April 22, 2020

COVID-19 Program and Billing Updates for Adult BH HCBS & Recovery CoordinationProgram Expectations, Documentation Changes & Minimum Billing Standards during the Disaster Emergency

OMH Division of Adult Community CareOASAS Bureau of Practice Innovation and Care Management

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THANK YOU and all your staff members for all the work you do and continue to do for the folks in our communities!

First & foremost…

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• New York State is a crisis zone in the global COVID-19 pandemic• Community-based behavioral health providers offer a critical safety net

to New Yorkers during this time• OMH and OASAS have worked closely with the Department of Health

and the Governor’s office to secure waivers that will allow providers to deliver services in new and flexible ways, including through the expansion of telehealth.

• Program & Billing Guidance became effective 3/7/20; when the state declared a disaster emergency.

Background

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Vision• The State’s intent is to maintain quality services and continuity of care

for participants, as well as to support agencies in maintaining recommended staffing levels

• HCBS providers should strive to offer a level of service, care, and support consistent with how services have been provided historically

• The intensity and frequency of service delivery should be appropriate to each individual’s needs

• Providers should continue to support each individual’s unique recovery goals during this crisis

• Delivery of Essential services must continue

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The guidance applies to designated providers of:• Community Psychiatric Support & Treatment, • Psychosocial Rehabilitation, • Habilitation, • Empowerment Services – Peer Support, • Family Support and Training, • Education Support Services, • Pre-vocational Services,

• Transitional Employment, • Intensive Supported Employment, • Ongoing Supported Employment• NYS Eligibility Assessment (RCA), • Plan of Care Development – Initial (RCA), and • Plan of Care Development – Ongoing (RCA.

Applicability

It does not apply to Short-Term Crisis Respite or Intensive Crisis Respite.

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• Essential services are a set of core services that must be provided throughout the Disaster Emergency, based on individual need and practitioner scope of practice

• Delivery of essential services does not require an update or revision to an individual’s Plan of Care or Individual Service Plan

• Essential services should be person-centered, flexible, and intended to support individuals’ basic needs at this time

Essential Service Delivery

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1. Medication2. Individual counseling/ therapy3. Crisis de-escalation and crisis intervention4. Substance use services5. Dissemination of COVID-19 related information6. Support of emotional and physical needs

Essential Services

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• BH HCBS providers will attempt to outreach each member at least once per week.

• The primary purpose of the outreach will be to engage the member, assess needs and provide support.

• If an individual receives multiple BH HCBS through the same designated provider, the agency may choose to provide only some or all authorized services.

• All active BH HCBS providers must continue to accept referrals and conduct intake/evaluation sessions, unless they are at capacity. Service specific intakes may be completed via telehealth. Providers that are at capacity for a specific service or county will notify their contracted MCOs immediately so that interested HARP members may be referred elsewhere.

• Practitioners providing services via telehealth will continue to receive appropriate supervision, per the Provider Manual.

Expectations of BH HCBS Providers:

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• Recovery Coordinators will continue to educate HARP members around the benefits of Health Home Care Management (particularly as it relates to coordinating benefits eligibility and access to basic needs during the disaster emergency) and will make appropriate referrals to Health Home whenever the client expresses an interest.

• The NYS Eligibility Assessment (EA) and Plan of Care Development may be completed via telehealth, including by telephone.

• Whenever practicable, Recovery Coordinators should conduct monthly outreach to all members on their caseload to assess access to services and determine whether additional referrals/linkage to BH HCBS or Health Home Care Management are necessary at this time.

Expectations of RCAs:

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For the duration of the declared disaster emergency, or until such time as supplemental guidance is issued:• Essential services may be provided within the scope of each BH HCBS without

a revision or update to the recipient’s BH HCBS Plan of Care or Individual Service Plan.

• Signatures will not be required at this time, but agreement obtained from the client and others involved shall be documented in the client’s record. (Such documentation may appear in a progress note, on the signature line of the document, or elsewhere in the chart.)

• The member’s informed consent for the NYS EA may be given verbally and must be documented in the record.

• BH HCBS and Recovery Coordination providers will document all outreach, even if the attempt is unsuccessful.

Changes in Documentation Requirements

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• The new guidance establishes program expectations and a reduction or elimination of minimum billing requirements for specific HARP rate codes.

• Requirements will remain in effect during the Disaster Emergency (or until such time as supplemental guidance is issued).

• This new flexibility in service delivery and billing are not intended to establish lesser standards for provision of services and support.

Program Expectations & Billing Requirements

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For the duration of the disaster emergency (effective 03/07/20), NYS is reducing the minimum

requirements to submit claims to HARPs for Adult BH HCBS.

• During the COVID-19 Disaster Emergency, for 15 minute billable units of BH

HCBS, the first billable unit qualifies with a minimum contact of five minutes and

then billable units accrue in 15 minute increments:

– 0-4 minutes = non-billable

– 5-19 minutes = 1 unit

– 20-34 minutes = 2 units

– 35-49 minutes = 3 units

Reduction of Minimum Billing Requirements

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BH HCBS with 5 minute initial contact:• Plan of Care Development – Ongoing (7781)

• Psychosocial Rehabilitation (7784-7787)

• Community Psychiatric Supportive Treatment (7790 – 7793)

• Peer Supports (7794)

• Residential Supports /Habilitation (7795)

• Family Support Training (7799)

• Transitional & Supported Employment (7802 - 7804)

Revised standard does NOT apply to assessments, groups, hourly rates, per diems or transportation services.

Billing Requirements (continued)

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• Education Support Services (rate code 7805 only) and Prevocational Services (rate code 7801 only):

• During the COVID-19 Disaster Emergency, for hourly billable units, the first billable unit for the above services is qualified with a minimum contact of 20 minutes and then billable units accrue in hourly increments:

– 0-19 minutes = non-billable– 20-79 minutes = 1 unit– 80-139+ minutes = 2 units

Billing Requirements (continued)

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During the declared COVID-19 disaster emergency,• If a service is still delivered in-person and existing minimum requirements are met, then

there is no need to use GT (telehealth) or CR (Catastrophe/Disaster related) modifiers• If a service is delivered via telehealth and existing minimum requirements are met, then

the GT (telehealth) modifier should be added to the claim• If a service is delivered via telehealth and existing minimum requirements are NOT met,

but the minimum requirement in the COVID-19 Flexibility Billing Guidelines are met, then the GT (telehealth) + CR (Catastrophe/Disaster related) modifiers should be added to the claim.

Please note: OMH will review claims submitted during the emergency period and may recoup any funding received that is found to be in excess of historical revenues or actual cost.

Billing Modifiers

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Questions Please submit any questions to: Transformation@omh.ny.gov

PICM@oasas.ny.gov

17April 22, 2020

CTAC Best Practices in Telehealth [Recorded Webinar]

OMH Guidance:OMH Guidance on COVID-19

OASAS Guidance:Telepractice FAQ’sTelepractice and Patient ConfidentialityTelepractice Informed ConsentTelepractice Standards for OASAS Designated Providers

Resources

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Thank you all for your continued support of clients and all New Yorkers during this public health crisis.