SCDHHS Announces Updates to Critical Telehealth Flexibilities to Continue Access to Care for Healthy Connections Medicaid Members

COLUMBIA, SC -The South Carolina Department of Health and Human Services (SCDHHS) today announced the extension of most of the temporary telehealth flexibilities it created during the coronavirus disease 2019 (COVID-19) federal public health emergency (PHE). During the first seven weeks of the federal PHE, SCDHHS issued approximately two years’ worth of policy changes. These policy changes included a heavy emphasis on building upon the state’s existing telehealth benefit. Both the telehealth and non-telehealth-related policy changes made during the federal PHE were issued for the duration of the federal PHE, which was declared March 13, 2020. The secretary of the U.S. Department of Health and Human Services recently announced the federal PHE will remain in effect until at least July 15, 2022.

Broadly, the updates to these telehealth flexibilities announced in today’s Medicaid bulletin can be categorized as flexibilities that will be made permanent, those that will be extended for further evaluation for one year after the end of the federal PHE and those that will expire at the end of the federal PHE.

“Since enacting dozens of telehealth flexibilities early in the COVID-19 pandemic, SCDHHS has been able to evaluate utilization data and receive critical input from members, providers and other stakeholders on the value of further growing our telehealth program,” SCDHHS Director Robby Kerr said. “Telehealth is a critical component of the future of health care delivery. With today’s announcement, we are taking another step toward further integrating this valuable tool into the Healthy Connections Medicaid program to help meet the needs of vulnerable South Carolinians.

“SCDHHS’ utilization data shows that 53% of the claims we received during the COVID-19 pandemic were for behavioral health services,” Kerr continued. “As SCDHHS continues to evaluate the structure and effectiveness of the state’s behavioral health delivery system, further extending these flexibilities will increase our ability to provide access to much-needed care as the state’s behavioral health needs continue to grow. We look forward to continuing our work with providers, state agency partners and other stakeholders to make data-driven decisions on the further development of our telehealth benefit. This collaborative approach will help us continue to properly balance our need to increase access to quality health care services with our responsibility as a state agency to properly manage the taxpayer funds that have been entrusted to the agency.”

Flexibilities That Will be Permanent
Evaluation of utilization data, clinical evidence and input from providers, Healthy Connections Medicaid members and other stakeholders have clearly demonstrated value in allowing patients to continue to receive care through telehealth from home. This will provide increased access to care for Healthy Connections Medicaid members and help ensure Medicaid members are receiving care in the appropriate setting by allowing providers to be reimbursed for services delivered via telehealth regardless of the members’ location. This change will apply to evaluation and management encounters for services rendered by:

• Physicians
• Nurse practitioners (NPs)
• Physician assistants (PAs)

Flexibilities That Will Extend for Further Evaluation
The flexibilities described below will be extended for one year beyond the date of the current federal PHE for further evaluation. This extended period will support continued access to care and allow SCDHHS to continue to evaluate data, study national payor trends and receive feedback from stakeholders to make data-driven decisions on future potential policy changes.

• Behavioral health
  • SCDHHS will continue to reimburse behavioral health providers for psychiatric diagnostic evaluations and individual and family psychotherapy rendered through telehealth.
• Audio-only telephonic services
  • When audio/visual telehealth is not an option, SCDHHS will continue to reimburse physicians, NPs, PAs and licensed independent practitioners (LIPs) for the evaluation and management, remote image and check-in services described in the Medicaid bulletin when performed as audio-only services.
• Services for Individuals with Disabilities Education Act Part C (commonly known as BabyNet)-enrolled children
  • SCDHHS will continue to reimburse for service coordination, individualized family service plan meetings and team participation, family training and occupational therapy rendered via telehealth to a child enrolled in the BabyNet program.
• Addiction and recovery-related services
• Applied Behavior Analysis
• Developmental Evaluation Center screenings
• Physical and speech therapy services
• Child well-care and Early and Periodic Screening, Diagnostic and Treatment visits

Flexibilities That Will Expire at the End of the Current Federal PHE
Evaluation of utilization data, clinical evidence and input from providers, Healthy Connections Medicaid members and other stakeholders have not demonstrated value in making some of the temporary flexibilities created during the COVID-19 pandemic permanent policies in South Carolina’s Medicaid program. As such, the flexibilities described below will expire for dates of service after the end of the current federal PHE.

• Occupational therapy (when provided to a Healthy Connections Medicaid member who is not enrolled in BabyNet)
• Audio-only telephonic assessment/management and audio-only telephonic evaluation and management related to occupational, physical and speech therapy and addiction and recovery-related services
• Behavior modification
• Psychosocial rehabilitation services
• Family support services

Provider Questions
Additional details on these changes are available in the health care provider guidance SCDHHS issued through a Medicaid bulletin available on SCDHHS’ website.

SCDHHS will release additional guidance for providers regarding the temporary flexibilities issued during the COVID-19 federal PHE not addressed in this bulletin.

A comprehensive list of the COVID-19-specific policy guidance SCDHHS issued during the federal PHE is available at www.scdhhs.gov/COVID19. Providers with questions about the policy changes announced in this bulletin should submit their questions to COVID@scdhhs.gov.

SCDHHS Data
From the beginning of federal PHE through the end of the last state fiscal year (SFY 2020-2021), 53% of the claims for services rendered via telehealth during the pandemic were for behavioral health services.

Approximately 60% of South Carolina children receive their health care coverage through the Healthy Connections Medicaid program. Similarly, approximately 60% of the 1.2 million people (as of Dec. 31, 2021) who received full-benefit Medicaid coverage in South Carolina are children.