Medicaid Update Special Edition – Comprehensive Guidance Available Regarding Use of Telehealth including Telephonic Services After COVID-19

The Situation Report | March 20, 2023

The New York State Department of Health has just issued a Medicaid Update Special Edition on “Comprehensive Guidance Regarding Use of Telehealth including Telephonic Services After the Coronavirus Disease 2019 Public Health Emergency.”

This guidance document is available on the Medicaid Update web page. A print version is available here.

The guidance is intended to clarify the New York State Medicaid program telehealth policy, including use of audio-only technology, following the federally declared Coronavirus Disease 2019 (COVID-19) Public Health Emergency (PHE), which ends on May 11, 2023.

According to the guidance, audio-only services also will continue to be covered when audio-visual services are not available or when the member chooses audio-only services in lieu of audio-visual telehealth or an in-person visit.

The guidance further specifies that audio-only visits must contain all elements of the billable procedure codes or rate codes and all required documentation. Providers must document in the chart of the NYS Medicaid member why audio-only services were used for each audio-only encounter. However, note that NYS DOH anticipates only rare occasions when audio-only visits are appropriate for non-behavioral health (BH) services and, DOH will monitor audio-only billing and take steps to limit overuse and prevent misuse of audio-only services.

In addition, the Department states that this guidance does not change any other NYS Medicaid program requirements, with respect to authorized services or provider enrollment, and does not expand authorization to bill NYS Medicaid beyond service providers who are currently enrolled to bill Medicaid fee-for-service (FFS) or contracted with a Medicaid Managed Care (MMC) Plan.

HCA is still reviewing this information and anticipates many questions, particularly as home care is not mentioned in it. HCA will be following up with the Department and further apprise members of clarifications.

In the meantime, plans and providers should direct questions directly to the DOH indicated sources below:

• Medicaid FFS telehealth/telephonic/teledental coverage and policy questions may be directed to the Office of Health Insurance Programs (OHIP) Division of Program Development and Management (DPDM) at (518) 473-2160 or via email at Telehealth.Policy@health.ny.gov.

• Questions regarding MMC reimbursement and/or documentation requirements should be directed to the MMC Plan of the enrollee.

• Questions regarding FFS claiming should be directed to the eMedNY Call Center at (800) 343-9000.