lieu of Service Definitions to address barriers to traditional treatment provisions during the COVID-19 pandemic. NC DHHS is fast-tracking its review of In Lieu of Service Definitions. The submission process is moving quickly, and we are collaborating with our peer LME/MCOs to streamline the definitions across the LME/MCOs. Until Partners has approved In Lieu of Service Definitions in place, we are implementing some changes for SAIOP, SACOT, PH and ACTT. Additionally, Community Support Team, Peer Support, Mobile Crisis Management and Psychosocial Rehabilitation (PSR) can be provided according to telehealth guidelines. Details are available in Provider Alert COVID-19 #9 issued on March 26, 2020.

If providers made hardship requests, how and when might those requests be discussed?

(Answer from April 21, 2020 Info Session) The provider sustainability forms are being processed. We have received a high volume of requests for various degrees of hardship. Many are in process. We’ve made some decisions aggregately as well as individual. Temporary rate increases have been offered for some services. If providers want information about your specific request, please reach out to your Provider Account Specialist for a status update.

Will Partners be supporting state funded day providers by converting dollars from UCR to non-UCR based on limited opening ability?

(Answer provided during the August 5, 2020 Provider Information Session.) This is being explored, but a decision has not been made by Partners.

Will prior authorization be required? 

**Answer Updated** (Answer updated Monday, April 20, 2020) Partners has extended this period through May 31, 2020.  Reference: Partners Provider Alert COVID-19 #17 https://providers.partnersbhm.org/info-session-authorizations-monitoring-sitevisits-ncdhhs-provider-update/

(Answer posted March 25, 2020) Effective March 19, 2020, Partners is lifting the requirement to obtain prior authorization for member services until April 30, 2020. Providers can continue to deliver and bill for services. (Source: Partners Communication Bulletin #103)

Authorizations: Will current authorizations for care be extended?

**Answer Updated** (Answer updated Monday, April 20, 2020) Partners has extended this period through May 31, 2020.  Reference: Partners Provider Alert COVID-19 #17 https://providers.partnersbhm.org/info-session-authorizations-monitoring-sitevisits-ncdhhs-provider-update/

(Answer posted March 25, 2020) Effective March 19, 2020, Partners is lifting the requirement to obtain prior authorization for member services until April 30, 2020. Providers can continue to deliver and bill for services.

  • The number of units that were approved in the most recent authorization will stay the same.
  • Medical Necessity will still apply.
  • Upon the first concurrent authorization after this period, all documentation must be submitted to Utilization Management according to the Service Definition and additional guidance from NC DHHS. (Source: Provider Communication Bulletin #103)

Do hospitals need to still call Utilization Management if authorization numbers aren’t going to be given?

(Answer posted March 25, 2020) For providers of acute services (Inpatient, Facility Based Crisis, Partial Hospitalizations) a Service Authorization Request (SAR) is not required for Dates of Service (DOS) with start dates of March 19, 2020, and end dates before April 30, 2020. SARs submitted with start dates of March 19, 2020, and end date before April 30, 2020, will be reviewed as Unable to Process (UTP) because no SAR is required. Medical Necessity criteria will still apply to services during this timeframe. SARs will be required when services extend beyond April 30, 2020. However, dates (in a Length of Stay) before the end date of April 30 will continue to be unmanaged.

Are In Lieu of Service Definitions being considered?

**Answer Updated** (Answer updated Monday, April 20, 2020) On April 16, 2020, NC DHB published Special Bulletin COVID-19 #46 Behavioral Health Flexibilities.  https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

This Bulletin addresses Mobile Crisis Management, Diagnostic Assessment, Intensive In-Home, Multisystemic Therapy, Community Support Team,  Assertive Community Treatment, Psychosocial Rehabilitation, Child and Adolescent Day Treatment, Partial Hospitalization, Substance Abuse Intensive Outpatient Program,  Substance Abuse Comprehensive Outpatient Treatment, Ambulatory Detox, Substance Abuse Non-Medical Community Residential Treatment, Substance Abuse, Medically Monitored Community Residential Treatment, Non Hospital Medical Detoxification, Outpatient Opioid Treatment, Peer Support Services, Residential Treatment Level III, Residential Treatment Level I and II – Family Type, Residential Treatment Services 8D-2 Level II – Program Type, Residential Treatment Services Level IV, Psychiatric Residential Treatment Facility for Children under the Age of 21, Therapeutic Leave for Psychiatric Residential Treatment Facilities for Children under the Age of 21 Residential Treatment Services Levels II – IV, Therapeutic Leave for Nursing Facilities and Intermediate Care for the Mentally Retarded, Professional Treatment Services in Facility-Based Crisis Program, Facility-Based Crisis Services for Children and Adolescents, Medically Supervised for ADATC Detoxification Crisis Stabilization, Research-Based Behavioral Health Treatment for Autism Spectrum Disorder and Outpatient Behavioral Health Service Provided by Direct-Enrolled Providers.

(Answer posted March 30, 2020) Partners is working with our fellow LME/MCOs and the North Carolina Department of Health and Human Services (NC DHHS) to develop and implement In Lieu of Service Definitions to address barriers to traditional treatment provisions during the COVID-19 pandemic. NC DHHS is fast-tracking its review of In Lieu of Service Definitions. The submission process is moving quickly, and we are collaborating with our peer LME/MCOs to streamline the definitions across the LME/MCOs. Until Partners has approved In Lieu of Service Definitions in place, we are implementing some changes for SAIOP, SACOT, PH and ACTT. Additionally, Community Support Team, Peer Support, Mobile Crisis Management and Psychosocial Rehabilitation (PSR) can be provided according to telehealth guidelines. Details are available in Provider Alert COVID-19 #9 issued on March 26, 2020.

Why is there flexibility for adults but not the same level of flexibility for children?

**Answer Updated** (Answer updated Monday, April 20, 2020):  On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities. This bulletin clarifies flexibilities allowed for children’s services. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Answer posted April 9, 2020) It is our understanding we have given flexibility for children under EPSDT.  Different waivers allow for various levels of flexibility.  Partners is exploring all levels of flexibility to support providers serving all populations at this time.

Can Peers have more than eight on a caseload?

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin clarifies flexibilities allowed for Peer Support Services. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Answer posted April 9, 2020) The current Peer Support Specialist Service Definition is being followed.  (https://files.nc.gov/ncdma/documents/files/public-comment/Public-Comment—8G-Peer-Support-Services.pdf)

Can non-certified peers conduct peer services?

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin clarifies Peers must be certified by the state of NC to provide Peer Support Services. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Answer posted April 9, 2020) The current Peer Support Specialist Service Definition is being followed. (https://files.nc.gov/ncdma/documents/files/public-comment/Public-Comment—8G-Peer-Support-Services.pdf)

Will Partners allow temporary changes to EPSDT?

(Answer posted March 30, 2020) Yes, Partners is offering immediate changes under EPSDT for children under the age of 21. Details are available in Provider Alert COVID-19 #6 published on March 24, 2020

What adjustments are being made to allow providers to continue to perform Intensive In-Home Services, Multi-Systemic Therapy (MST), Research Based Behavioral Health Treatment (RBBHT) or Family Centered Treatment (FCT) during this time? What is expected for after-hours crisis response?

(Answer posted March 30, 2020) Partners is implementing immediate changes under EPSDT immediately that address these services. Please see the detailed requirements for each service in Provider Alert COVID-19 #6 published on March 24, 2020.

Scope of Service Delivery: If we need to temporarily change the scope and/or method of service delivery, how do we inform Partners? What if we need to suspend services altogether? When will we receive acknowledgment that our decision is acceptable?

(Answer posted March 25, 2020) Please report all disruptions in service on the Provider Disruption Form.

Can we modify Open Access? 

(Answer posted March 25, 2020) Please report all disruptions in service on the Provider Disruption Form.

What about ABA Services? 

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin clarifies the use of RBBHT codes. Partners also allows the provider to bill the RBBHT codes under EPSDT. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Answer posted March 25, 2020) NC DHHS has not given guidance on stopping ABA services. Complete the Temporary Service Disruption Formhttps://providers.partnersbhm.org/provider-teleconference-temporary-service-disruption-communication-to-group

Manpower/Staffing: If we need to combine group homes due to staffing issues, will licensing be flexible? 

(Answer posted March 25, 2020) Please refer to the Division of Health Service Regulation (DHSR) website (https://info.ncdhhs.gov/dhsr/) for specific guidance related to licensure requirements and flexibility. Please email PNAS@partnersbhm.org if you need additional guidance.

Place of Service Delivery: Can services normally provided onsite (day treatment) or on school premises now be delivered elsewhere (in the home, by remote methods)? Can we have members come in and receive service onsite? Can services normally required to be face to face now be delivered differently? Can staff provide services as they do during summer break?

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin clarifies flexibilities allowed for place of service delivery. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities 

(Answer updated April 7, 2020)Special Medicaid Bulletin COVID-19 #35 replaces Special Bulletin COVID-19 #20 (https://medicaid.ncdhhs.gov/blog/2020/04/07/special-bulletin-covid-19-34-telehealth-clinical-policy-modifications-%E2%80%93-definitions)

NC Medicaid Telehealth Billing Code Summary Chart at https://medicaid.ncdhhs.gov/about-us/coronavirus-disease-2019-covid-19-and-nc-medicaid/covid-19-telehealth

(Updated response dated March 27, 2020) Special Medicaid Bulletin COVID-19 #20 gave instruction for enhanced services.

(Answer posted March 25, 2020) Telephonic codes are being added to contracts with existing outpatient and E/M codes with no action required from providers. The codes are effective on March 13, 2020. Providers will receive a contract amendment to sign in order to submit claims for these service codes. Partners is following guidance from NC DHHS related to telehealth: https://medicaid.ncdhhs.gov/blog/2020/03/20/special-bulletin-covid-19-9-telehealth-provisions-clinical-policy-modification

Complete the Temporary Service Disruption Form:

No specific guidance has been given to flexibility around enhanced services. To the extent possible providers are encouraged to use telephonic and telehealth codes. Telephonic codes are being added to contracts with existing outpatient and E/M codes with no action required from providers. The codes will be effective on March 13, 2020. Providers will receive a contract amendment to sign in order to submit claims for these service codes. Partners is following guidance from NC DHHS related to telehealth:

Can there be a consistent statewide approach to modifiers, coding and billing?  When will the grid with service codes, modifiers and service cross-references be made available?

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin clarifies procedure codes and modifiers. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities 

(Answer posted April 9, 2020)  NC Medicaid Telehealth Billing Code Summary Chart at https://medicaid.ncdhhs.gov/about-us/coronavirus-disease-2019-covid-19-and-nc-medicaid/covid-19-telehealth

Are providers being required to use measurement-based care during COVID-19?

(Answer from April 21, 2020 Info Session) If this is something you are trying to do with your processes, that is ideal. Folding it into your work and assessing how to continue to do this will best meet the needs of members. It is important that you deliver the best clinical services that you can to meet member needs in whatever format is working.

With these modifiers that are just being added being effective back to March 10?  Do we need to file replacements to add modifiers for all the claims without modifiers that we had already submitted (in order to keep getting paid)?

(Answer from April 21, 2020 Info Session) Provider will only need to submit a replacement claim if the new code was the service actually provided.

What modifier should be used for In Lieu Of service definitions?

(Answer from April 21, 2020 Info Session) The state recently clarified that we are to use an UR modifier.

Will there be another session to discuss the additional information around OP Enhanced services?  Specifically, for SAIOP, SACOT, and PH?  

(Answer from April 21, 2020 Info Session) It is Partners intention to offer maximum flexibilities.  We can set up a meeting specific for SAIOP, SACOT and PH.

It looks like Partners Training Academy classes will be in person in May in the Gastonia and Hickory building.  What precautions will be taken?  

(Answer from April 21, 2020 Info Session) Classes will remain on the calendar. We are making formal decisions one week in advance and are striving to convert to a virtual format rather than cancel. Registrants will receive email communication about the decision for each class.

Please note: Innovations has a specific section for questions and answers.

Can psychological testing be done via telehealth?

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin clarifies flexibilities allowed for Diagnostic Assessment. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Answer posted April 9, 2020) There is guidance on the American Psychological Association website regarding Psychological tele-assessment during the COVID-19 crisis.  There are many different types of Assessment, many of which may not be appropriate for telehealth with the current materials.  This article gives appropriate guidance to use with physical distance and isolation circumstances.

https://www.apaservices.org/practice/reimbursement/health-codes/testing/tele-assessment-covid-19

Have there been updates for Day Treatment and telehealth?

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin clarifies flexibilities for Day Treatment Services. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Answer posted April 9, 2020) DHB is reviewing our Day Treatment In Lieu of service definition and has sent us several questions and edits.  We are collaborating with DHB to resubmit for approval.  If you, as a Day Treatment provider, have specific questions or needs, please reach out to PNAS@partnersbhm.org. 

Did DHHS publish clarification regarding telehealth for Enhanced Services? 

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin clarifies flexibilities for Enhanced Services and telehealth. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Answer updated April 7, 2020)  Special Medicaid Bulletin COVID-19 #35 replaces Special Bulletin COVID-19 #20  (https://medicaid.ncdhhs.gov/blog/2020/04/07/special-bulletin-covid-19-35-telehealth-clinical-policy-modifications-%E2%80%93-enhanced)

(Answer posted March 31, 2020) On Friday, March 27, Special Medicaid Bulletin COViD-19 #20 was published with clarification for the delivery of Intensive In-Home Service, Multisystemic Therapy, Mobile Crisis Management, Assertive Community Treatment (ACT), Community Support Team (CST) and Peer Support Services (PSS). This is effective March 30 but will be retroactive to March 10, 2020. Once the declared State of Emergency has ended, all face to face elements of the service shall again be required to be performed in person. For details and requirements/expectations of service delivery and billing, see the bulletin.

Can associate-level providers provide telehealth?

**Answer Updated** (Answer updated Monday, April 20, 2020).  On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin clarifies flexibilities for providers and telehealth. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Answer updated April 7, 2020) Special Medicaid Bulletin COVID-19 #34 replaces Special Bulletin COVID-19 #19.  (https://medicaid.ncdhhs.gov/blog/2020/04/07/special-bulletin-covid-19-34-telehealth-clinical-policy-modifications-%E2%80%93-definitions)

NC Medicaid Telehealth Billing Code Summary Chart at https://medicaid.ncdhhs.gov/about-us/coronavirus-disease-2019-covid-19-and-nc-medicaid/covid-19-telehealth

(original answer posted to FAQs on March 25, 2020, did not include associate level professionals)

(Answer posted March 31, 2020) On Friday, March 27 DHHS published Special Bulletin COVID-19 #19 clarifying that telehealth providers are being expanded to include LCSW-A, LCMHC-A, LMFT-A and LCAS-A. Attachment A of the Telemedicine and Telepsychiatry Clinical Coverage Policy was modified. Please see the bulletin for details regarding coding use of modifiers, billing units and place of service requirements.

What place of service codes should be used for telehealth?

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin reinforces the use of the provider’s usual place of service code and not using (02). https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Answer updated April 7, 2020) Telemedicine and telepsychiatry claims should be filed with the provider’s usual place of service code per the appropriate clinical coverage policy and not Place of Service (POS) 02 (telehealth).   Special Medicaid Bulletin COVID-19 #34, #35 replaces Special Bulletin COVID-19 #19, #20

(Answer posted March 31, 2020) Claims filed using GT modifiers indicate that a service has been provided via interaction audio-visual and should be filed with place of service 02.  Services filed as telehealth will be reimbursed at the same rate as if the service was performed in person (Source:  Special Bulletin COVID-19 #19 and #20)

Have we received clarification regarding using modifiers to bill?

**Answer Updated** (Answer updated April 24, 2020) Partners published Provider Alert COVID-19 #21 Behavioral Health Service Flexibilities.  This bulletin shows a grid for procedure code and modifiers that have been added to provider contracts for Medicaid, State funded, and In-Lieu of Medicaid codes.  On April 23, 2020 NC DHHS published Special Bulletin COVID-19 #59 Telehealth Clinical Policy Modifications – Outpatient Behavioral Health Services shared procedure codes and modifiers to be used for Outpatient Services.

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin clarifies modifiers for billing. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Answer updated April 7, 2020) A Telehealth Billing Code Summary Chart showing services, codes and modifiers has been published. 

(Answer posted March 31, 2020) Modifier GT must be appended to the CPT and HCPCS code to indicate that a service has been provided via interactive audio-visual communication. This modifier is not appropriate for services performed telephonically, through email or patient portal. Modifier CR (catastrophe/disaster-related) must be appended to all claims for CPT and HCPCS codes to relax frequency limitations defined in code definitions. (Source: Special Bulletin COVID-19 #20)

Can you clarify differences for requirements between telehealth and telephonic intervention? What changes did Partners make to expand the use of telephone and telehealth interventions?

**Answer Updated** (Answer updated Monday, April 20, 2020) Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin offers definitions for telehealth and telephonic intervention.   https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Updated response dated April 7, 2020) Special Medicaid Bulletin COVID-19 #34, #35 gives instruction for Telehealth and telephonic services.

(Answer posted March 30, 2020) Partners is allowing the following expansions to telehealth effective with March 10, 2020 dates of services. Please see the detailed information shared in Provider Alert COVID-19 #6 published on March 24, 2020.

Who can perform telehealth for treatment? 

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin offers guidance for provider type for some services. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Updated response dated April 7, 2020) Licensed psychologists and licensed psychological associates are permitted to bill using codes for psychiatric diagnostic evaluation and psychotherapy.  This was originally listed as “psychologists.”Special Medicaid Bulletin COVID-19 #34 replaces Special Bulletin COVID-19 #19 (https://medicaid.ncdhhs.gov/blog/2020/04/07/special-bulletin-covid-19-34-telehealth-clinical-policy-modifications-%E2%80%93-definitions)

(Updated response dated March 27, 2020) Special Medicaid Bulletin COVID-19 #19: https://medicaid.ncdhhs.gov/blog/2020/03/27/special-bulletin-covid-19-19-update-telehealth-provisions-clinical-policy

(Answer posted March 25, 2020) NC Medicaid has expanded the list of eligible distant site telemedicine and telepsychiatry providers to include clinical pharmacists, licensed clinical social workers (LCSW), licensed clinical mental health counselors (LCMHC), licensed marriage and family therapists (LMFT), licensed clinical addiction specialists (LCAS) and licensed psychological associates (LPA). (Source: March 20 Special Bulletin COVID-19 #9)

Who can perform telephone check-ins with members? 

**Answer Updated** (Answer updated April 7, 2020) Licensed psychologists and licensed psychological associates are permitted to bill using codes for psychiatric diagnostic evaluation and psychotherapy.  This was originally listed as “psychologists.” Special Medicaid Bulletin COVID-19 #34 replaces Special Bulletin COVID-19 #19  (https://medicaid.ncdhhs.gov/blog/2020/04/07/special-bulletin-covid-19-34-telehealth-clinical-policy-modifications-%E2%80%93-definitions)

(Answer posted March 25, 2020) Behavioral health telephonic assessment and management can be conducted by a licensed non-physician behavioral health professional (licensed clinical social worker (LCSW) or licensed clinical social worker associate (LCSW-A); licensed professional counselor (LPC); licensed professional counselor associate (LPC-A); licensed marriage and family therapist (LMFT); licensed marriage and family therapist associate (LMFT-A); licensed clinical addiction specialist (LCAS); licensed clinical addiction specialist associate (LCAS-A); psychologist and licensed psychological associate (LPA). (Source: March 20 Special Bulletin COVID-19 #9)

What are the methods that are acceptable to use and not use? (call only/Skype/Facetime, etc.) 

(Answer posted March 25, 2020) NC Medicaid has eliminated the restriction that telemedicine and telepsychiatry services cannot be conducted via “video cell phone interactions.” These services can now be delivered via any HIPAA-compliant, secure technology with audio and video capabilities, including (but not limited to) smartphones, tablets and computers. (Source: March 20 Special Bulletin COVID-19 #9)

Additionally, the Office of Civil Rights (OCR) at Health and Human Services (HHS) recently issued guidance noting that “covered health care providers may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype, to provide telehealth without risk that OCR might seek to impose a penalty for noncompliance with the HIPAA Rules related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency.”

Reminder: The telephonic codes effective March 13, 2020, are not the only codes that providers are limited to using to treat members. Providers may accept new clients into services. They may continue to bill regular outpatient treatment services and use tele-modalities as the NCDHHS waiver was approved – the specific details are being worked out for the billing aspects.

What if I need to use staff members other than those listed on the Medicaid Bulletin for telephonic check-in with members? Will Partners allow a modified claim number to be used? (example: BCBA, PSS)  

**Answer Updated** (Answer updated April 7, 2020) Special Medicaid Bulletin COVID-19 #35 replaces Special Medicaid Bulletin COVID-19#20. (https://medicaid.ncdhhs.gov/blog/2020/04/07/special-bulletin-covid-19-35-telehealth-clinical-policy-modifications-%E2%80%93-enhanced) 

(Updated response dated March 27, 2020) Special Medicaid Bulletin COVID-19 #20, gave instruction for enhanced services.

(Answer posted March 25, 2020) NC Medicaid has expanded the list of eligible distant site telemedicine and telepsychiatry providers to include clinical pharmacists, licensed clinical social workers (LCSWs), licensed clinical mental health counselors (LMHCs), licensed marriage and family therapists (LMFTs), licensed clinical addiction specialists (LCASs) and licensed psychological associates (LPAs).

No specific guidance has been given to flexibility around enhanced services. To the extent possible, providers are encouraged to use telephonic and telehealth codes. Telephonic codes are being added to contracts with existing outpatient and E/M codes with no action required from providers. The codes were effective on March 13, 2020. Providers will receive a contract amendment to sign in order to submit claims for these service codes. Partners is following guidance from NC DHHS related to telehealth: https://medicaid.ncdhhs.gov/blog/2020/03/20/special-bulletin-covid-19-9-telehealth-provisions-clinical-policy-modification and https://providers.partnersbhm.org/provider-bulletin-103/#Codes

Can Enhanced Services use telephonic check-in or Skype? 

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin describes flexibilities for Enhanced Services including codes and modifiers. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Updated response dated April 7, 2020) Special Medicaid Bulletin COVID-19 #35 replaces Special Medicaid Bulletin COVID-19#20. (https://medicaid.ncdhhs.gov/blog/2020/04/07/special-bulletin-covid-19-35-telehealth-clinical-policy-modifications-%E2%80%93-enhanced)

(Updated response dated March 27, 2020) Special Medicaid Bulletin COVID-19 #20, gave instruction for enhanced services.

(Answer posted March 25, 2020) No specific guidance has been given to flexibility around enhanced services. Providers are encouraged to use telephonic and telehealth codes to the extent possible. Telephonic codes are being added to contracts with existing outpatient and E&M codes with no action required from providers. The codes were effective on March 13, 2020. Providers will receive a contract amendment to sign in order to submit claims for these service codes. Partners is following guidance from NC DHHS related to telehealth.

What are the actual codes? What are the timeframes for each? 

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities. This bulletin clarifies procedure codes and modifier guidance.  https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Answer updated April 7, 2020)   A Telehealth Billing Code Summary Chart showing services, codes and modifiers has been published.  Special Medicaid Bulletin COVID-19 #34 &#35 replaces the following:

(Updated response dated March 31, 2020) specific associate-level providers can now bill per Special Medicaid Bulletin COVID-19 #19: https://medicaid.ncdhhs.gov/blog/2020/03/27/special-bulletin-covid-19-19-update-telehealth-provisions-clinical-policy

(Answer posted March 25, 2020)

Telephonic codes (audio only):

  • 99441CR: Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management (E/M) services provided to an established patient, parent or guardian not originating from a related E/M service provided within the previous seven days or leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
  • 99442CR: Telephone evaluation and management service by a physician or other qualified health care professional who may report E/M services provided to an established patient, parent or guardian not originating from a related E/M service provided within the previous seven days or leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion.
  • 99443CR: Telephone evaluation and management service by a physician or other qualified health care professional who may report E/M services provided to an established patient, parent or guardian not originating from a related E/M service provided within the previous seven days or leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 21-30 minutes of medical discussion.

Codes to be used when reporting behavioral health telephonic assessment and management by a licensed non-physician behavioral health professional (licensed clinical social worker (LCSW), licensed clinical social worker associate (LCSW-A); licensed professional counselor (LPC); licensed professional counselor associate (LPC-A); licensed marriage and family therapist (LMFT); licensed marriage and family therapist associate (LMFT-A); licensed clinical addiction specialist (LCAS); licensed clinical addiction specialist associate (LCAS-A); psychologist and licensed psychological associate (LPA):

  • 98966CR: Telephone assessment and management service provided by a qualified non-physician health care professional to an established patient, parent or guardian not originating from a related assessment and management service provided within the previous seven days not leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
  • 98967CR: Telephone assessment and management service provided by a qualified non-physician health care professional to an established patient, parent or guardian not originating from a related assessment and management service provided within the previous seven days not leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion.
  • 98968CR: Telephone assessment and management service provided by a qualified non-physician health care professional to an established patient, parent or guardian not originating from a related assessment and management service provided within the previous seven days not leading to an assessment and management service or procedure with the next 24 hours or soonest available appointment; 21-30 minutes of medical discussion.

ICD-10 Diagnosis Codes  

ICD-10 diagnosis codes to report Coronavirus Virtual Patient Communication and Telephonic Evaluation and Management codes include:

  • If the visit is for COVID-19 symptoms, contact with and (suspected) exposure to other viral communicable disease: Z20.828

It is important to note that the CR codes can be used to bill individual therapy sessions for members authorized for other services if those delivering the service meet the criteria. For example, licensed clinicians that serve on an intensive in-home team, may use these codes and the CR modifier to provide this service to those members but not on the same day when billing another service.

The interpretation for the term “established client” for use of the CR codes is for those members who have had an intake and assessment completed. (Source: Partners Communication Bulletin #103)

What is the reimbursement for each code? 

(Answer posted March 25, 2020)

Code

DMH Rate

99441CR $13.83
99442CR $26.93
99443CR $39.48
9866CR $11.89
98967CR $22.16
98968CR $33.95

(Source: Partners Communication Bulletin #103)

Will prior authorization be required? 

**Answer Updated** (Answer updated Monday, April 20, 2020) Partners has now extended this period through May 31, 2020.  Reference: Partners Provider Alert COVID-19 #17 https://providers.partnersbhm.org/info-session-authorizations-monitoring-sitevisits-ncdhhs-provider-update/

(Answer posted March 25, 2020) Effective March 19, 2020, Partners is lifting the requirement to obtain prior authorization for member services until April 30, 2020. Providers can continue to deliver and bill for services. (Source: Partners Communication Bulletin #103)

Can these codes be used in place of current requirements for face to face care?

**Answer Updated** (Answer updated Monday, April 20, 2020) On Thursday, April 16, 2020, NC DHB published Special Bulletin COVID-19 # 46 Behavioral Health Service Flexibilities.  This bulletin clarifies flexibilities regarding the waiver of authorizations for specific services. https://medicaid.ncdhhs.gov/blog/2020/04/16/special-bulletin-covid-19-46-behavioral-health-service-flexibilities

(Answer posted March 25, 2020) We will get direction from NC Medicaid regarding Innovations Waiver participants soon as they are working with CMS to approve some flexibilities within the waiver to mitigate risks. Partners anticipates more guidance in the next few days on those flexibilities.

Can these codes be used for testing purposes or initial Comprehensive Clinical Assessments? 

(Answer posted March 25, 2020) The following psychiatric diagnostic evaluation codes can be used for testing and CCAs: 90791 and 90792. (Source: March 20 Special Bulletin COVID-19 #9)

Is there a timeframe to receive contract updates allowing us to bill the need codes? 

(Answer posted March 25, 2020) Telephonic codes are being added to contracts with existing outpatient and E/M codes with no action required from providers. The codes were effective March 13, 2020. Providers will receive a contract amendment to sign in order to submit claims for these service codes. Partners is following guidance from NC DHHS related to telehealth: https://medicaid.ncdhhs.gov/blog/2020/03/20/special-bulletin-covid-19-9-telehealth-provisions-clinical-policy-modification and https://providers.partnersbhm.org/provider-bulletin-103/#Codes.

Are we limited to one call every seven days? 

**Answer Updated** (Answer updated April 7, 2020) Special Medicaid Bulletin COVID-19 #34 replaces Special Bulletin COVID-19 #19  (https://medicaid.ncdhhs.gov/blog/2020/04/07/special-bulletin-covid-19-34-telehealth-clinical-policy-modifications-%E2%80%93-definitions)

(Answer posted March 25, 2020) Refer to guidance from the State regarding telephone codes and restrictions on those codes: https://medicaid.ncdhhs.gov/blog/2020/03/13/special-bulletin-covid-19-2-general-guidance-and-policy-modifications

Are there any plans to expand the opportunity to conduct any of the Innovations or IPRS IDD services to a telehealth modality?   

(Answer from April 21, 2020 Info Session) Some guidance has been given.  Some of the questions received have been sent to the state for clarification. Another call is being set up specifically for IDD providers. We are trying to meet the needs of many provider types.

If a client is unable to connect through a visual device, are we allowed to provide a telephone session?  Such as 90832 with a CR modifier?

(Answer from April 21, 2020 Info Session) 90832 is a code that can be used with a CR modifier.

With these modifiers that are just being added being effective back to March 10, 2020? Do we need to file replacements to add modifiers for all the claims without modifiers that we had already submitted?

(Answer from April 21, 2020 Info Session) Provider will only need to submit a replacement claim if the new code was the service provided.

What modifier should be used for In Lieu Of service definitions?   

(Answer from April 21, 2020 Info Session) The state recently clarified that we are to use a UR modifier.

Do we have a date that Alpha will be updated with all the new modifiers?

(Answer from April 21, 2020 Info Session) We are working to update with the new codes from the Bulletin posted on April 16. We will send out a provider alert when it is complete.

Does the CPT code for telehealth need to have the modifier GT if video AND place of service is office?

(Answer from April 21, 2020 Info Session) Yes, guidance from communication bulletins indicates you would use normal place of service. Do not use (02).

We are still having outpatient Telehealth codes 90847 & 90846 denied or kicked out. Is there a problem or something else to do with these codes specifically? (Codes 90837 and 90834 are not being denied)

(Answer from April 21, 2020 Info Session) If it is the code GT and CR, then they previously denied due to the rates not being set up. These were readjudicated. Only a few still denied. Some have denied that just have GT modifiers. When we checked these, then it was found that GT was not in the provider contract. If a provider is having denials different than one of these reasons, the provider can send an email directly to the Claims Department and Partners will check the individual provider contract.

If claims have already been sent with place of service 02, what can we expect? Will these be denied?

(Answer from April 21, 2020 Info Session) No, they do not need to be resubmitted. They will only deny if place of service 02 is invalid for the service on claim.

Will previously denied GT codes be readjudicated by Partners or will the provider need to rebill?

(Answer from April 21, 2020 Info Session) Providers will need to submit replacement claims for the denials. This allows us to readjudicate claims.

What is the different between GT and GTCR?

(Answer from April 21, 2020 Info Session) The GT modifier indicates that you are using a full telehealth intervention inclusive of audio and visual. The GTCR means that you are using full telehealth AND it is due to any of the flexibilities/waivers allowed during COVID19.  This is for providers who did not previously use telehealth and now you are. It is important to check out website to be sure what codes the state of NC has allowed.