NYS Council Summaries re: SOMH Documentation and Billing Guidance Webinars

April 16, 2020

Today, the Office of Mental Health held a series of webinars related to newly issued documentation and billing guidance for certain OMH programs during this time of the COVID-19 emergency. We have brief notes from each of the webinars, outlined below. MCTAC promises to post the webinar recordings on their site soon, along with an FAQ document based on questions submitted during the webinars. Any other questions can be sent to the email box: transformation@omh.ny.gov. 

All of the presentations emphasized the following:

  • The new guidance for billing during the COVID-19 emergency is meant to sustain providers at an average level, allowing them to continue operations without staff cuts or salary reductions
  • The intent is to maintain services for individuals, and provide additional support as needed during this emergency, maintaining quality and continuity of care
  • If there are providers who demonstrate a marked increase in revenue, the State reserves the right to review those providers on a case by case basis, as it is not anticipated that the new billing rules will substantially increase revenue, but will allow providers to maintain income at an historical level
  • COVID-19 disaster emergency billing modifiers are required to appear in the claim if billing under the new guidance
  • If the contacts with the client meets routine as well as COVID-19 emergency requirements for billing, it’s OK to bill at the higher rate
  • Billing changes are effective March 2020, so billing can be revised and resubmitted for contacts as of March 7, 2020. Ensure that revised standards for contacts are met, and that documentation reflects this
  • Service plan (treatment plan) updates can be postponed, and there is no need to revise a service plan to reflect contacts that are focused on COVID-19-related concerns. The documentation should reflect that COVID-19 related concerns were discussed and that this was the need of the client
  • Updated service plans are likely to become due close to the discontinuation of this guidance, after the emergency has passed, however no decision has been made about exactly when the updated service plan will be due
  • Efforts should be made to ensure that every individual has a list of important phone numbers, local resources, and a step-by-step plan for contacting appropriate stakeholders
  • This is a good time to review and update individual crisis plans

ACT Program and Billing Guidance Regarding COVID-19 Emergency Response

  • Telehealth guidance indicates that a contact can be five minutes to count as a billable service
  • If the only contact for a client is a collateral contact, it can be submitted for partial billing
  • Full billing can include three contacts, one of which can be a collateral contact
  • No changes have been made in what is considered to be a collateral contact
  • If a client is admitted to inpatient, the same guidance applies

OMH-Licensed Personalized Recovery Oriented Services (PROS) Programs

  • Clinic treatment services (Medication Management and Counseling) must continue to be provided 1x month
  • Continued new program admissions are vital
  • Consents can be obtained telephonically
  • In/Out times for program services should be recorded
  • Should produce an Immediate Needs Plan as usual on the date of admission for new clients
  • Include Relapse Prevention for clients who require this–no plan amendment is required, just document appropriately

OMH-Licensed Continuing Day Treatment and Partial Hospitalization Programs

  • CDT programs must make a minimum of five telephonic outreaches per week, at least one per day, with continued documented efforts to reach those who are difficult to reach
  • Additional services that were not already documented in the treatment plan should be documented in a progress note and approved by a physician as soon as possible during or after the disaster emergency
  • Treatment plan timeframes are waived, and signatures can be obtained verbally and documented in the record
  • The full day rate code can be used for any contact with the individual of at least five minutes
  • Unsuccessful outreaches/or if the outreach is less than five minutes can be billed at the half day rate
  • Partial Hospitalization programs–assessments and service plan should be completed to the extent possible
  • Verbal consent for the plan should be documented
  • Providers may use the six-hour rate code for any contact with the individual of at least five minutes

Children’s Day Treatment Programs

  • A minimum of five telephonic outreach efforts should be made to every program participant, at least once per day
  • Psychiatry services or NP medication management, for those receiving it, must be provided at least once monthly. This can be done telephonically
  • OMH’s expectation that admissions remain open does NOT apply to Children’s Day Treatment programs when schools are closed
  • The time of day of outreach does not matter for billing purposes, which may help in families where parents are working 
  • Any state and federal guidance about HIPAA privacy and telehealth applies to these contacts
  • Child Day Treatment Program guidance does not consider the billing and particulars for the educational part of the program, which is governed by the State Education Department