COVID-19 FAQs
- Additional Operational Questions
Do you temporarily waive pre-authorization/pre-certification guidelines?
SCDHHS has extended the timeframe for submitting additional documentation from two days to seven days. The agency continues to work closely with its quality improvement organization, KEPRO, to monitor the needs of the provider community and will make additional changes should they be necessary.
For claims submitted to MCOs, providers should confirm authorization requirements with the MCO.
Do you temporarily waive or extend provider enrollment time frames?
Providers need to be enrolled to provide services, however SCDHHS currently allows retroactive review/enrollment for emergency services, which would apply for COVID-19 services.
If a provider is provisionally enrolled, will they have to be re-enrolled once the crisis is over. If so, when can we submit the full app?
Yes, the provider will have to complete the full application. This can be done at any time even while currently enrolled in a provisional status.
For Quality Measures related to wellness visits, what documentation requirements can be self-reported?
SCDHHS continues to use the National Committee for Quality Assurance (NCQA) technical specifications as standard for requirements related to supplemental data for hybrid measures for the Healthcare Effectiveness Data and Information Set (HEDIS).
Does the South Carolina Healthy Connections Medicaid program provide or reimburse for interpreters and/or translators?
The Medicaid provider enrollment agreement and the SCDHHS policy manual both require providers to deliver services to non-English speaking individuals without additional compensation or support from the agency.
- Appendix K
How should providers prove they received money from the Small Business Administration (SBA) or Paycheck Protection Program (PPP)?
An attestation for any loans or monies received during the public health emergency (PHE) is included in the required Form 950K1 and Form 950K2. Proof must be maintained by the provider in case of an audit or review. Providers who received PPP loans thatexceeded their revenue for the last full quarter prior to the public health emergency are not eligible for retainer payments.
Will any additional funding be provided for personal protective equipment (PPE)?
At this time, no additional funding is being provided for PPE.
If a provider closed due to low census can they request a retainer payment? What if a provider closed after Jan. 1,2020?
No. To be approved for retainer payments, providers must have been enrolled with the South Carolina Department of Health and Human Services (SCDHHS) as of Jan. 1, 2020, and remain in good standing with SCDHHS. Good standing means a provider who is in an active status with SCDHHS and is not on suspension.
What if a provider has already let staff go due to low census?
SCDHHS will require an attestation from the provider that it will not lay off staff and will maintain wages at existing levels to receive retainer payments. Previous layoffs prior to the retainer payment request are not part of the required attestation.
What happens if the provider does not agree with the amount they are awarded?
The acceptance of retainer payments is strictly voluntary. Providers do not have to receive retainer payments.
Which services are available for retainer payments?
Adult Day Health Care, Adult Day Health Care Nursing, Attendant Care, Personal Care I and II, Agency Companion, Respite, Nursing (Registered Nurse (RN), Licensed Practical Nurse (LPN), Medicaid Nursing, Children’s Private Duty Nursing), Day Activity, Career Preparation, Community Services, Support Center Services, Group Employment, Individual Employment. These are the only services that were approved for retainer payments by the Centers for Medicare and Medicaid Services (CMS).
How can providers tell how much money Medicaid has reimbursed my agency?
Providers can run a claims activity report in Phoenix and/or review the remittance advice in the Webtool.
How will this work for Adult Day Health Care (ADHC) providers that render services on Saturdays?
ADHC falls under service group one. This service group is to report their usual and customary revenue received for each service over a six-week period, as well as actual revenue received for those services provided during the periods of March 16 to April 24, 2020; April 27 to June 5, 2020; and, June 8 to July 17, 2020.
Will this provide reimbursement for ADHC transportation?
No. ADHC transportation was not included in the approved request.
For ADHC services, there are some authorizations on my remittance advice with procedure code LTC10. This is not listed on the Appendix K – will it count?
No. Only revenue received under the approved procedure code S5102 will be considered for retainer payments. If you are receiving revenue under the LTC10 procedure code, please contact the Provider Oversight, Support and Education Team via email at waiverclaims@scdhhs.gov.
Will this provide reimbursement for Veterans Affairs (VA) or other type of payment clients
No. Retainer payments are based upon the average payment amount made to providers from SCDHHS.
We are a multi-state provider. Are the revenue figures used to complete the attestation form strictly revenue related to our South Carolina operations?
Only the revenue generated from SCDHHS Medicaid payments for the specified South Carolina Medicaid services are applicable.
How will this work if we owe SCDHHS funds?
SCDHHS will evaluate each situation in which a provider has an outstanding balance due to SCDHHS. In certain circumstances, the retainer payment may be applied as a credit against the outstanding amount due.
For Group 1 providers, the actual revenue for the services provided in the designated periods is a six-week period; however, the form requires usual and customary revenue to be listed as an average monthly amount. It appears the comparison is not an equal date range.
SCDHHS will conduct a comparison analysis of usual and customary revenue and actual revenue for the designated periods that utilizes a weekly average to account for the six-week periods for Group 1.
Will retainer payments be calculated for each service distinctly or as an aggregate for all services?
Each service will be evaluated individually for retainer payment eligibility and amounts. The provider will be paid in individual adjustments for each waiver and each service.
Is procedure code S5170 included to add to 950K2?
No. Procedure code S5170 is not approved for retainer payments.
- Behavioral Health
How should 301 clinics list modifiers when billing for service delivered through the telehealth flexibilities authorized during the COVID-19 public health emergency?
For codes 90832, 90834, 90837, 99408, H0001, H0032 and H0038, providers should bill with existing modifiers and use the second modifier field to add the GT modifier as applicable. For code H0004, providers should bill with the GT modifier in the first modifier field.
Can providers performing Applied Behavior Analysis services as parent-directed services or through remote supervision of a registered behavior technician change between the two delivery methods during the COVID-19 pandemic?
As the period of recommended social distancing has increased, SCDHHS will allow providers to change from parent-directed services to in-home services with an RBT receiving remote supervision by a BCBA once. The decision to switch between delivery methods must be agreed to by both the provider and the parent or guardian of the child receiving the service. Providers must document the change of circumstance in the beneficiary’s record on a clinical service note.
Is guidance available regarding telehealth services for the 301-provider system?
Yes, SCDHHS published a memo on April 17, 2020, that clarified authorities for telehealth authorities for Act 301 local alcohol and drug abuse authorities. The memo is available here on SCDHHS’ COVID-19 website.
Can licensed LPCs also bill for telephonic check-ins in addition to being able to bill for individual therapy?
Yes. All services should be in line with the individual’s medical necessity and should be billed as described in Bulletin 20-009.
Will licensed independent practitioners (LIPs) with associate-level licenses be able to provide and be reimbursed for telehealth services?
SCDHHS has offered telemedicine flexibilities to several categories of LIPs in the behavioral health and therapeutic professions. In addition, SCDHHS issued a bulletin on April 6, 2020, shortly after the conclusion of the webinar, that provides additional expanded coverage and guidelines for licensed associates. Bulletins explaining these flexibilities can be found on the COVID-19 webpage.
- Billing and Reimbursement
Is there an end date to COVID-19-related telehealth coverage?
Any modifications to telehealth policies, including the sunsetting of any telehealth flexibilities authorized in response to COVID-19, will be communicated via Medicaid bulletin(s) in a manner that allows ample notice for providers and Healthy Connections Medicaid members to plan and ensure continuity of care. Policy changes and additional guidance and resources related to the COVID-19 pandemic are available on the COVID-19 webpage.
What is the location code when billing telephonic and telehealth codes?
For COVID-19-related telehealth services submitted to the fee-for-service benefit, providers can elect to submit either ‘02’, indicating telehealth, or place of service code they would have used if the service had been provided in person (FQHCs billing through the SCDHHS webtool should select “POS 12”). Medicaid MCOs may have additional requirements related to the place of service for COVID-19 related telehealth services.
Can you please advise on the proper use of this GT modifier? We use another code in the first block. Does this take that place or does it go in the second block?
When billing for a service with a GT modifier, the GT modifier should be listed after any other modifiers. For example, if you bill with a HO modifier and a GT modifier, HO should be included in the first block and GT should be included in the second block.
Why is there a difference between covered dates of service and the claims submission acceptance date?
SCDHHS’ goal in preparing and responding to COVID-19 is to authorize services quickly, but the agency also needs time to update its system(s) to receive bills and reimburse for claims.
Will telehealth services be reimbursed at the same rate as traditional services?
Telehealth services will be reimbursed at the same rate as traditional services, unless there is already an existing telemedicine code that follows one of the agency's benchmarks, such as Medicare, or a different rate is stated otherwise in a bulletin or guidance sent out by the agency. The South Carolina Department of Health and Human Services (SCDHHS) will continue to provide additional guidance as needed and will publish fee schedules as they are available for expanded telehealth services during this emergency response period.
- Managed Care Organizations
Do you temporarily waive pre-authorization/pre-certification guidelines
SCDHHS has extended the timeframe for submitting additional documentation from two days to seven days. The agency continues to work closely with its quality improvement organization, KEPRO, to monitor the needs of the provider community and will make additional changes should they be necessary.
For claims submitted to MCOs, providers should confirm authorization requirements with the MCO.
What is the location code when billing telephonic and telehealth codes?
For COVID-19-related telehealth services submitted to the fee-for-service benefit, providers can elect to submit either ‘02’, indicating telehealth, or place of service code they would have used if the service had been provided in person (FQHCs billing through the SCDHHS web tool should select “POS 12”). Medicaid MCOs may have additional requirements related to the place of service for COVID-19-related telehealth services.
Are Healthy Connections Medicaid managed care organizations (MCOs) covering teletherapy services for their members?
MCOs are broadly implementing teletherapy coverage in a manner consistent with the agency's interim policies. As with all service coverage questions, the agency encourages providers to contact the MCOs' provider liaison center for any billing or documentation guidance necessary to receive reimbursement.
- Medicaid Eligibility
How can applicants, beneficiaries and authorized representatives submit documents to SCDHHS electronically?
Applicants, beneficiaries, authorized representatives and third parties providing application assistance are now encouraged to submit documents electronically to SCDHHS using the email address 8888201204@fax.scdhhs.gov.
For third parties assisting multiple individuals, a separate secure email must be sent for each applicant or beneficiary. The secure email must include the applicant or beneficiary’s name, phone number, date of birth, Medicaid number (if applicable) and Social Security number.
Will SCDHHS allow Medicaid applicants to use e-signatures?
SCDHHS has modified the eligibility signature policy in recognition of the current challenges in obtaining physical signatures from individuals during the COVID-19 emergency response period. An applicant, or a person authorized by SCDHHS policy to apply on behalf of an individual, may “sign” an application by typing the name on the signature line and completing the “Is someone helping you fill out this application?” section of the form.
Does SCDHHS ensure that newborn members have retroactive effective dates due to any delays in enrollment?
Yes, SCDHHS will ensure newborn members have retroactive coverage; however, the agency does not anticipate delays in enrollment.
Does SCDHHS ensure that newborn members have retroactive effective dates due to any delays in enrollment?
Yes, SCDHHS will ensure newborn members have retroactive coverage; however, the agency does not anticipate delays in enrollment.
- Physical, Occupational and Speech Therapy
Does the three-visit limit in 30 days for physical, occupational and speech therapists apply to assessment and management only? Is the limit on codes 98966-98968 total or per discipline? Can the regular telehealth therapy visits be covered using a modifier GT with 97530, 97110 and 92507?
Bulletin 20-008, which was issued on March 27, authorized common therapy codes to be used to render therapy through telemedicine. These services (codes 97530, 97110 and 92507)can be provided through telehealth in accordance with the service authorization or service plan in place within the parameters set in the bulletin. The three-visit limit for codes 98966-98968 is only for telephonic assessment and management services and is a total of three across disciplines.
- Telehealth Documentation and Platform Requirements
Is there an end date to COVID-19-related telehealth coverage?
Any modifications to telehealth policies, including the sunsetting of any telehealth flexibilities authorized in response to COVID-19, will be communicated via Medicaid bulletin(s) in a manner that allows ample notice for providers and Healthy Connections Medicaid members to plan and ensure continuity of care. Policy changes and additional guidance and resources related to the COVID-19 pandemic are available on the COVID-19 webpage.
Does SCDHHS require use of a certain platform to provide telehealth services?
Providers have the same ethical and other obligations to maintain the security and privacy of their patients’ information and the service delivery platform. The agency understands not everyone has the same capabilities and/or has adopted a Health Insurance Portability and Accountability Act (HIPAA)-compliant platform and is expecting providers to use reasonable judgement and show evidence of a good faith effort. SCDHHS does not want technical compliance with certain requirements to stand in the way of patient care during this emergency response period.
What are the documentation requirements for reimbursement for telehealth services? Will the South Carolina Medicaid program require wet-ink signatures?
Providers are responsible for maintaining service planning, service notes and any necessary documentation requirements as listed in the provider manual. As described in the provider manual, Medicaid requires that services provided/ordered be authenticated by the author. Medical documentation must be signed by the author of the documentation except when otherwise specified in the provider manual. The signature may be handwritten, electronic or digital.