DSS’ continued expectation is that enrolled CMAP providers will perform clinically appropriate services including, but not limited to, ensuring timely access to in-person services when medically necessary or requested by the HUSKY Health member for optimum quality of care. Therefore, all enrolled billing entities must have the capacity to deliver services in-person and must provide services in-person to the full extent that is clinically appropriate for their patients and to the full extent necessary if the HUSKY Health member does not consent to receiving one or more services via telehealth. Having the capacity means that the provider must have a physical location in CT, (or an approved applicable border state as approved as part of enrollment) where the provider has a room or set of rooms to see members in-person and can maintain the member’s privacy and confidentiality during the visit.
Location of Practitioner – Providers
Independent Practitioners/Group Practitioners/Federally Qualified Health Centers/Outpatient Hospitals
Except as otherwise specifically stated in subsequent provider guidance issued by DSS, stated as part of telehealth policy criteria for a specific service as outlined on the CMAP Telehealth Table, or for coverage of out-of-state services that are not available in-state or from a border provider as required under 42 CFR §431.52, a practitioner who is enrolled with CMAP as an independent provider or as part of an independent provider group, or as a FQHC or outpatient hospital and maintains an approved service location as part of the CMAP enrollment, has the flexibility to perform eligible telehealth services even when the performing/rendering practitioner is not physically in-person at one of the enrolled CT or border service locations at the time of the service, so long as the practitioner complies with all applicable state and federal requirements. Enrolled border providers and out-of-state providers rendering services as approved in 42 CFR 431.52, are encouraged to research applicable licensing and scope of practice requirements that may apply specifically to their location at the time of the telehealth service.
In-state enrolled CMAP providers (facility/billing provider/parent company etc.) who contract with out-of-state practitioners to provide 100% telehealth services to HUSKY members must ensure that the billing provider can provide in-person services when medically necessary or when the member requests it. Consistent with current CMAP requirements, the out-of-state practitioner must hold an active CT license. The billing provider is responsible for providing the Department with supporting documentation for services during any audit review or investigation. If documentation is not provided, or if it is not sufficient to support the services billed, the billing provider will be responsible for any calculated overpayment that needs to be returned to the Department. Except for providers meeting the requirements under 42 CFR §431.52, out-of-state practitioners who are not contracted with an instate CMAP provider are not eligible to enroll and bill for telehealth services.
SOURCE: CT Dept. of Social Services. Provider Bulletin 2023-38 REVISED Guidance for Services Rendered via Telehealth (May 2023). (Accessed Jul. 2023).
Border Providers who are enrolled with the CMAP and have a designation as a border provider may continue to render telehealth services in their border state. Border providers do not need to have an approved location within the state of Connecticut. Enrolled border providers follow the same rules as in-state CMAP enrolled providers, therefore they can perform approved telehealth services.
SOURCE: CT Medicaid Assistance Program Telehealth FAQ (May 2023), p. 6. (Accessed Jul. 2023).
Effective Now Until June 30, 2024
The following providers in another state or territory of the United States or the District of Columbia, that provide telehealth services pursuant to his or her authority under any relevant order issued by the Commissioner of Public Health, and maintains professional liability insurance or other indemnity against liability for professional malpractice in an amount that is equal to or greater than that required for similarly licensed, certified or registered Connecticut health care providers, are considered a telehealth provider:
- Physician assistant
- Physical therapist or physical therapist assistant
- Occupational therapist or occupational therapy assistant
- Registered nurse or advanced practice registered nurse
- Marital and family therapist
- Clinical social worker
- Master social worker
- Alcohol and drug counselor
- Professional counselor
- Speech and language pathologist
- Respiratory care practitioner
- Behavior analyst
- Genetic counselor
- Music therapist
- Art therapist
- Athletic trainer
Ending on June 30, 2024, any Connecticut entity, institution or health care provider that engages or contracts with a telehealth provider that is licensed, certified or registered in another state or territory of the United States or the District of Columbia to provide health care or other health services shall verify the credentials of such provider in the state in which he or she is licensed, certified or registered, ensure that such a provider is in good standing in such state, and confirm that such provider maintains professional liability insurance or other indemnity against liability for professional malpractice in an amount that is equal to or greater than that required for similarly licensed, certified or registered Connecticut health care providers.
Ending on June 30, 2024, the Commissioner of Public Health may temporarily waive, modify or suspend any regulatory requirements adopted by the Commissioner of Public Health or any boards or commissions as the Commissioner of Public Health deems necessary to reduce the spread of COVID-19 and to protect the public health for the purpose of providing residents of this state with telehealth services from out-of-state practitioners.
SOURCE: HB 5596 (2021 Session) & SB 2 (2022 Session). (Accessed Jul. 2023).
*See COVID-19 Licensing Section in regard to any effective temporary orders.
Effective July 1, 2022
The Commissioner of Public Health may issue an order authorizing telehealth providers who are not licensed, certified or registered to practice in this state to provide telehealth services to patients in this state. Such order may be of limited duration and limited to one or more types of providers described in subdivision (13) of subsection (a) of section 1 of public act 21-9, as amended by this act, or subdivision (12) of subsection (a) of section 19a906 of the general statutes, as amended by this act. The commissioner may impose conditions including, but not limited to, a requirement that any telehealth provider providing telehealth services to patients in this state pursuant to such order shall submit an application for licensure, certification or registration, as applicable. The commissioner may suspend or revoke any authorization provided pursuant to this section to a telehealth provider who violates any condition imposed by the commissioner or applicable requirements for the provision of telehealth services under the law. Any such order issued pursuant to this section shall not constitute a regulation, as defined in section 4-166 of the general statutes.
SOURCE: SB 2 (2022 Session), Sec. 33 (Accessed Jul. 2023).
Physicians rendering inpatient surgical services for a CMAP member must ensure the hospital has submitted and obtained an approved prior authorization for the inpatient surgery. Once the hospital has an approved authorization on file for the CMAP member, the member is eligible to receive their pre- and/or post-surgical consultations via telemedicine. Any telemedicine service related to the surgery must be rendered by the Out-of-State (OOS) provider who will be performing the surgery. All telemedicine services must be clinically appropriate and medically necessary. Pre/Post surgery instructions are not eligible for reimbursement via telemedicine.
SOURCE: CT Medical Assistance Program, Provider Bulletin 2020-09 (March 2020), p. 4. (Accessed Jul. 2023).
Border Hospital Reimbursement
The Department of Social Services (DSS) is notifying border and out-of-state (OOS) hospitals that the rates and parameters for reimbursement of inpatient and outpatient hospital services, provided to Connecticut Medicaid members, have been updated effective for dates of discharges on or after January 1, 2023.
SOURCE: CT Medical Assistance Program, Provider Bulletin 2022-95 (Dec. 2020), p. 1. (Accessed Jul. 2023).
The Commissioner of Public Health, in consultation with the Commissioner of Early Childhood, shall develop and implement a plan to establish licensure by reciprocity or endorsement of a person who (1) is (A) a speech and language pathologist licensed or certified to provide speech and language pathology services, or entitled to provide speech and language pathology services under a different designation, in another state having requirements for practicing in such capacity that are substantially similar to or higher than the requirements in force in this state, or (B) an occupational therapist licensed or certified to provide occupational therapy services, or entitled to provide occupational therapy services under a different designation, in another state having requirements for practicing in such capacity that are substantially similar to or higher than the requirements in force in this state, (2) has no disciplinary action or unresolved complaint pending against such person, and (3) intends to provide early intervention services under the employment of an early intervention service program participating in the birth-to-three program established pursuant to section 17a-248b of the general statutes.
When developing and implementing such plan, the Commissioner of Public Health shall consider eliminating barriers to the expedient licensure of such persons in order to immediately address the needs of children receiving early intervention services under the birthto-three program. The provisions of any interstate licensure compact regarding a speech and language pathologist or occupational therapist adopted by the state shall supersede any program of licensure by reciprocity or endorsement implemented under this section for such speech and language pathologist or occupational therapist.
On or before January 1, 2023, the Commissioner of Public Health shall (1) implement the plan to establish licensure by reciprocity or endorsement, and (2) report, in accordance with the provisions of section 11-4a of the general statutes, to the joint standing committees of the General Assembly having cognizance of matters relating to public health and children regarding such plan and recommendations for any necessary legislative changes related to such plan.
SOURCE: SB 2 (2022 Session), Sec. 26. (Accessed Jul. 2023).
Effective July 1, 2024
A telehealth provider also is to include an appropriately licensed, certified or registered provider as listed below in another state or territory of the United States or the District of Columbia, who (i) provides telehealth services under any relevant order issued pursuant to section 33 of this act, (ii) provides mental or behavioral health care through the use of telehealth within such person’s scope of practice and in accordance with the standard of care applicable to the profession, and (iii) maintains professional liability insurance, or other indemnity against liability for professional malpractice, in an amount that is equal to or greater than that required for similarly licensed, certified or registered Connecticut mental or behavioral health care providers:
- registered nurse
- advanced practice registered nurse
- physician assistant
- marital and family therapist
- clinical social worker
- master social worker
- alcohol and drug counselor
- professional counselor
- behavior analyst
- music therapist
- art therapist
SOURCE: SB 2 (2022 Session), Sec. 30. (Accessed Jul. 2023).