As families face immense stress from the pandemic, states have rapidly reworked their home visiting programs to continue to support women and children. Because face-to-face services, including case management and family support and counseling, are no longer an option, health departments now deliver these vital services by telehealth. But with this new operating platform, states have needed to quickly address issues such as privacy requirements and billing, reimbursement, and enrollment processes as they launch their telehealth services.
Recently, the Centers for Medicare & Medicaid Services (CMS) released a toolkit in response to COVID-19 with guidance and steps for state Medicaid programs as they transition services to telehealth. The updated CMS guidance allows for greater flexibilities, including reimbursement for telephonic visits. To streamline the process, CMS stipulated that “no federal approval is needed for state Medicaid programs to reimburse for telehealth services in the same manner or at the same rate paid for face-to-face services, visits, or consultations.” However, a state plan amendment (SPA) is necessary to accommodate any revisions to payment methodology to account for telehealth costs.
Additionally, the Office of Civil Rights at the Department of Health and Human Services issued guidance that allows for enforcement discretion for noncompliance with the Health Insurance Portability and Accountability Act (HIPAA) regulatory requirements related to providers and telehealth, such as using non-HIPAA-compliant systems, such as the free version of Zoom.
How Michigan Converted its Home Visiting Service
Michigan, a state with a robust home visiting program prior to COVID-19, took quick action to support home visiting staff and the families they served to ensure continuation of services during the pandemic. The Maternal and Infant Health Program (MIHP) is administered and financed by the state Medicaid agency and is the largest home visiting program in the state. MIHP is available to all pregnant women enrolled in Medicaid and their infants up to age 12 months, with some exceptions. The program promotes healthy pregnancies and positive birth outcomes through a standardized, systemwide process of case management. When Michigan Gov. Gretchen Whitmer announced a state of emergency and stay-at-home orders in March 2020, the program quickly moved its home visiting services to telehealth.
The Michigan Department of Health and Human Services (MDHHS) updated guidance on telehealth visits for Medicaid beneficiaries. The provider bulletin allows for greater flexibilities on distant and originating sites and outlines the billing codes and modifiers providers should use. The MIHP operations team took numerous steps to ensure a smooth transition to telehealth services for their providers and families, including:
- Both the state Medicaid agency and the MIHP operations team had early and continued communication with providers, including making staff available to answer questions and provide support.
- The MIHP program created additional guidance specifically for MIHP providers. The guidance includes instructions on how to obtain and properly document verbal consent, billing procedures and codes specific to the MIHP program, and documentation procedures for all virtual visits.
- MDHHS held a provider webinar with detailed information related to telemedicine flexibility, including information targeted to MIHP providers and others.
- MIHP operations conducted a provider survey about how MIHP programs were continuing to provide services during this time, which netted a near 100 percent provider response rate. The survey revealed that a large majority of agencies adjusted successfully and quickly to the telehealth service delivery model. In addition, only a small number of agencies suspended services temporarily, primarily due to agencies shifting resources to cover COVID-19 emergency functions.
As states begin to reopen, many home visiting programs will begin to consider returning to face-to-face visits exclusively or as a part of their support programs. Considerations for the role of telehealth in home visiting is expected to factor into state decisions. While it is unclear how state home visiting programs will transition, some groups including The National Alliance of Home Visiting Models have encouraged all home visiting programs to continue to use telehealth to ensure the safety of women and their families, as well as home visitors. With the greater flexibilities allowed by CMS, states have the option to continue using telehealth for their home visiting programs during the pandemic. This allows for the continuation of important services for women and children and helps decrease the spread of COVID-19.
States will be weighing a number of considerations as they begin to open, including the benefits of telehealth for home visits and the costs associated with telehealth compared to in-person visits. These new policies will be important to monitor and will have implications for longer-term and possibly permanent use of telehealth to deliver essential services to families.
- NASHP Infographic: How State Medicaid Programs Can Use Telehealth to Serve Pregnant Women during COVID-19, May 2020
- NASHP Blog: States Rapidly Build their Telehealth Capacity to Deliver Opioid Use Disorder Treatment, April 2020
- Institute for the Advancement of Family Support Professionals: Rapid Response Virtual Home Visiting Collaborative