Is there a cost share on mental health services for essential workers?

In accordance with New York Insurance Circular Letter No. 10 and the associated emergency regulation (Insurance Regulation 62, as amended, hereinafter “Emergency Regulation”), all copayments, coinsurance and deductibles for non-HSA-qualified plans are waived for face-to-face outpatient mental health services provided to essential workers beginning May 2, 2020 until further notice.

This cost share waiver applies to commercial and Essential Plan Members. For HSA-qualified plans, annual deductibles will continue to be applied to face-to-face visits. For Essential Plan members, please contact Beacon Health Options to verify billing requirements; claims for Essential Plan members must continue to be billed to Beacon Health Options.

Please refer to this list of occupations considered Essential Workers.

How should a provider bill for these services?

At the time of service, health care providers must verify whether their patient is an Essential Worker as defined in the Emergency Regulation. A copy of such definition of “Essential Worker” is included as an attachment to this letter. For services rendered prior to the date of this notice, any copayments, coinsurance or non-HSA qualified deductibles collected from a patient should be refunded as soon as possible.

To ensure compliance with the Circular Letter and Emergency Regulation, please follow the billing instructions below:

• In order to identify the individual as an Essential Worker, append Modifier CR to all claim lines so liability can be waived in accordance with the regulation.
• For any claims that were previously adjudicated, you should submit corrected claims appending Modifier CR so that the liability will be waived in accordance with the regulation. If you need further assistance with the corrected claim process, please reach out to the contact information provided below.
• The cost-share waiver for self-funded groups may vary by plan. Please contact Provider Relations at the number below in this letter regarding self-funded group coverage.

Is there any additional information or clarification about these services from NYS?

• Insurance Regulation 62: Cost share waiver for mental health services for essential workers including list of essential workers.
• NYS Circular Letter 10, which describes the regulation
• Frequently Asked Questions posted by the NY Department of Financial Services

Does Independent Health cover laboratory testing and services related to the diagnosis of COVID-19?

Independent Health covers all laboratory testing and services related to the diagnosis of COVID-19 with no member cost share.

• Members of our State products (MediSource, Essential Plan, Child Health Plus) must use participating in- network provider for these services. (These products follow specific coverage guidelines).
• However, testing is not covered if ordered or required by a third party, such as: government/public agency to determine community spread, or by an employer for return-to-work or weekly testing, or for school or camp purposes. (Self-funded coverage may vary by plan).

Does Independent Health cover rehabilitative in nature and serve to facilitate (support and ease) the patient’s recovery?

Services which are rehabilitative in nature and serve to facilitate (support and ease) the patient’s recovery to their new normal would be subject to the cost share associated with those services.

What COVID-19 services are covered for Independent Health members?

Independent Health will continue to waive the cost share for commercial, Medicare Advantage and State program members, including commercial HSA-qualified high deductible health plans, until further notice for the following services:

• Care received when ordered by a health care provider as part of a COVID-19 treatment plan.
• In-network telehealth/telemedicine services, whether or not COVID-19 related. For further details, view the coverage grid and policy. Medicare Advantage Members will continue to be responsible for the cost share associated with ancillary services (e.g. dietitians).
• Antibody testing with an order or prescription from a primary care provider. (While CMS regulations do not require a provider’s order for Medicare Advantage members, we encourage providers to discuss the benefit of the test with those members.) View the CDC website and New York State Department of Health websites for guidance and criteria for health care professionals.
• Independent Health covers all services and treatment for our members with no member cost share, including in-person, telehealth, urgent care center, outpatient hospital or emergency room visits when the primary purpose of the visit is COVID-19 testing, diagnosis and treatment.
• This coverage applies until further notice to all fully insured commercial plans (including HSA-qualified high deductible health plans), Medicare Advantage, State Products and Individual plan members.

Coverage for self-funded employer plans varies by employer group.

Is COVID-19 antibody testing covered by Independent Health?

At this time, antibody testing is covered with no cost-share if the test is determined to be medically appropriate by the healthcare provider (see CDC’s Evaluation and Testing Persons for Coronavirus COVID-19 Disease) You may also visit coronavirus.health.ny.gov/covid-19-testing.

The test is covered for Medicare Advantage members with no cost share.

Members of self-funded plans should check with their employer to determine if their group is covering testing.

Members of state products must receive services through in-network providers, which will help ensure they are not billed in error by providers that do not participate with Independent Health.

Where should Independent Health patients go for testing?

Certain testing sites may require a prescription or ask for payment in advance and reimbursement for covered services will have to be submitted and processed by Independent Health. To reduce out-of-pocket cost, we encourage members to use one of the county or State testing sites. These county and state testing locations will not take any cost upfront.

Individuals can make appointments at these testing sites by calling the Departments of Health:

• ECDOH - Call 716-858-2929 to schedule a test (a lab order is not needed). Or visit the County Health Department’s website.
• NYSDOH - Call 1-888-364-3065 to schedule a test (a lab order is not needed)
• View additional testing sites in Erie County here.
• Residents of other counties should call their county health departments

What if COVID-19 or antibody testing is a requirement for going or returning to work?

It is the employer’s responsibility to pay for services they require for their employees, such as the COVID-19 virus or antibody testing.

Do individuals need a prescription or doctor’s order to get tested?

We are requiring our members to obtain an order from their primary care providers in order to determine whether antibody testing is medically appropriate. View the CDC website and New York State Department of Health websites for guidance and criteria for health care professionals. Please note, CMS regulations do not require a provider’s order for Medicare Advantage members, but we encourage providers to discuss the benefit of the test with those members.

What should patients know about the antibody test?

The CDC has advised that antibody tests should not be used to diagnose an active COVID-19 infection. An antibody test may not indicate current infection, because it could take several weeks to make antibodies after symptoms occur.

The CDC has also advised that we do not know yet if having antibodies to the virus can protect someone from getting infected with the virus again, or how long that protection might last. For these reasons, it is important that patients discuss with their primary care provider the value of antibody testing. If the primary care provider orders antibody testing, the patient should follow up with your practice to discuss the test results and what they may mean.

The lab that conducts the test is required to tell individuals:

• If the test has not been reviewed by the Food and Drug Administration.
• False negative results can occur. Someone could have infection not detected by the test.
• False positive results can occur. Positive results may be due to past or present infection with non-COVID-19 coronavirus strains such as the common “cold.”
• Results from antibody testing should not be used as the sole basis to diagnose or exclude COVID-19 infection, or to inform infection status.

What are members told about testing for both the virus and antibody at the same time?

The test to diagnose COVID-19 checks for the virus that causes the illness. The virus is most likely to be detected at the time of active illness/symptoms.

After the virus is present, the body will start to develop an immune response which will serve to fight the virus. This happens through the development of antibodies. The antibodies can take weeks to develop (as few as 2 weeks, but in some cases more than 6 weeks), so testing for active viral infection and antibodies at the same time is not advised.

It is appropriate to wait at least 3 weeks after symptoms started, or 2 weeks after symptoms have cleared up to test for antibodies. If you’ve had a positive diagnostic test, you should wait at least 3 weeks from the time of the positive test to test for antibodies. If you’ve never had symptoms, but think you might have been exposed or been asymptomatic case, you should wait at least 3 weeks from the time of that potential exposure.

Is Independent Health covering and allowing Telehealth and Telemedicine for insured members?

Yes. Independent Health will cover in-network telehealth/telemedicine services, whether or not COVID-19 related. There will be $0 copay or cost-sharing* for members for these services, except for Medicare members, who are responsible for the cost share associated with ancillary services (e.g. dietitians).

We’ve organized important information in the Telehealth Fee Schedule, Coverage Grid, and Policy.

Providers may render services via non-HIPAA compliant technologies such as FaceTime or Skype as permitted by the Department of Health and Human Services Office for Civil Rights.

Additionally, Independent Health is expanding coverage for Primary Care annual well visits. When both audio and visual contact is possible, and in accordance with the guidelines below, annual preventive visits may be performed via telemedicine during the COVID-19 pandemic for all lines of business. When telephone is the only option (audiovisual is not possible), telephone E/M services can be billed business. Refer to Billing Guidelines for Primary Care Telehealth Preventive Visits for more details.

Important Guidelines for Primary Care Preventive Visits via Telemedicine

• Providers should reference their specialty society professional recommendations for virtual preventive visits.
• Providers should only engage in this care delivery when the patient’s conditions and needs can adequately be met, and the service is safe.
• Billing for the services does not require completion of the physical exam during the state of emergency.
• Additional, subsequent preventive visits or well visits should not be billed to Independent Health. In the event a member needs to be brought in later for a specific service, such as immunizations, those services would be reportable and reimbursed.
• Members will not be required to return to the office for a face-to-face visit to “complete” the preventive service done through telemedicine or telephone contact.

Independent Health is reviewing the use of telehealth and telemedicine regularly and will communicate with providers when any adjustments are necessary

*Coverage for self-funded employer plans (see FAQ below), including Nova, varies by employer group.

Is Independent Health covering telehealth and telemedicine for Self-Funded Members?

Self-funded members are administered through Independent Health Self-Funded Services and Nova Healthcare Administrators. Telehealth and telemedicine coverage updates for these members include the following:

• Independent Health Self-Funded Services members

  All employer groups who utilize Independent Health Self-Funded Services to administer health coverage for their employees have elected to cover telehealth services for COVID-19 and non-COVID-19 patient visits with no member liability.

  Self-funded members are identified on the member ID card. The back of the ID card for these members indicates "administered by Nova" near the top. Self-Funded members should contact customer service at 716-631-2661 or 1-800-257-2753 for more information.

• Nova members

  All Western New York clients of Nova, a wholly owned affiliate of Independent Health, have elected to allow telehealth services for all diagnoses under their plans except New York Business Development Corporation .

  While most Nova clients have chosen to apply a member cost share through a standard office visit copay for telehealth services not related to COVID-19, the following clients have waived the member cost share:

  • Jamestown BPU
  • Sheet Metal Workers
  • Uniland

  Nova members are identified by the Nova logo on front of the member ID card. (Lancaster Schools members have an Independent Health Self-Funded Services ID card and the back of the ID card for these members will indicate "administered by Nova" near the top.) These members can call the customer service number on their ID card or call Nova at 716-773-2122 or toll free 1-800-999-5703. or toll free 1-800-999-5703.

What types of visits are covered for Telehealth/Telemedicine?

Most interactions with a patient can be handled through Telehealth/Telemedicine visit for $0 copay or cost-sharing* for members for these services. Providers should only engage in this care delivery when the patient’s conditions and needs can adequately be met, and the service is safe. Some Examples are:

• COVID-19 related needs
• Primary Care Annual Well Visits
• New Patient Visits
• Neuropsychological Testing
• Specialist visits
• Lactation Counseling
• Transitional Care Management
• Remote Monitoring (as long as the specified guidelines are satisfied)

Refer to this Coverage Grid for more information.

There are certain services that require in-person interaction (e.g., immunization administration, specimen collection) and therefore are not appropriate for telehealth at this time.

*Medicare Members are responsible for the cost share associated with ancillary services (e.g. dietitians). Coverage for self-funded employer plans varies by employer group.

Who can perform Telehealth/Telemedicine services?

The following provider types can perform Telehealth/Telemedicine services:

• Primary Care Physician (PCP)
• Specialist Physician
• Registered Nurse (if performed solely by the RN, must be performed while working with a supervising physician and under general supervision)
• Non-Physician, independent billing provider (i.e. Audiologist, CSW, Physical Therapist, Psychologist, Dietitian)

The following provider types can NOT perform Telehealth/Telemedicine services:

• Urgent care center visits are not covered for telehealth/telemedicine at this time. Independent Health encourages member to reach out to their PCP with urgent needs by phone or through telemedicine. Members without PCP's can call Independent Health Member Servicing for available providers.
• Licensing Practical Nurses (LPNs)

Refer to this Coverage Grid for more information.

What is Teladoc®?

Although Independent Health encourages its members to contact their primary care physician for their medical needs, we realize this isn’t always possible. So, when a member can’t reach their primary care practice, Independent Health’s telemedicine benefit is provided through Teladoc®. Independent Health is waiving the cost share for Teladoc services during the COVID-19 outbreak.

Teladoc is not available to MediSource, MediSource Connect, Essential Plan and Child Health Plus members. Coverage for self-funded employer plans varies by employer group.

Can Medicare Advantage Member obtain care from out-of-network providers?

Due to the emergency declaration, Medicare Advantage members may obtain care from out-of-network providers at the in-network cost sharing. For more information, see the page called “Getting care during a disaster.”

What is the difference between virtual check-ins and phone visit codes?

Telephone services are provided only via telephone. Virtual check-ins can be performed via telephone or other telecommunication means (e.g., audio, secure text, use of patient portal).

Another virtual service is a “store and forward” remote evaluation where the patient submits a recorded video and/or images and the provider evaluates, interprets and provides follow-up with the patient within 24 hours.

Does Independent Health cover home health, home infusion nursing, and hospital outpatient therapies virtually?

Yes, Independent Health is covering the following services delivered virtually for all lines of business effective immediately and through June 22, 2020:

• Home Health Services
• Home Infusion Nursing
• Hospital Outpatient Therapies

To track and appropriately apply member benefits for these services when delivered virtually, Independent Health is requesting providers append the following modifiers to each applicable claim line based on how the service is provided:

Service Delivery	Modifier
Telephone: Audio-Only	GQ
Synchronous, Two-Way Audio-Visual Technology	GT or 95
In-Person	n/a

Independent Health is working with providers along with state and federal agencies to determine a possible increase or decrease in the duration of this change, if needed.

Is there any change to current provider reimbursement for home health services, home infusion nursing and hospital outpatient therapies via telephone or two-way audio-visual technology?

No, not at this time.

Should providers continue to submit claims for home health services, home infusion nursing and hospital outpatient therapies?

Yes, beyond the application of the additional modifiers listed above.

Does Independent Health still require concurrent review authorization upon receipt of clinical information for home health services, home infusion nursing and hospital outpatient therapies?

Yes, while notification timeframes are relaxed to ease hospital discharge planning, please continue to notify as close to initiation of care to avoid retrospective denials for medical necessity.

What is the reimbursement rate for Telehealth/Telemedicine visits?

Independent Health has provided a Telehealth Fee Schedule to outline the reimbursement rates for different codes. The same percentage applies to Advanced Practice Practitioners as any other service. Reimbursement for Primary Value providers may be included in the global payment for the applicable lines of business.

If a patient calls in and they are triaged, the billing is based on the cumulative number of minutes performed for that date of service, so it includes the call back from the provider.

The billing is based on the cumulative number of minutes performed for that date of service.

In order to process claims appropriately, the same documentation requirements apply when services are rendered via telemedicine as they are for in-person visits, including:

• Method of Communication
• Start and end times (for time-based codes)
• Patient consent (verbal or electronic), if required
• Completed SOAP notes must be included in the documentation

What POS should be used when Telehealth/Telemedicine visits are being conducted from the office to the patient’s home?

POS 02 should be used for these visits. Independent Health has adjusted how these claims are processed during the state of emergency to pay at the non-facility rate.

What codes are covered for Telehealth/Telemedicine by Independent Health?

Please refer to our Coverage Grid and Telehealth Fee Schedule which detail the codes and reimbursement rates for Telehealth/Telemedicine.

What are the guidelines I should follow for COVID-19 ICD-10 diagnosis coding of claims?

Follow ICD-10 CM Diagnosis Coding guidelines published by CDC to report claims for COVID-19 related services on or after April 1, 2020. Additionally, there is a new diagnosis code for COVID-19 infection. The updated CDC guidance further outlines the appropriate use of the new diagnosis code. For claims with a date of service before April 1, 2020 follow this ICD-10 diagnosis coding guidance. If the CDC makes additional recommendations in the future, please adhere to updated guidance.

What are the changes there for Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) due to COVID-19?

• We are waiving the requirement for a face-to-face visit in order for a member to receive replacement DMEPOS (Durable Medical Equipment, Prosthetics, Orthotics and Supplies) equipment and a telehealth visit with the ordering provider is acceptable.
• We are waiving sleep study requirements for CPAP supplies (e.g., when a member needs an updated sleep study and order from the physician to obtain a new mask for existing equipment)
• We will cover respiratory services for acute treatment of COVID-19.
• We are waiving signature and proof of delivery requirements for Durable Medical Equipment when a signature cannot be obtained due to COVID-19. Suppliers should document in the medical record the appropriate date of delivery and that a signature was not able to be obtained because of COVID-19.
• Delivery receipts will not be exempt from future post payment review
• Independent Health requires an expiration date on any orders and will not extend that for recurring medical supply orders (e.g., oxygen, CPAP supplies).

Is Independent Health still requiring authorizations for Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS)?

Yes. Independent Health is still requiring authorizations for Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) at this time.

Has Independent Health considered waiving all place of service edits that would normally result in a claim denial for Infusion, Respiratory Therapy and DME while a patient is placed in an in-patient facility related to COVID-19?

Independent Health is not making this change at this time.

May I charge my patients for the cost of personal protective equipment our practice is using?

No, health care providers must not charge health plan members for the providers’ use of PPE during in-person visits. Any provider that has charged their patients fees to cover the cost of PPE must refund those patients in full.

Can I temporarily consolidate my practice?

Please email networkoperations@independenthealth.com for requests for any type of temporary practice consolidation or changes.

Is there an impact to my contract if I temporarily close my office?

Please email the Credentialing Department at credentialing@independenthealth.com to discuss options.

Will Independent Health extend the timely filing requirements?

No, not at this time. Independent Health will comply with all published regulatory guidance as it is released.

How can I submit practice data changes and credentialing requests to Independent Health?

Since many provider offices have support staff working from home and may not have access to a fax machine to submit data changes, your practice may also notify Independent Health of any changes that may occur within your practice by email at networkoperations@independenthealth.com. Your practice may also continue to submit data changes by fax.

To check on the status of new provider application or if you would like to credential a new provider for participation, you can email those requests to credentialing@independenthealth.com

Will Independent Health extend the timely filing requirements?

Independent Health will continue to follow regulatory requirements. At this time, there are no federal or state changes issued to the timing of this requirement.

Will Independent Health suspend all audits for at least 6 months to allow us to focus more effectively on emergency activities?

Audit activities are currently being reviewed, but changes have not been communicated at that time.

Will Independent Health extend the appeal deadlines beyond current requirements?

Independent Health will continue to follow regulatory requirements. At this time, there are no federal or state changes issued to the timing of this requirement.

Will Independent Health require providers to add their home address as a practice location to each of their profile? Or, will there be any other requirements?

No, this is not required.

What should I do if I am having trouble obtaining personal protective equipment for my practice?

The NYS DOH has developed guidance for county health departments to uniformly be able to dispense PPE. If your practice is having trouble obtaining this equipment from your normal sources, please see the attached guidance. Please be considerate in your requests for these scarce items by only ordering when you are in need and requesting stock appropriately.

All local county health departments have requested that your practice contact them directly for assistance as follows:

• Erie County has the following email process:
  Email: esf8@erie.gov
  Include practice name, 24-hour contact phone number, type of clinic, location(s), and items needed, including quantity.
• Niagara: (716) 438-3171
• Orleans: (585) 589-3278
• Wyoming: (585) 786-8890
• Allegany: (412) 687-2243
• Genesee: (585) 344-2580
• Cattaraugus: 1 (800) 251-2584
• Chautauqua: 1 (866) 604-6789

Please note: a previous related notification from Howard A. Zucker, MD, JD, Commissioner of Health, NYSDOH, with additional information is available here.