Billing FAQ

In general, services must be billed in accordance with applicable sections of DMAP Provider manuals. For interactive telehealth services, the same procedure codes and rates apply to the underlying covered service as if those services were delivered face- to-face.

In response to COVID-19, effective March 18, 2020, until further notice, telephonic services can be provided to any member for any visit not related to an evaluation and management (E&M) service provided within the previous 7 days nor leading to an E&M service or procedure within the next 24 hours or soonest available appointment. Billable telephonic Services must be between the patient and the physician or other qualified health professional.

Originating Site Providers

If the health care provider at the originating site is making a room and telecommunications equipment available the provider may bill for an Originating Facility Fee using code Q3014.

Non-Federally Qualified Health Care Center Distant Site/Rendering Providers

• Distant site/rendering providers billing for interactive telehealth services should continue to bill their appropriate usual and customary charge for the service provided and use an 02 modifier as place of service for all telehealth charges.

• Distant Site/Rendering Providers billing for Telephonic Services should use the following codes as appropriate, and should use an 02 Modifier as Place of Service for all Telehealth charges:

  • Physician or other qualified health professional:

    • 99441: 5-10 minutes of medical discussion

    • 99442: 11-20 minutes of medical discussion

    • 99443: 21-30 minutes of medical discussion

  • Qualified Non-Physician:

    • 98966: 5-10 minutes of medical discussion

    • 98967: 11-20 minutes of medical discussion

    • 98968: 21-30 minutes of medical discussion

Federally Qualified Health Care Center (FQHC) Distant Site/Rendering Providers

FQHC rendering providers billing for interactive telehealth services or telephonic services should continue to bill their appropriate HCPCS (Healthcare Common Procedure Coding System) “G” visit payment code for each payable encounter visit, along with the appropriate code for the service provided and use an 02 modifier as place of service for all telehealth charges. For telephonic services, the same codes listed above should be used as appropriate.

Providers billing for telephonic services should use two codes in this instance. For example, if a telepsychiatry call lasts for 45 minutes, the provider should be bill the appropriate 21- 30 minutes of medical discussion code (99443 or 98968) and the appropriate 11-20 minutes of medical discussion code (99442 or 98967).

In general, yes, although there are some exceptions. Many of the large insurers have announced expended telemedicine coverage. Providers are advised to exhaust all opportunities to work with insurers, given the current pandemic situation. If all other payment opportunities are unsuccessful, please contact DSAMH to discuss the situation.

Any programs that currently bill DSAMH or Medicaid are allowed to bill for telehealth. This includes all programs licensed or certified by DSAMH.

MEDICAID

Yes, with conditions. The Division of Medicaid and Medical Assistance (DMMA) DMMA has a longstanding Telehealth Policy that allows for all State Plan Services to be provided via Telehealth. In response to COVID-19, DMMA has expanded the methods that Telehealth may be delivered to include:

• Interactive Communication – Provider and patient interact in “real time” using an interactive telecommunications system that includes, at a minimum, audio and video equipment permitting two-way, real time interactive communication between the patient, at the originating site, and the physician or practitioner at the distant site; or

• Telephonic Services – In addition to Interactive Telehealth Services, telephones are an acceptable mode to deliver telehealth if the following conditions are met:

  • It is determined that Interactive Telehealth Services are unavailable, and

  • Telephonic Services are medically appropriate for the underlying covered service.

Chart reviews, electronic mail messages, facsimile transmissions or internet services for online medical evaluations are not coverable telehealth services.

DSAMH

Yes.

PRIVATE INSURERS

Please contact them directly with questions.

MEDICAID

In response to COVID-19, effective March 18, 2020, DMMA has expanded eligibility for providing Telehealth Services. For services delivered through telehealth technology from DMAP or MCOs to be covered, healthcare practitioners must:

• Act within their scope of practice;

• Be licensed for the service for which they bill DMAP;

  • Any out of state healthcare provider who would be permitted to provide telemedicine services in Delaware if they were licensed under Title 24 may provide telemedicine services to a Delaware resident if they hold an active license in another jurisdiction.

• Be enrolled with, or have engaged in the process to become enrolled with, DMAP/MCOs; and

• Be located within the continental United States.

Additionally, Title 24 requirements that patients present in person before telemedicine services may be provided are suspended.

DSAMH

DSAMH is covering all of its services and programs that are able to be provided via telehealth.

Private Insurers

Please contact them directly with questions.

No. Prior authorization for telehealth-delivered services is not required, but the Distant Site provider must obtain prior approval for any other covered services which would normally require prior authorization.

The Division of Medicaid and Medical Assistance (DMMA) is eliminating the current informed consent requirement and redefining patient consent as follows:

Consent is required to assure that the recipient is a willing participant in the telehealth delivered service and to assure that the recipient retains a voice in their treatment plan. The patient must be informed and given an opportunity to request an in-person assessment before receiving a telehealth assessment. Verbal consent is accepted, and written consent is no longer required. However, this consent must be documented in the patient’s record.

In response to COVID-19, effective March 18, 2020, until further notice provided by Governor John Carney, the Division of Medicaid and Medical Assistance relaxed eligibility requirements for providers providing telehealth services. DMAP or MCO clients to be covered, healthcare practitioners must:

• Act within their scope of practice;

• Be licensed for the service for which they bill DMAP;

  • Any out of state healthcare provider who holds an equivalent active license in another jurisdiction may provide telemedicine services to a Delaware resident.

• Be enrolled with, or have engaged in the process to become enrolled with, DMAP/MCOs; and

• Be located within the continental United States.

No. DMMA covers all medically necessary telehealth services and procedures under the Title XIX State Plan if medically appropriate. All telehealth services must be furnished within the limits of provider program policies and within the scope and practice outlined in the DMAP Provider Manuals.

Yes. In response to COVID-19, DMMA has expanded the methods that telehealth may be delivered to include telephonic services if it is determined that interactive telehealth services are unavailable, and telephonic services are medically appropriate for the underlying covered service.

Yes. DMMA is following guidance issued by the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR). OCR published a Notification of Enforcement Discretion (“Notification”) regarding HIPAA noncompliance in connection with the provision of telehealth services.

The notification states that OCR “will exercise its enforcement discretion and will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules against covered health care providers in connection with the good faith provision of telehealth” during the public health emergency. Additionally, telehealth services may be provided using “any non-public facing remote communication product that is available to communicate with patients.” This means that more widely used and available consumer services and products that would not typically meet the HIPAA privacy and security standards for telehealth can be used. Examples of such services and products include FaceTime and Skype. Under the Notification, 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.

So long as the patient is a Delaware resident any requirements that the patient be present in Delaware at the time the telemedicine service is provided are suspended.

No. As long as there are two distinct sites there are no restrictions.

No. In response to COVID-19, requirements that patients present in person before telemedicine services may be provided are suspended by executive order. It is imperative during this public health emergency that patients avoid travel, when possible, to physicians’ offices, clinics, hospitals, or other health care facilities where they could risk their own or others’ exposure to further illness.

Yes. For initiation of home health services, face-to-face encounters may occur using telehealth as described at 42 C.F.R. §440.70(f)(6). A physician, nurse practitioner or clinical nurse specialist, a certified nurse midwife, a physician assistant, or attending acute or post-acute physician for beneficiaries admitted to home health immediately after an acute or post-acute stay may perform the face-to-face encounter. The allowed non-physician practitioner must communicate the clinical findings of the face-to-face encounter to the ordering physician. Those clinical findings must be incorporated into the beneficiary’s written or electronic medical record. Additionally, the ordering physician must document that the face-to-face encounter occurred within the required timeframes prior to the start of home health services and indicate the practitioner who conducted the encounter and the date of the encounter.