This page contains resources related to Telehealth for Colorado CHCs. We have organized the information by telehealth topic to help you find what you need quickly. We will update our information as the situation changes and we learn more. If you have any suggestions for this page or specific questions please don’t hesitate to reach out to anyone at CCHN.
(Last Updated: March 19, 2:43 PM)
Primary Care Fund Visits
HCPF clarified on 3/26/20 that telehealth visits via “all allowable means” will be accepted for the FY 2021-22 Primary Care Fund application. This includes telephone, live chats, etc. CHCs are asked to document this service as they normally would do.
- From HCPF 3/18/2020: Both telephone and telemedicine visits are allowable under CICP. Read more about applications (need not be filled out in person) and more here.
- 4/13/20: HCPF posted FAQs related to CICP and telehealth during the COVID-19 crisis on their website. The FAQs answer application, co-pay, backdating/end dating, documentation, and income calculation questions. Visit the FAQs page here.
CCHN has seen no change to current guidance on counting telehealth visits. CHCs should continue to use the definition in the 2019 UDS manual:
- “Report documented virtual (telemedicine) contact between a patient and a licensed or credentialed provider who exercises their independent, professional judgment in the provision of services to the patient as a visit in Column B2. Report virtual visits that occurred during the reporting year rendered by salaried, contracted, or volunteer staff. Most visits reported in Column B2 will be provided by staff identified in Column A. Virtual visits purchased from contracted providers on a fee-for-service basis will also be reported.”
(Last Updated: April 7, 2020 2:41 PM)
ADA COVID-19 Coding and Billing Interim Guidance (updated March 24, 2020)
Provides coding guidelines for the use of telecommunication technology to triage patients and determine urgency/emergency of cases, and additional required codes to distinguish synchronous vs. asynchronous consultations. Also describes HIPAA considerations, appropriate platforms, and a practice considerations checklist.
Colorado Department of Health Care Policy and Financing (HCPF): Teledentistry Guidance
Statement from HCPF regarding expansion of telemedicine to include dental consultations. Includes basic teledentistry requirements and billing guidance.
Emergency Teledental Screening Tool (Denver Health): Scripting for triage of dental patients, including consent, clinical questions, and recommended documentation.
Teledentistry Visit Standard Work (Denver Health): A step-by-step guide for dentists to use during a teledentistry visit, including visit types based on established vs. non-established patients, scripting, consent, documentation, and emergency procedure guidance from the ADA and CDA.
Guidance Document for Patient Assessment via Synchronous Teledentistry: A guide to coaching patients through a teledentistry visit to obtain optimal images for assessment via video or photo. Created by Scott Howell, DMD, MPH, this link also includes one of his recorded webinars on the topic.
(Last Updated: April 29, 11:28 AM)
HIPAA Enforcement Discretion for Telehealth Remote Communication: On March 17 the Office for Civil Rights (OCR) announced a notification of enforcement discretion for telehealth remote communications during the COVID-19 nationwide public health emergency. OCR will waive potential penalties for HIPAA violations against health care providers that serve patients through everyday communications technologies during the COVID-19 nationwide public health emergency. A representative from OCR’s Denver Office Confirmed to CCHN that this would apply to all care provided right now. The full announcement is available here.
- This applies to a wide list of communication apps including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype.
- Providers are encouraged to notify patients that these third-party applications potentially introduce privacy risks, and providers should enable all available encryption and privacy modes when using such applications.
- Under this Notice, however, Facebook Live, Twitch, TikTok, and similar video communication applications are public facing, and should not be used in the provision of telehealth by covered health care providers.
This memorandum put together by FTLF answers some commonly asked questions related to HIPAA and telework.
Guidance from OCR on Telehealth Remote Communications: The Office for Civil Rights (OCR) issued guidance on telehealth remote communications following its Notification of Enforcement Discretion during the COVID-19 nationwide public health emergency. Notice of the guidance is available here and the FAQs are available here. Questions answered in the guidance include:
- What covered entities are included and excluded under the Notification?
- Which parts of the HIPAA Rules are included in the Notification?
- Does the Notification apply to violations of 42 CFR Part 2, the HHS regulation that protects the confidentiality of substance use disorder patient records?
- When does the Notification expire?
- Where can health care providers conduct telehealth?
- What is a “non-public facing” remote communication product?
(Last Updated: April 15, 3:48 PM)
UPDATE Telehealth Program Assistance Letter (PAL 2020-01): Within the context of the Health Center Program scope of project, “telehealth” is not a service or a service delivery method requiring specific HRSA approval; rather, telehealth is a mechanism or means for delivering a health service(s) to health center patients using telecommunications technology or equipment. As such, health centers are not required to seek prior approval from HRSA for a change in scope to use telehealth, nor separately record the use of telehealth as the means, to deliver a service that is already in scope on Form 5A: Services Provided or to explicitly indicate the use of telehealth on Form 5A.
- CHCs Should consider if the service you are delivering is within scope.
- The chart and footnote 11 in the PAL shows that a patient or provider can be at a site not listed on Form 5B.
- If the patient is at their home receiving telehealth services, CHC should confirm that “home visits” is listed on Form 5C: other activities. If not, CHCs may want to add a reference to telehealth.
- To help with FTCA coverage for providers working offsite the employee contract or job description should include some language to allow for flexibility (e.g. other duties as assigned, removal of language that says care is provide strictly at the CHC, etc.) and someone in an authoritative position (e.g. CMO) should outline the tasks for the employee in writing.
On April 15, 2020 HRSA released an updated version of the telehealth PAL. The bulk of the information remained the same, but some clarifying information was added, including:
- Adds that the PAL does not reflect temporary changes HRSA makes to established policy that occur in response to declared emergencies (Page 1).
- Adds two new examples to telehealth scenarios within the health center scope of project.
- Patient at in-scope service site, provider at another location (Page 5).
- Patient and provider at a location that is not an in-scope service site (Page 7).
(Last Updated: April 8, 3:00 PM)
During the COVID-19 state of emergency, Medicaid will reimburse CHCs for telehealth services for all normally billable providers at each CHC’s applicable encounter rate.
Read more about the temporary authorization here. This link includes the following:
- Specificity that providers can still only bill codes they are eligible to bill
- Consent to receive telemedicine services
- Maintenance of prior authorization rules
- HIPAA information, noting that the Office for Civil Rights has relaxed enforcement of some HIPAA standards, read more here.
- UB-04 billing guidance
Modalities to be reimbursed are:
- Interactive audiovisual visits
- Telephone visits
Telemedicine does not include: fax consultations, text, email or instant messaging. Costs associated with these modalities can be included in cost reporting.
In an effort to remove administrative and regulatory barriers to delivering remote services during the COVID-19 state of emergency, all RAEs are currently allowing outpatient treatment services listed in the Uniform Services Coding Standards Manual (USCSM) to be delivered via audiovisual, telephone, or live chat modalities, when it is clinically viable and appropriate. The Department and the RAEs have NOT changed USCSM requirements, prior authorization policies, or payment rules. Providers must follow each individual RAE’s billing policies.
Specific guidance and frequently asked questions are available from each RAE through the following websites:
- Rocky Mountain Health Plans (Region 1)
- Northeast Health Partners (Region 2)
- Health Colorado Inc (Region 4)
- Colorado Access (Region 3, 5, and Denver Health Medicaid Choice Behavioral Health)
- Colorado Community Health Alliance (CCHA) (Region 6 and 7)
The Department will continue to post updates on policies, codes and other information important to providers on their website as it becomes available. HCPF will continue to send out communications via bulletins and newsletters too and will post those on their COVID-19 Resource Center.
(Last Updated: April 1, 1:54 PM)
Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law on March 27, 2020. This bill authorizes Medicare reimbursement for health centers and rural health clinics as distant sites for the duration of the emergency, not reimbursed at PPS rate but instead “such payment methods shall be based on payment rates that are similar to the national average payment rates for comparable telehealth services under the physician fee schedule under section 1848.” On April 17, CMS issued guidance about how FQHCs can bill Medicare as a telehealth providers. See the guidance here.
Centers for Medicare and Medicaid Services has shared their list of approved telehealth codes, here.
On April 30, CMS announced an interim final rule with COVID related changes. Included in this important rule is allowance for FQHCs and RHCs to provide SOME audio only services to their Medicare patients for the duration of the Public Health Emergency. CCHN staff is working through exactly what this means and what is available to bill via audio and we will update this section soon! In addition, they provided additional information on the distant site provision for health centers, including more detail on billing and coding for these services. See the updated MLN Matters here.
(Last Updated: March 30, 1:30 PM)
CHPA provided an email update about how different payers are handling telehealth visits on March 27. See below for these updates.
- Anthem: Anthem has expanded services to include telehealth and telephonic visits, prescription coverage and some member cost-shares. Please visit this website for additional details and billing information.
- Bright Health: Bright Health has made updates to expand telehealth services, allow early medication refills and provide non-emergency transportation. Please visit this website for additional details and billing information.
- Cigna: Cigna has expanded and updated it’s medical billing guidelines for telehealth back to March 2nd, and can start billing on April 6th. Please see this Cigna COVID-19 Billing Update. Please visit this website for additional details and billing information.
- Cigna Has also updated it’s Behavioral Health telehealth guidance to allow for both telemedicine session and telephonic sessions. Please visit this website for additional details and billing information.
- Humana: Humana has expanded telehealth service scope and reimbursement rules. See three Humana Provider updates here. Please visit this website for additional details and billing information.
- Oscar Health: Oscar Health is waiving all early refill limits and encouraging members to stock up on 30 day supplies. However, since telehealth is a benefit in Colorado you should be able to bill and receive contract rates for services provided.
- United Health Care: United Healthcare has expanded services to include telehealth and telephonic visits, prescription coverage and some member cost-shares. Please visit this website for additional details and billing information.
(Last Updated: April 13, 2:18 PM)
Information on Telehealth Services for Healthcare Professionals from the Division of Professions and Occupations: This set of FAQs addresses lingering question licensed professionals may have about how to undertake telehealth during the COVID-19 crisis. Questions on the page include:
- Which DORA-regulated professions fall under Executive Order D 2020 020?
- What if telehealth is not sufficient to address the needs of my patients? Can I still conduct in-person appointments?
- What insurance considerations must I be aware of before offering telehealth services?
- Can I continue providing services to people who may now be residing outside of Colorado (i.e. college students who returned to out of state homes) without getting in trouble?
Colorado Division of Insurance FAQs on COVID-19 Telehealth Services: Questions answered include:
- What is telehealth? How has it changed based on the Governor’s Executive Order and DOI emergency regulation 20-E-05
- Which health plans are required to comply with the new telehealth benefit requirements?
- Which providers can be reimbursed for telehealth services?
- Can an insurer require the use of certain types of platforms to reimburse?
- Are there specific codes that health care providers should use to bill for telehealth services?
- What kinds of medications can be prescribed through telehealth?
(Last Updated: April 23, 12:00 PM)
CHC Telehealth Examples: CHC examples of policies, procedures, and workflows related to telehealth are available in the links below. For documents that are password protected please use the password for CCHN’s members-only website. CCHN is seeking sample telehealth/telephone visit workflows, policies, and procedures from Colorado CHCs. If you have a sample to share, please send it to email@example.com.
Telehealth Examples from Community Health Centers
Please note with the rapid developments for telehealth these documents may have been updated since the date they were shared with CCHN.
- Consent for Telehealth Services and Treatment (Clínica Tepeyac)
- Telehealth Etiquette Checklist (Clínica Tepeyac)
- Telehealth Information for Patients (Clínica Tepeyac)
- Telehealth Services Guideline (Clínica Tepeyac)
- Telehealth Starter Guide (Clínica Tepeyac)
- Telehealth Telephone Visit – Ambulatory (Denver Health)
- Telehealth Telephone Visit – Ambulatory Front Desk (Denver Health)
- Teledentistry Visit Standard Work (Denver Health)
- Emergency Teledental Screening Tool (Denver Health)
- Provider Phone Visit appointments Instructions (Frontier)
- Medical Telehealth Workflow (Northwest)
- Behavioral Telehealth Workflow (Northwest)
- Dental Telehealth Workflow (Northwest)
- Telehealth Policy and Procedure (RVFHC)
- Telecommuting Policy (Summit)
- Telecommuting Procedures (Summit)
- Telemedicine during COVID-19 State of Emergency (Summit)
- Telemed Consent (UMC)
Other Telehealth Examples and Resources:
- Workflow sample from American Academy of Pediatrics for provider to patient visit workflow
- Sample consent to participate in telemedicine in English and Spanish from California telehealth resource center (note: your CHC will have to modify this to fit the model of provider to patient visits).
- Telehealth Resource Center Etiquette Checklist offers tips for conducting telehealth visits.
- National Consortium of Telehealth Resource Centers provides information from Telehealth Resource Centers. Telehealth Resource Centers have been established to provide assistance, education, and information to organizations and individuals who are actively providing or interested in providing health care at a distance. The assistance is generally offered free of charge.
- Rural Telehealth Toolkit includes several resources for telehealth,including workflow mapping examples
- COVID-19 Telehealth Toolkit from the National Consortium of Telehealth Resource Centers. This toolkit provides guidance on how telehealth can be used for COVID-19, recent telehealth policies, and examples of how telehealth has been used in past pandemics.
- Toolkit from The Centers for Medicare & Medicaid Services (CMS): This comprehensive toolkit on telehealth that is specific to general Practitioners. The toolkit contains electronic links to reliable sources of information on telehealth and telemedicine, which will reduce the amount of time providers spend searching for answers and increase their time with patients. Many of these links will help providers learn about the general concept of telehealth, choose telemedicine vendors, initiate a telemedicine program, monitor patients remotely, and develop documentation tools. Additionally, the information contained within the toolkit will also outline temporary virtual services that could be used to treat patients during this specific period of time. You can find the Telehealth Toolkit for General Practitioners here.
- Webinar on how to develop and define telehealth strategies: On March 25 the Weitzman Istitute held an ECHO session focusing specifically on how to develop and define telehealth strategies during COVID-19. The presentation slides are available here and the recording can be found here.
- Telehealth and Telephone Visits in the Time of COVID-19: FQHC Workflows and Guides from the Center for Care Innovations includes specific telehealth workflows for NextGen and eClinicalWorks, as well as other useful information directed to Community Health Centers.
- Tips and Tricks on telehealth for school-based health care from the Colorado Association for School-Based Health Care.
- Telehealth Implementation Quick Guide from NACHC
- Getting a New Workflow and Process Started During the COVID-19 Pandemic: This tool from HITEQ is a guide for starting new workflows. In it you will find:
- Quick Start Guidance
- Come Up with a Triage Plan
- Technology and Tools that can Support your Triage Plan
- Communicate with Everyone About your Plan
- Establishing your Workforce for Telehealth
- Reimbursement Policy and Coding for Telehealth