On March 19, 2020, the Family and Social Services Administration (the “FSSA”) announced Indiana Medicaid will temporarily cover telephone and telemedicine interactions between Medicaid beneficiaries and health care providers in an effort to contain the spread of COVID-19. These services will be reimbursed as if it was a face‑to‑face encounter. The FSSA says interactions must be provided within the guidelines of the provider’s licensure and scope of practice rules, and this applies to in- and out-of-state providers. On March 19, 2020, Indiana Governor Eric Holcomb signed an Executive Order suspending the requirement that a health care provider hold an Indiana license if he or she has an equivalent license from another state and has not been suspended or barred from practice in that state or any other state. However, questions still remain about whether those out-of-state providers can bill Indiana Medicaid absent going through the process to become enrolled as an Indiana Medicaid provider, and we anticipate additional guidance about this.
This policy, which will apply to both Fee-for-Service Medicaid beneficiaries, as well as enrollees in all Medicaid managed care programs, covers both mental health services as well as home- and community-based services. No firm end date has been provided for this policy; it will last as long as Governor Eric Holcomb’s declaration of a public emergency remains in effect.
The FSSA announced there will be some exceptions to this policy where physical interaction is required, like surgical procedures, anesthesia, laboratory, radiology, audiological services and chiropractor services. Only voice and video interactions are covered services; email and text exchanges are not available for reimbursement under this expansion. If the code being billed is not currently listed in the Telemedicine Services Code Set (available here), the FSSA instructs providers to include the GT modifier on the claim for reimbursement and refrain from selecting Place of Service code 02 or modifier 95.
If you have any questions or would like additional information on this topic, please contact:
- Liz Elias at (317) 977-1468 or eelias@hallrender.com;
- Chris Eades at (317) 977-1460 or ceades@hallrender.com; or
- Your regular Hall Render attorney.
