Managed Care

Texas Medicaid managed care organizations (MCOs) must provide all medically necessary, Medicaid-covered services to eligible clients. Administrative procedures such as prior authorization, pre-certification, referrals, and claims/encounter data filing may differ from traditional Medicaid (fee-for-service) and from MCO to MCO. Providers should contact the client's specific MCO for details.

Effective Dates

Effective for dates of service March 15, 2020, through April 30 2020, authorized occupational, physical, and speech therapy for clients of all ages may be delivered as a telehealth service.

Telehealth therapy services must be delivered within the provision of current licensure requirements found in Occupational Therapy Rules, Physical Therapy Rules, and Speech-Language Pathologists and Audiologists Administrative Rules. See Texas Medicaid for more information.

Modifiers

Providers should use the 95 modifier to indicate remote delivery. Providers are reminded to use the required modifiers GP, GO, and GN on all claims for physical, occupational, or speech therapy treatment.

Prior Authorization

There will be no changes to the prior authorization submission process. A separate prior authorization is not needed solely to allow for the remote delivery of therapy services.

Evaluations

Evaluation, re-evaluation, and treatment may be delivered via telehealth as determined clinically appropriate by the rendering therapist and in compliance with each discipline’s rules.

Assistants

Therapy assistants may provide telehealth and receive supervision within limits outlined in each discipline’s rules. Providers should refer to state practice rules and national guidelines regarding supervision requirements for each discipline. See Texas Physical Therapy Assistants or Texas Occupational Therapy Assistants.

Informed Consent

Telehealth requires consent from the client or responsible adult. Verbal consent is permissible and should be documented in the client’s medical record. Teletherapies may require participation of a parent or caregiver to assist with the treatment.

Services that Cannot be Performed via Telehealth

Clinical evaluations required for the provision of new complex rehabilitation technology, such as power mobility and adaptive seating systems or augmentative  communication devices, require the physical presence of the speech-language pathologist, the occupational therapist, or physical therapist and should not be delivered via telehealth unless exceptional medical circumstances exist.

Treatment Notes

Treatment notes should indicate that remote delivery of the service is clinically appropriate per the treating therapist’s professional judgement.

HIPAA

The Office of Civil Rights (OCR) has relaxed Health Insurance Portability and Accountability (HIPAA) requirements to allow for the use of additional video capabilities to deliver service via telehealth. Texas Medicaid will recognize OCR’s HIPAA enforcement discretion as it relates to telehealth platform requirements.

Reference

Claims for Telehealth Service for Occupational, Physical, and Speech Therapy. April 14, 2020 available at http://www.tmhp.com/News_Items/2020/04-April/04-14 20%20Claims%20for%20Telehealth%20Service%20for%20Occupational,%20Physical,%20and%20Speech%20Therapy.pdf