NC DHHS Puts More Detail on Regulatory Flexibility: Telehealth is Key

For many years North Carolina has been slowly including telehealth in the service system. As NC DHHS leaders have said on several recent webinars, our State has made more movement to embed telehealth in the past two weeks than in the past 10 years. To point, many of the recently announced temporary regulatory flexibilities are focused on telehealth. These flexibilities in Medicaid services have been possible through the federal approval of an 1135 Medicaid waiver that was received on March 23rd. Temporary waivers to in-person treatment will remain in place as long as the State of Emergency is in effect.

Most recently, NC DHHS published a Joint Communication Bulletin stating that the flexibilities put in place through the Medicaid 1135 waiver are extended to State funded services—to the extent that funding is available. NC DHHS has made the temporary waiver provisions retroactive to March 10th for both Medicaid and State funds.

A synopsis of the 1135 waiver and the telehealth approach was included in an earlier article i2i published. Continuing with the staggered start plan (noted in that article) for telehealth:

· NC DHHS operationalized procedure codes for medical, clinical pharmacist, and some behavioral telehealth, including diagnostic evaluation and psychotherapy and assessment codes, as of March 23rd.

· On March 30th, intensive in-home services, multisystemic therapy, mobile crisis management, Assertive Community Treatment, Community Support Team, Peer Support Services, specialized therapies like physical therapy, dental and telehealth procedure codes went into place.

· No later than April 7th procedure codes will be activated for CDSAs, LEAs, optometry, registered dietetics, diabetes educators and more behavioral health services.

Expanding professionals qualified for telehealth services:

Eligible telepsychiatry providers are being expanded to include the following associate level providers:

· Licensed clinical social worker associate (LCSW-A)

· Licensed clinical mental health counselor associate (LCMHC-A)

· Licensed marriage and family therapist associate (LMFT-A)

· Licensed clinical addiction specialist associate (LCAS-A)

Additionally, NC DHHS is expanding the types of professionals that can provide telehealth through Federally Qualified Health Centers (FQHCs) and Rural Health Centers (RHCs) to include: clinical pharmacists, licensed clinical social workers

(LCSWs), licensed clinical mental health counselors (LCMHCs), licensed marriage and family therapists (LMFTs), licensed clinical addiction specialists (LCASs) and licensed psychological associates (LPAs).

Other new temporary changes to regulations include: · NC DHHS is refining the Amendment K that is related to the 1915(c) home and community-based waivers. They are awaiting final approval from CMS but were directed to move forward with the Amendment K provisions. These refinements are listed in a chart and include easing requirements in the Innovations and TBI Medicaid waivers, CAP/CA and CAP/DA programs.

• Pharmacy modifications have been operationalized to allow for:

early refills and extended supplies;

• inhalers to be moved to the preferred drug list to ensure availability due to a nationwide shortage.

• Blood pressure devices will be covered by Medicaid for individuals who can benefit from home monitoring.

• Medicaid rates for long-term care providers were increased by 5%.

• Medicaid rates for services managed by LME/MCOs were increased by 1.5%.

NC DHHS has partnered with NC AHEC and CCNC to offer healthcare providers webinars and materials. Every Thursday through April 30th from 5:30 p.m. to 6:30 p.m. there is a webinar to give providers updates.