Last updated 10/12/2021
Definitions
“Telehealth” in this bulletin compensable behavioral health services using real-time, two-way interactive audio-video transmission. Telehealth does not include text messaging, electronic mail messaging or facsimile (fax) transmissions.
Source: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-21-09, p.1, Aug. 26, 2021, (Accessed Oct. 2021).
Telemedicine is the use of two-way, real time interactive telecommunications technology that includes, at a minimum, audio and video equipment as a mode of delivering healthcare services.
Telemedicine, for purposes of Medicaid payment, does not include telephone, asynchronous or store and forward technology or facsimile machines, electronic mail systems or remote patient monitoring devices. However, these technologies may be utilized as a part of the provision of a MA-covered service.
Source: PA Department of Human Services, Medical Assistance Bulletin 99-21-06, p. 2 Sept. 30, 2021 (Accessed Oct. 2021).
Last updated 10/12/2021
Live Video
POLICY
For FQHCs & RHCs
Telepsychiatry Services – Only applicable to Behavioral Health Managed Care delivery system claims and not fee-for-service delivery. Mental health services are provided through the use of approved electronic communication and information technologies to provide or support clinical psychiatric care at a distance. Qualifying telepsych services utilize real-time, two-way interactive audio-video transmission, and do not include a telephone conversation, electronic mail message, or facsimile transmission between a health care practitioner and a service recipient, or a consultation between two healthcare practitioners, although these activities may support the delivery of telepsych services. Telepsych services require service providers to have a service description approved by the Office of Mental Health and Substance Abuse Services (OMHSAS) and deliverable through the managed care option.
SOURCE: PA PROMISe, 837 Professional/CMS-1500 Claim Form, Provider Handbook, Appendix E – FQHC/RHC. p. 10 (Apr. 22, 2014). (Accessed Oct. 2021).
Services delivered in the MA FFS delivery system through telehealth will be paid the same rate as if the services were delivered in-person.
MA providers in the MA FFS delivery system that provide services via telehealth should bill for services with a Place of Service (POS) 02 unless instructed otherwise for specific services. Please consult the MA Fee Schedule for procedure codes that now have the POS 02.
SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-21-09, p. 7 & 8, Aug 26, 2021, (Accessed Oct. 2021).
ELIGIBLE SERVICES/SPECIALTIES
Effective, September 30, 2021, the MA Program will pay for MA covered services rendered to beneficiaries via telemedicine when clinically appropriate and allowable according to the provider’s scope of practice. Services rendered via telemedicine must be provided according to the same standard of care as if delivered in-person. Providers are encouraged to establish protocols for the use of telemedicine.
Limited English Proficiency
All recipients of federal funding, including the MA Program, must offer and make available interpretation services to beneficiaries with limited English proficiency, visual limitations, and/or auditory limitations. Providers who elect to render services through telemedicine must have policies in place to make language assistance services, such as oral interpretation, including sign language interpretation, and written translation, available to beneficiaries being served via telemedicine.
SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-21-06, p. 4, Sept. 30, 2021, & PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-21-09, p. 6, Aug 26, 2021, (Accessed Oct. 2021).
MA covered services rendered via telemedicine in the FFS delivery system will be paid at the same rate as if they were rendered in-person. The Department added Place of Service (POS) 02 (telemedicine) for providers to identify services that are rendered via telemedicine. Providers are no longer required to utilize the GT modifier to indicate the use of telemedicine and are instead to use POS 02. Providers are to indicate in the beneficiary’s medical record when telemedicine services are rendered via audio-only.
When the beneficiary accesses services at an enrolled originating site, the provider serving as the originating site may bill for the technology service using the telehealth originating site procedure code Q3014 only. MA Providers may no longer bill procedure code Q3014 in addition to an office visit that is provided at the originating site.
PA Medical Assistance Program has a fee schedule that lists codes eligible to be performed using interactive telecommunication technology.
SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-21-06, p. 5, Sept. 30, 2021, (Accessed Oct. 2021).
Some behavioral health services may be appropriate to be provided primarily through telehealth, while other services will require ongoing in-person delivery for a significant portion of or all of the services. Providers and practitioners should carefully consider the clinical appropriateness of telehealth delivery for such services, including, but not limited to: Partial Hospitalization, Intensive Behavioral Health Services (IBHS), Family Based Mental Health, Assertive Community Treatment (ACT), or if the beneficiary is in a residential facility or inpatient setting
Providers in the MA HC program must follow the billing instructions of the BH-MCO.
SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-21-09, p. 5, 7 & 8, Aug 26, 2021, (Accessed Oct. 2021).
ELIGIBLE PROVIDERS
Licensed Practitioners
Licensed practitioners may provide behavioral health services through telehealth that are within their scope of practice. Practitioners should exercise sound clinical judgement and should not provide services through telehealth when it is clinically not appropriate to do so. Services delivered using telehealth must comply with all service specific and payment requirements for the service.
Provider Agencies
Provider agencies using behavioral health staff who are unlicensed, including unlicensed master’s level therapists, mental health targeted case managers, mental health certified peer support specialists, certified recovery specialists, and drug and alcohol counselors (as defined in 28 Pa. Code §704.7(b)), and licensed practitioners may provide services using telehealth. Provider agencies should establish and enforce policies for assessing when it is clinically appropriate to deliver services through telehealth. Services delivered using telehealth must comply with all service specific and payment requirements for the service.
SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-21-09, p. 2 & 3, Aug 26, 2021, (Accessed Oct. 2021).
Telepsych services delivered in FQHCs and RHCs require providers to have a service description approved by the Office of Mental Health and Substance Abuse Services and the service must be deliverable through the managed care option. Telepsych services are limited to psychologists and psychiatrists.
SOURCE: PA PROMISe, 837 Professional/CMS-1500 Claim Form, Provider Handbook, Appendix E – FQHC/RHC. p. 10 (Apr. 22, 2014). (Accessed Oct. 2021).
ELIGIBLE SITES
The originating site is the setting at which an individual receives behavioral health services using telehealth delivery. When telehealth is being used to deliver services to an individual who is at a clinic, residential treatment setting, or facility setting, the originating site must have staff trained in telehealth equipment and protocols to provide operating support. In addition, the clinic or facility must have staff trained and available to provide clinical intervention in- person, if a need arises.
Services delivered through telehealth may also be provided outside of a clinic, residential treatment setting or facility setting. With the consent of the individual served and when clinically appropriate, licensed practitioners and provider agencies may deliver services through telehealth to individuals in community settings, such as to an individual located in their home. The licensed practitioner or provider agency must have policies in place to address emergency situations, such as a risk of harm to self or others.
Prior to delivering services through telehealth, providers or practitioners should provide information to the individual receiving services that supports the delivery of quality services. At a minimum, information should address the importance of the individual being in a private location, preventing interruptions and distractions such as from children or other family members, visitors in the household and from other communication or band- width reducing devices. When services are being provided to a child, youth or young adult consideration should also be given to how much caregiver involvement will be needed during the appointment.
SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-21-09, p. 4, & 7-8, Aug. 26, 2021, (Accessed Oct. 2021).
The originating site is where the beneficiary is located at the time the MA covered service is rendered to them via telemedicine. The originating site can be, but is not limited to the beneficiary’s home, a provider’s office, clinic, nursing facility, or other medical facility site. When the originating site is a provider’s office, clinic, nursing facility or other medical facility, staff at the originating site should be trained to assist beneficiaries with the use of the telemedicine equipment and available to provide in-person clinical intervention, if needed. The provider may bill the telehealth originating site facility fee (procedure code Q3014) for the use of their office if no other MA covered service is provided at the originating site.
Providers should obtain the location of the beneficiary at the time each service is rendered via telemedicine should there be a need for emergency medical services.
SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-21-06, p. 4, Sept. 30, 2021, (Accessed Oct. 2021).
GEOGRAPHIC LIMITS
Access to Services Delivered In-Person
In the managed care delivery system, the HealthChoices Primary Contractor must ensure that provider agencies and licensed practitioners who deliver services through telehealth within their service area can arrange for services to be delivered in-person as clinically appropriate or requested by the individual served. HealthChoices Primary Contractors must ensure that each contracted provider agency and licensed practitioner meets one of the two following criteria:
- The provider agency or licensed practitioner maintains a physical location in Pennsylvania within 60 minutes or 45 miles (whichever is greater) of the area served with appropriate licensure for all services provided through telehealth; or
- The provider agency or licensed practitioner maintains a physical location in a state bordering Pennsylvania, located within 60 minutes or 45 miles (whichever is greater) of the area served in Pennsylvania, maintains licensure in the state where they are physically located for all services provided through telehealth and is enrolled with the Pennsylvania MA program.
The HealthChoices Primary Contractor may apply for an exception to allow licensed practitioners and/or provider agencies beyond the 60 minute/45 mile restriction to deliver services through telehealth in their service area when supporting additional access to services or in circumstances when the licensed practitioner and/or provider agency is needed to meet the cultural, racial/ethnic, sexual/affectional or linguistic needs of individual(s) served. Exception requests forms, included in Attachment B, can be submitted to the OMHSAS Telehealth Resource Account.
SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-21-09, p. 3 & 4, Aug. 26, 2021, (Accessed Oct. 2021).
FACILITY/TRANSMISSION FEE
The provider may bill the telehealth originating site facility fee (procedure code Q3014) for the use of their office if no other MA covered service is provided at the originating site.
SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-21-06, p. 4, Sept. 30, 2021, (Accessed Oct. 2021).
Last updated 10/14/2021
Miscellaneous
Technology Requirements:
Technology used for telehealth, whether fixed or mobile, should be capable of presenting sound and image in real-time and without delay. Telehealth equipment should clearly display the practitioners’ and participants’ faces to facilitate clinical interactions. The telehealth equipment must meet all state and federal requirements for the transmission or security of health information and comply with the Health Insurance Portability and Accountability Act (HIPAA).
Delivery of Services:
The medical record for the individual served must indicate each time a service is provided using telehealth including the receipt of informed consent prior to the start of the session, start time of service and end time of service. Additionally, if the individual served or their legal guardian, as applicable, consents to the recording of a telehealth service, documentation of consent must be included in the medical record.
Provider Policies:
- Providers using telehealth must maintain written policies for the operation and use of telehealth equipment. Policies must include the provision of periodic staff training to ensure telehealth is provided in accordance with the guidance in this bulletin as well as the provider’s established patient care standards.
- Providers must maintain a written policy detailing a contingency plan for transmission failure or other technical difficulties that render the behavioral health service undeliverable. Contingency plans should describe how the plan will be communicated to individuals receiving services.
- Prior to delivering services through telehealth, providers or practitioners should provide information to the individual receiving services that supports the delivery of quality services. At a minimum, information should address the importance of the individual being in a private location, preventing interruptions and distractions such as from children or other family members, visitors in the household and from other communication or band-width reducing devices. When services are being provided to a child, youth or young adult consideration should also be given to how much caregiver involvement will be needed during the appointment.
Determining Appropriateness for Telehealth Delivery of Services
Licensed practitioners and provider agencies delivering services through telehealth must have policies that ensure that services are delivered using telehealth only when it is clinically appropriate to do so and that licensed practitioners are complying with standards of practice set by their licensing board for telehealth where applicable.
Factors to consider include, but are not limited to:
- The preference of the individual served and/or the preference of parents/guardians
- Whether there is an established relationship with the service provider and the length of time the individual has been in treatment
- Level of acuity needed for care
- Risk of harm to self or others
- Age of a minor child
- Ability of the individual served to communicate, either independently or with accommodation such as an interpreter or electronic communication device
- Any barriers to in-person service delivery for the individual
- Access to technology of the individual served
- Whether privacy for the individual served could be maintained if services are delivered using telehealth
- Whether the service relies on social cueing and fluency
The preference of the individual served and their legal guardian(s), as applicable, should be given high priority when making determinations of the appropriateness of the telehealth delivery. However, no service should be provided through telehealth when, in the best clinical judgement of the licensed practitioner, it is not clinically appropriate. When the use of telehealth is not clinically appropriate, the licensed practitioner or provider agency must offer the services in-person. If the individual disagrees with the clinical determination, the licensed practitioner or provider agency may refer the individual to other in-network providers or the managed care organization.
Guidance specific to delivering children’s services through telehealth is included in Attachment A.
SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-21-09, pgs. 4-5 & 7-8, Aug 26, 2021, (Accessed Oct. 2021).
Pennsylvania Residents Temporarily Out-of-State
Behavioral Health Services may be provided using telehealth to meet the behavioral healthcare needs of Pennsylvania residents who are temporarily out of the state as long as the delivery of services out-of-state is consistent with the authorization for services and treatment plan, the individual continues to meet eligibility for the Pennsylvania MA Program, and the Pennsylvania provider agency or licensed practitioner has received authorization to practice in the state or territory where the individual will be temporarily located.
SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-21-09, pgs. 5, Aug 26, 2021, (Accessed Oct. 2021).
Technology Requirements
Technology used for telemedicine, whether fixed or mobile, should be capable of presenting sound and image in real-time and without delay. The telemedicine equipment should clearly display the rendering practitioner’s and participant’s face to facilitate clinical interactions and must meet all state and federal requirements for the transmission and security of health information, including HIPAA.
Audio-only telecommunications technology may be used when the beneficiary does not have video capability or for an urgent medical situation, if consistent with state and federal law. Providers must assure the privacy of the beneficiary receiving services and comply with HIPAA and all other federal and state laws governing confidentiality, privacy, and consent. Public facing video communication applications should not be used to render services via telemedicine.
Telemedicine does not include asynchronous or “store and forward” technology such as facsimile machines, electronic mail systems, or remote patient monitoring devices. While asynchronous applications are not considered telemedicine, they may be utilized as part of a MA covered service, such as a laboratory service, x-ray service or physician service.
Telemedicine also does not include text messages, although text messages and telephone may continue to be utilized for non-service activities, such as scheduling appointments.
SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-21-06, p. 4-5, Sept. 30, 2021, (Accessed Oct. 2021).
