COVID-19 Frequently Asked Questions for Treatment Providers

Are we required to stay open and provide services?

It is the expectation that the people we serve through the ODMHSAS system still receive services and supports from our provider network. Service delivery may look very different than before COVID-19 by increasing the use of technology and incorporating CDC recommended safety protocols such as screening, social distancing, frequency of sanitizing efforts, etc.

The Governor issued a “Safer at Home” Order. What does this mean?

The Governor’s Order requires individuals to stay at home until April 30, 2020 but the Executive Order applies only to individuals included in Oklahoma’s “vulnerable population.”

Who is included in the “vulnerable population?”

The “vulnerable population” includes individuals over the age of sixty-five (65) and individuals with serious underlying health conditions.

May I leave my house?

Members of the vulnerable population are encouraged to stay at home. However, those affected are permitted to leave their homes to go to work provided their employer is part of the Essential Critical Infrastructure Workforce and to conduct essential errands.

What is considered to be an essential errand?

Essential errands are those errands that are important and critical to everyday life. For example, purchasing supplies and medications from grocery stores or pharmacies and visits to medical providers.

What businesses are included in the Essential Critical Infrastructure Workforce?

The Executive Order directs businesses to determine whether they are essential or non-essential by consulting the Department of Homeland Security’s CISA Guidance on the Essential Critical Infrastructure Workforce. The essential workforce incudes business, employers, and employees in the following fields:

1. Healthcare and Public Health
2. Law Enforcement, Public Safety, and First Responders,
3. Food and Agriculture
4. Energy including Electricity, Petroleum, and Natural and Propane Gas
5. Water and Wastewater
6. Transportation and Logistics
7. Public Works
8. Communications
9. Information Technology
10. Critical manufacturing,
11. Other Community Based Government Operations and Essential Functions
12. Hazardous Materials
13. Financial Services
14. Chemical
15. Defense Industrial Base

Are ODMHSAS facilities and those facilities certified by ODMHSAS included in the Essential Critical Infrastructure Workforce?

Yes. ODMHSAS facilities and staff, as well as those certified by ODMHSAS, are included as covered businesses and workers as part of the Health and Public Health Essential Critical Infrastructure Workforce. As such, ODMHSAS facilities and staff, as well as those certified by ODMHSAS, are exempt from any mandatory closure orders as well as any mandatory stay at home orders.

What limitations have been placed on gatherings?

Social gatherings of ten (10) or more people are currently banned statewide. This prohibition does not apply to those businesses, employers, and employees deemed essential. However, those within the Essential Critical Infrastructure Workforce are encouraged to take every step reasonable to comply with the prohibition. That is, as reasonable, limit gatherings to ten or fewer individuals. If not reasonable, impose the directives of social distancing, as reasonable, by distancing individuals at least six (6) feet from one another, washing hands for twenty (20) seconds with soap and water, using hand sanitizer, and not shaking hands with others.

COVID-related changes regarding telehealth/telephonic services have been preliminarily extended by ODMHSAS and OHCA through 01/31/2021. ODMHSAS and OHCA will monitor the situation and will notify providers of changes to this extension should they occur.

Are there preferred telehealth platforms that we can use to provide services?

There are several HIPAA compliant telehealth platforms to choose from including, Polycom Real Presence, Zoom, VIDYO, DOXY.ME, My Care, and ThinkTelehealth. ODMHSAS will continue to explore options.

What efforts is the ODMHSAS taking to assist and support providers with the utilization of telehealth services? 

ODMHSAS has procured an option for providers, Polycom Real Presence. The initiation fees associated with their utilization will be waived. For information on using this tool, contact the ODMHSAS Help Desk.

Currently, group services and family therapy are not allowed through telehealth. Can that be modified? 

All services using a recognized telehealth platform are considered face-to-face. Those will now include group and family therapy services. 

Are there additional codes that now have GT modifiers for telehealth?

Group rehabilitation, psychological testing, and behavioral health aid now have GT modifiers.

What type of services can we provide through telephone?

There is nothing prohibiting treatment providers from engaging with consumers over the telephone. There is a list of reimbursable service codes that can be accessed by clicking here.  These are for department contracted services paid for by ODMHSAS.

For telephone codes that are reimbursable through OHCA: Effective immediately and only for so long as the national emergency surrounding COVID-19 exists, services rendered by behavioral health providers via telephone will use the HCPCS/CPT codes listed in the rates & codes sheets applicable to their provider type found at www.okhca.org/behavioral-health using the GT modifier. Services should only be delivered telephonically (non face-to-face) in instances when the SoonerCare member does not have access to telehealth equipment, the service is necessary to the health and safety of the member, and the service can safely and effectively be provided over the telephone. Providers are encouraged to create internal policies and procedures regarding the use of telehealth during a national/state emergency so that all staff understand its appropriate use during this time. Documentation in the client’s record should either reference the provider’s internal policy or otherwise indicate why telehealth was utilized if the service was not reimbursed via telehealth prior to March 16, 2020.

Can telemedicine be used to conduct ADSAC assessments and ADSAC courses?

Yes, telemedicine can be used to conduct both ADSAC assessments and courses. An emergency declaration for ADSAC services has been issued. Click here for a copy of the declaration.

Can licensure candidates provide telehealth/telephonic services?

Telehealth and telephonic services can be provided by fully licensed, under board approved supervision for licensure, and/or actively certified providers (e.g., Certified Behavioral Health Case Manager II). Requirements for provider qualifications are not changed or more restrictive due to telehealth billing policies.

For information from the Board of Behavioral Health Licensure regarding telehealth and supervision of candidates, please visit https://www.ok.gov/behavioralhealth/COVID-19.html

To visit the Oklahoma State Board of Licensed Social Workers website, go to https://www.ok.gov/socialworkers/

To visit the Oklahoma State Board of Licensed Drug and Alcohol Counselors website, go to http://www.okdrugcounselors.org/

How should signatures be obtained if services are provided by telehealth/telephone?

Signatures for treatment plans and other service documents can be obtained by postal mail with a return envelope (or returned by email), electronic signature, or fax signature.

If those methods are not achievable, providers may consider the options below. However, providers should ensure their accrediting entities also accept these methods, robust documentation is kept (including specific documentation of what the client is consenting to), and internal policies are addressed.

1. Email the document and client emails back a written consent (not able to print, sign, scan back)
2. Record a statement and keep recording
3. Document a statement, along with reasons this method was necessary
4. Use voice signature technology
   

Are there additional consent requirements for telehealth?

There are no additional consent requirements for providing a service with telehealth, unless the service is provided in a school and reimbursed by Medicaid/SoonerCare. (In that case, advance consent from a parent or legal guardian is required). Please follow standard consent requirements for the provision of services.

Do I have to update a treatment plan to add the GT modifier?

If the service is already on the treatment plan, no you do not have to update to add the modifier. However, you may need to check with your vendor, as the treatment plan update may be how your vendor adds the modifier.

Who should clinicians in loan repayment programs contact for information on providing telehealth services?

Each clinician should contact the National Health Service Corps (NHSC) through the Bureau of Health Workforce Portal to request permission. Visit https://nhsc.hrsa.gov/coronavirus for more information.

What about privacy rules and alternative ways to deliver telehealth services?

The HHS Office for Civil Rights (OCR) announced on March 17, 2020, that it will waive potential HIPAA penalties for good faith use of telehealth during the nationwide public health emergency due to COVID-19. The notification below explains how covered health care providers can use everyday communications technologies to offer telehealth to patients responsibly.

• Notice of Enforcement Discretion for Telehealth
• February 2020 HIPAA and Novel Coronavirus - PDF*
• CMS Fact Sheet
• CMS Press Release
• SAMHSA Guidance Related to 42 CFR Part 2

Can I bill for case management services via telephone?

Yes, case management was already approved via telephone.

Can I bill for screening services via telephone?

Yes, screenings were already approved via telephone.

Can I bill for Wellness services?

Yes, during the COVID 19 crisis wellness will be allowed via telephone.

Can I bill for Outreach services?

Yes, during the COVID 19 crisis outreach will be allowed via telephone.

Additional Resources

Opioid Response Network - Telemedicine for OUD During COVID-19 National Public Health Emergency

SAMHSA's COVID-19 Page - Includes emergency grant FOA, training and TA guidance, and OTP guidance.

ASPR TRACIE's COVID-19 Page - Includes guidance on Alternate Care Sites, drive-thru testing, and fatality management

Health Workforce Technical Assistance Center - Includes guidance on surge capacity strategies, regulatory flexibility, and workforce strategies from various states

What is the status of treatment courts?

The priority for all treatment court programs is the ongoing support and care for program participants.  Courthouse operations and supervision procedures are likely to vary widely by county and changing each day at the direction of county commissioners, district court judges, and probation officials.  Treatment court teams are expected to clearly communicate all changes in procedures and requirements to program participants.  Services and supports to participants through the provider network are to continue.  Please see FAQ questions related to service provision requirements and telehealth.

Can we continue providing Offender Screening services in the county jail?

Yes, continuing Offender Screening services is especially important as it supports a quicker release from jail and access into community treatment services.  We encourage you to work with jail administrators to be creative in ways to safely access large numbers of the jail population to provide this service (ex. Technology, use of visiting areas through phone, etc.).  ODMHSAS is also extending the use of available Outreach codes in your contracts to support connection to treatment at reentry for individuals leaving jail.

For a list of FAQs regarding Opioid Treatment Programs and Opioid Use Disorder in the COVID-19 Emergency, please click here.

The United States Drug Enforcement Administration has also released information regarding OTP services and can be found here.

SAMHSA has a comprehensive list for MAT and COVID-19 guidance that can be found here.

Additional Questions? Please email COVID@ODMHSAS.ORG.  This page will be updated as more information becomes available.

National Indian Health Board: https://www.nihb.org/
National Congress of American Indians: https://www.nihb.org/
Southern Plains Tribal Health Board: https://www.spthb.org/
Native Wellness Institute: https://www.nativewellness.com/
Indian Health Services: https://www.ihs.gov/
Native Center for Behavioral Health: https://www.public-health.uiowa.edu/ncbh/

Oklahoma Tribal Liaisons for Health

OHCA - Dana Miller http://www.okhca.org/providers.aspx?id=128&menu=74&parts=7471_7703
Health Department - Stephen Weaver https://www.ok.gov/health/Organization/Partnerships_for_Health_Improvement/Office_of_Tribal_Liaison/
Department of Mental Health & Substance Abuse Services - Johnna James https://www.ok.gov/odmhsas/Additional_Information/Tribal_State_Relations/index.html

(This information is taken from the State Board of Behavioral Health website.)

Due to concerns regarding the spread of COVID-19 and in accordance with Executive Order 2020-07 the Board of Behavioral Health Licensure (BBHL) is limiting face-to-face interactions with the public. In order to ensure the public’s health, safety and welfare are protected, during the current State of Emergency the staff of the Board will be primarily working remotely. Phone messages will be checked and returned as time permits.

On Tuesday, March 24, 2020 at 10:00 a.m. the Board held a special meeting to address several issues that are a direct result of the COVID-19 crisis and voted on the stay of enforcement for many of our rules that require face-to-face interactions. The following motions were made and approved by the Board.

Candidates:

The Board has approved a stay of enforcement of the requirement to submit a Supervision Agreement in order to utilize technology-assisted supervision for the duration of Executive Order 2020-07.

The Board approved a stay of enforcement for the requirement limiting 50 percent of supervised experience to be accrued through technology-assisted supervision for the duration of Executive Order 2020-07.

The Board has approved a stay of enforcement for the requirement of On-Site supervision to be on-site during the duration of Executive Order 2020-07.

The Board has approved a motion for a stay of enforcement of the requirement that two observations be required each six month period for all licensure candidates for the duration of Executive Order 2020-07.

The Board has approved a stay of enforcement on testing eligibility periods, as well as supervision hour eligibility periods for all licensure candidates, pausing the eligibility periods, for the duration of Executive Order 2020-07.

Licensure:

The Board has approved a stay of enforcement for all face-to-face CEU requirements, including Ethics and Supervision for the duration of Executive Order 2020-07.

The Board voted to allow any previously approved CEU’s to automatically be approved for face-to-face and technology-assisted CEU's during the duration of Executive Order 2020-07.

The Board suspended the processing of any new CEU applications, pending further discussion and review by the Board, and to allow any previously approved CEU’s to automatically be approved for face-to-face and technology-assisted.

Tele-counseling/therapy:

The Board has received many inquiries regarding tele-counseling. In an effort to reduce barriers to tele-counseling the Board has not adopted any restrictions regarding tele-counseling. If you plan to provide services out-of-state, it is also recommend that you contact that states Board to see if they have adopted additional provisions. The Board is not promoting any service provider; however the lists of providers below have been deemed HIPAA compliant by OMES:

V-See
Doxy.me
Theranest
Vidyo.com
Simplepractice
Microsoft Teams
Skype for BUSINESS
Zoom

General Information:

The Board of Behavioral Health Licensure along with other State agencies will continue to work with state and local government agencies to provide information to all licensees and the general public as we receive information on the Coronavirus (COVID-19). We encourage you as healthcare providers to continue to communicate with staff on proper sanitary measures as well as communication to your clients. You can access further information at the Oklahoma State Department of Health website. In addition to visiting the State Department of Health website the Call Center number and hours are being provided to further assist in questions, you or your clients may have regarding Coronavirus (COVID-19).

Additional Resources for Treatment Courts

https://www.nadcp.org/covid-19-resources/

https://www.oscn.net/v4/

https://connect.appa-net.org/resources/covid-19 

Here are various questions and answers from a webinar with the OHCA regarding COVID-19 measures around providing services.

For information regarding the Enhanced Medicaid/CHIP Provider Relief Fund, please visit the US Department of Health and Human Services website. Applications for eligible providers can be submitted online through the portal at this website, which includes application instructions.