DOH Medicaid Update
On March 10th, the Department of Health (DOH) released a Medicaid Update that provides guidance on the State’s Medicaid coverage and reimbursement policy for services related to COVID-19 (available here). To date, the CDC, Wadsworth Labs, the New York City Public Health Laboratory, and some hospitals and commercial laboratories are authorized to provide testing. To ensure that cost-sharing is not a barrier to testing for the disease, NYS Medicaid will cover services for members including:
- Testing for COVID-19 conducted by commercial laboratories that have been granted approval to provide testing;
- Physician, clinic, and emergency visits (with no copays required) for the purposes of COVID-19 testing.
Claims submitted for these services should be identified with emergency indicators. The State will add Healthcare Common Procedure Coding System (HCPCS) billing codes as they become available. This includes the two codes so far, U0001 (for CDC laboratory tests) and U0002 (for non-CDC laboratory tests). U0002 will be reimbursed at an interim fee, as of yet unspecified. Additionally, DOH is encouraging providers to use telehealth to provide COVID-19 related services when possible and to consider 90-day supplies of long-term maintenance medications for individuals in quarantine.
DOH will handle questions about Medicaid fee-for-service or general questions about managed care coverage. However, questions about a given managed care organization’s (MCO) billing, reimbursement, and documentation policies should be directed to that organization.
DFS Insurance Circular Letters
On March 3rd, the Department of Financial Services (DFS) issued a circular letter for regulated insurers on COVID-19 preparedness (available here). The letter encourages plans to reduce barriers to COVID-19 testing, including waiving any cost-sharing requirements for testing, and for in-network office visits, in-network urgent care visits, and all emergency rooms when testing for COVID-19. If in-network testing is not available, they must cover out-of-network testing. Plans are also reminded that COVID-19 testing falls under laboratory services, which must be covered by individual and small group plans as an essential health benefit, and which would typically be included in base coverage by large group issuers under the Insurance Law. DFS also reminds issuers that telehealth services should be covered under the same basis as regular services, and encourages them to ensure they have a robust telehealth network.
On March 10th, DFS issued a letter to regulated carriers (available here) requiring that they submit preparedness plans to address the operational risk of COVID-19. The submissions must describe the carriers’ preparations to manage the risk of disruption to their operations and the financial risk arising from COVID-19. Responses are to be provided to DFS as soon as possible and in no event later than thirty (30) days from the date of the letter.
OMH Telehealth Self-Attestation and Guidance
On March 11th, the Office of Mental Health (OMH) issued a waiver allowing all Article 31 licensed programs to offer services via telehealth for the duration of the COVID-19 emergency (available here). Providers must self-attest that they will meet operating standards, use a secure telehealth system, maintain confidentiality, and use appropriate telehealth modifiers in billing. The attestation form is available here.
OMH earlier issued other guidance on COVID-19 screening for in-person visits (available here). It directs community programs to screen patients for COVID-19 risk factors and, if such factors are present, to contact DOH and to instruct patients to return home and contact DOH themselves.
OPWDD Guidance
On March 10th, the Office for People with Developmental Disabilities (OPWDD) issued guidance on screening visitors to programs (available here). The guidance recommends pre-screening and considering temporary visiting restrictions.