APD COVID-19 FAQ

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Provider Questions and Answers

Visitation

• Are there restrictions on visitors entering facilities?

Yes. To protect the health and safety of residents in a long-term care facility, group home setting, or Institutional Care Facility (ICF), visitation in these living settings has been suspended with few exceptions. See Emergency Order DEM 20-006 for more information.



• Can Waiver Support Coordinators minimize face to face contacts?

Yes. Providers should employ alternative forms of communication such as telephonic or video conferencing in lieu of in-person visits. Please refer to the March 13, 2020 waiver support coordinator (WSC) Advisory for more information: https://apd.myflorida.com/waiver/docs/WSC%20Advisory%202020-009%20COVID-19%20and%20Consumer%20Contact%20Requirements.pdf.

In addition, support plans and waiver eligibility worksheets can be completed telephonically temporarily. Once the in-person visits are reinstated, WSCs should conduct a visit in recipients’ homes to assess the safety of the living environment.



• Are family members able to visit their loved one receiving services in a facility setting? What if the family member wants to take their loved one home or for an outing during this public health emergency?

Emergency Order DEM 20-006 allows family visits in the facility only in the case of end of life situations. If the family wants to take their family member home or for an outing during this time, they may do so. However, it is strongly discouraged. Prior to being allowed to reenter the group home or ICF, the person must pass the pre-screening questionnaire.

Community Integration

• Can a companion worker take a resident of a group home into the community?

This is strongly discouraged. Prior to being allowed to reenter the group home after a community outing, the resident must pass the pre-screening questionnaire.

Site Visits

• Will APD staff still be conducting monthly monitoring visits in APD licensed foster/group homes?

APD monitoring staff will be completing monthly group home visits remotely during this time.



•  NEW  Does the Governor’s Phase 1 plan mean that group home residents can now go on home visits and outings with family members but should still be screened for COVID-19 upon returning to the home?

The Phase 1 plan continues to restrict visitors into the group homes.

Flexibility of Waiver Services

• Will APD work with providers on staffing levels required by licensure if they experience a significant shortage in staff due to illness.

APD and AHCA are requesting flexibility with federal requirements to address this.



• For group/foster home residents under the age of 21 who are out of school, can companion services be provided in the licensed home while out of school?

No. At this time companion services can only be authorized for individuals if they are 21 or older.



• Can a therapist do telehealth visits for Medicaid waiver clients or CDC+? If so, would they charge the same rate or what would the rate be? Will the provider need an authorization modifying it as a telehealth visit?

iBudget Waiver providers should deliver telemedicine iBudget waiver or CDC+ services following the same guidance regarding telemedicine as was sent out by AHCA in the Medicaid Provider Alerts on March 18, 2020 and can be found on AHCA’s COVID-19 webpage. Providers should deliver waiver services in the home whenever possible and only utilize telemedicine if:

Services cannot be delivered because the center is closed (when services are delivered in the center) and home-based care is not an option; or

The provider and/or the recipient meet one or more of the self-screening criteria for COVID-19 in accordance with the Department of Health guidelines and services cannot be delivered in the home.

Additional prior authorization is not required for transitioning a service to a telemedicine modality. Services provided via telemedicine will be paid at the current service rate.



• Since behavioral services require that 75% of their time be face-to-face, can this be waived or reduced so more frequent phone calls can be made between behavioral staff and GH/PS/SLC staff?

iBudget Waiver providers should deliver waiver services via telemedicine following the same guidance that was sent out by the AHCA in the Medicaid Provider Alerts on March 18, 2020 and can be found on AHCA’s COVID-19 webpage. We are asking providers to provide waiver services in the home whenever possible and only utilize telemedicine if:

Services cannot be delivered because the center is closed (when services are delivered in the center) and home-based care is not an option; or

The provider and/or the recipient meet one or more of the self-screening criteria for COVID-19 in accordance with the Department of Health guidelines and services cannot be delivered in the home.

Providers MUST perform all service components designated in the iBudget Waiver Handbook for the procedure code billed and be appropriately reflected in the individual service plan.



• Will background screening requirements be lifted during the pandemic to allow providers to maintain staffing ratios? Some Live Scan facilities are closing.

AHCA released guidance on March 28, 2020 that provides information on flexibilities surrounding background screening. When a criminal background check is required, a provider must first review the Clearinghouse Results Website to verify if the candidate has a current Level 2 screening. If the candidate does not have a current Level 2 screening or the provider is not able to initiate an Agency Review or Resubmission on the candidate in the Clearinghouse Results Website, then the provider must make every effort to find a Livescan Service Provider that will process fingerprints for a Level 2 screening. The alert also describes the process providers should use to handle cases where the candidate is not in the Clearinghouse and they are unable to initiate Level 2 screening due to the inability to access a Livescan site to be fingerprinted.

This information can be found on AHCA’s COVID-19 webpage at http://ahca.myflorida.com/covid-19_alerts.shtml. Under “Facility Information,” it is titled “Health Care Provider Background Screening.” The web page provides the most up-to-date information about the flexibilities we are enacting to ensure our recipients continue to receive services and the ways the Agency is responding to the needs of the community



• Since many ADTs have closed, will the residential habilitation providers be able to bill at an enhanced rate or would they have to have a service authorization for ADT?

Residential habilitation is considered a 24-hour a day service. Residential habilitation providers will not be paid at an enhanced rate for individuals remaining in the home in lieu of attending ADT. However, ADT providers may render the ADT service at an alternate setting such as a group home.



• There is a concern about the timeline for implementation plans and this is a recoupment issue. Will support plans be issued during this time period? If so, will implementation plans have to be implemented within 30 days of receipt?

The State will allow for the use of telephonic support plan development for any plans that expire during the emergency period. If telephonic or video conferencing is unavailable, extensions will be granted. Upon receipt of the support plan, the expectation is the implementation plan would be developed using similar methods, if required, within the established timeframes.



• Will timelines for quarterly and annual reports be waived or extended during this time period?

Yes. The State has requested federal flexibility on waiver reporting requirements. Providers should consult with APD to determine which reporting deadlines have been waived or extended.



• APD offices around the state are closing but some are still planning for the BCBA to hold LRC? Can the reviews be extended?

All LRC meetings are being held telephonically for the duration of the emergency. It is strongly recommended that each provider contact their LRC Chairperson to clarify proper submission of documents (including behavior plans and data) within HIPAA encryption requirements.



•  NEW  Will APD be issuing new authorizations for April through June for providers that keep the advanced payment? Some service authorizations provide a quarterly allocation with units of service listed for each month (e.g. ADT, Companion, quarter hour Personal Supports, etc.), but available for use in any month for the quarter. Does this mean a provider who only accepts the payment in April, could then bill the entire quarterly allocation on either of the two remaining months (i.e. May or June)?

APD will not be issuing new authorizations for the last quarter of the cost plan year ( April- June). Providers not accepting the retention payment should bill in accordance with service provision identified in the notes section of the authorization based on the consumer’s needs. If a consumer needs a different service arrangement or selects a different provider, the WSC will work with the consumer to update the cost plan and changes in service authorizations will be issued to the providers.



•  NEW  Can you verify that APD is allowing the ADT services like LSD-3 to be converted to LSD-1 as a temporary resolution to allow Group Homes the ability to care for clients, by billing for this service?

The Appendix K, submitted to CMS for approval, allows flexibility in the location where services can be provided. As an example, ADT services ( LSD3) or Companion services ( LSD1) can be rendered in the group home. If a client requested a change in service due to COVID-19 and selected the group home provider to render the service, the group home provider could render and bill for LSD1 if the group home operator has an authorization to render the service. Additionally the group home provider and would also have to ensure that this service is not duplicating the current residential habilitation services. As a reminder, providers who accept the retention payment may not also bill for the service for which the retention payment is received.



•  NEW  Are providers able to deliver necessary services, that normally require client participation, without the client to assure their health and safety during the COVID-19 crisis (e.g. grocery shopping without the client as a service under Supported Living)?

Supported Living services do currently allow for a supported living coach to conduct tasks on behalf of the person when the person is unable to participate such as getting groceries, picking up prescriptions, paying bills. However when a coach is conducting activities on behalf of the person, the person should be involved as much as possible. For example, if the coach will be grocery shopping on behalf of the person, the person should be actively engaged, via phone conversation, in deciding what grocery items will be purchased. As a suggestion, groceries may be able to be ordered online with involvement of the person and picked up by provider, thereby saving time.



•  NEW  Can you please confirm that there will not be recoupment for providers accepting Advanced Payment unless the provider also bills for those same services for the month in which and for which they received an Advanced Payment? This remains a concern for some providers based on language describing recoupment in the Alerts pertaining to iBudget Provider Payment Flexibilities.

AHCA has verified that recoupment will only occur if a provider accepts the retention payment and bills for the service for which the retention payment is received.



•  NEW  Does the testing of staff in LTC recently announced by the Governor, include staff in Group Homes or other residential settings? This is definitely a need and would be welcomed by providers.

Currently there are no requirements for across the board testing for group home staff in APD licensed homes who have not been directly impacted by the COVID-19 disease. However, the Department of Health will immediately visit a group home if a resident or a working staff member show symptoms of COVID-19. If DOH finds a positive case, they will test everyone in the group home.



•  NEW  Can iBudget be amended for additional services when needed to address the client’s needs, including those related to health and safety during the COVID-19 crisis?

As with any service need, if additional needs arise, the individual will need to work with the waiver support coordinator to accommodate additional needs.



•  NEW  Will APD provide guidance that directs facilities to temporarily suspend services until COVID-19 is ruled-out or the person has demonstrated recovery, each by testing during the reopen phases?

The Agency for Health Care Administration has implemented an Emergency Rule to ensure that individuals who are hospitalized as a result of COVID-19, are not discharged back to the facility until the individual has had two negative test results in no less than 24 hours from each other. This will assist the residential programs in reducing the spread of the disease. As positive cases are identified involving individuals who live in licensed homes or have staff who test positive, the facility must immediately make contact with the local county health department for guidance.



•  NEW  Can providers hire new people to work in BF/ IB homes if they have not had Initial training/certification in Reactive Strategies?

If Behavioral homes hire additional staff in the homes during the COVID-19 crisis and are unable to obtain Reactive Strategies training prior to hire, the home will need to ensure that there are sufficient staff on each shift who are certified in reactive strategies. New hires should not be allowed to use reactive strategies without having prior training and certification.



•  NEW  If any of the Behavior Analysis Services, which are wrapped into the IB Residential Habilitation rate, are provided via telemedicine, does this need to be documented?

Yes, the type of service delivery should be reflected in the provider documentation.



•  NEW  Page 14 of the Guidance document references Flexibility in Staffing Ratios. Is this just for those ratios that are rendered at 1:10?

This flexibility was included in the Appendix K for those limited circumstances where the provider could not meet the staff ratio requirements specifically due to COVID-19. It is not restricted to the 1:10 ratio.



•  NEW  If a provider is authorized to render services at a 1:3 ratio but due to staff shortages related to COVID-19, can only render it at a higher ratio, would the provider need to get a new service authorization?

No, the provider would not need to get an adjusted service authorization.



•  NEW  Page 14 – The Guidance indicates providers should be “case noting” why they are not providing service to some clients. A provider wants to know if one case note indicating the ADT is closed in response to the COVID-19 pandemic is acceptable? The provider is regularly calling clients to check on them and case noting these contacts but wants to know if a case note indicating the ADT was closed on a particular date is acceptable when there was no client contact?

Per the Agency for Health Care Administration, yes, this would be acceptable.



•  NEW  Page 14 – The Guidance indicates providers must submit documentation to the waiver support coordinator for those services that continue to be delivered and submit case notes for clients not receiving services with an explanation of why services were not rendered.. What is the APD expectation regarding documentation of services provided/not provided under the iBudget Flexibility process related to amount of time services are being rendered?

If the provider is accepting the retention payment and is providing documentation of services being rendered to the client, the provider should reflect the date the contact was made, and description of the service rendered. Providers who are rendering and billing for the service should provide the same documentation as reflected in the iBudget Handbook.



•  NEW  Will there be an expansion of the 25% limitation on indirect hours allowed for behavior analysis services during COVID-19?

No.

ADTs

• Will APD require ADTs providing services to more than 10 individuals to close?

Not at this time. If ADT providers are required to close, we will allow ADT services to be provided in other settings.

AHCA will be making advanced Medicaid payments to ADT providers to help address the financial hardship sustained during this state of emergency. Please refer to the iBudget Provider Payment Flexibility provider alert distributed by the Agency dated March 18, 2020 for more information.



• What are ADTs to do if a person gets sick while at the ADT and the group home refuses to pick them up citing no staff to work during ADT hours?

Group homes are required to have adequate staffing to meet client needs. Notify the APD Regional Operations Manager immediately for incidents of this nature.



• If ADT programs are closing and the person will be remaining in his/her own home with personal supports, how could additional hours be authorized?

The provider should work with the client’s waiver support coordinator to shift any available unallocated funds to cover the additional hours needed.



• If ADT programs wish to temporarily close to reduce the potential spread of the virus, are they required to give a 30-day notice?

No. ADT programs who wish to temporarily close do not need to give a 30-day notice. However, the ADT should work with the individuals’ WSCs so that alternative services can be arranged.



• Can closed ADT programs be considered as possible quarantine sites for group home residents who become infected with COVID-19?

This may be considered as an option should that become necessary.



• Can providers offer offsite ADT, virtual ADT, or have staff work at home providing client oversight and still count this as ADT services provided?

ADT may be provided off site but cannot be provided via telemedicine. ADT may also be rendered in alternative settings, including in the group home or the individual’s own home.



•  NEW  What are ways that Adult Day Training providers can have flexibility while delivering services to clients during the COVID-19 pandemic?

As described in the iBudget Provider Payment Flexibility provider alert that was issued by AHCA on March 18, 2020, the AHCA and APD recognize the financial impact that COVID-19 may have iBudget Waiver providers. In response, AHCA began making monthly advanced payments to certain types of iBudget waiver service providers, including ADTs, on April 1, 2020.

These advance payments are intended to keep providers fiscally solvent and their workers employed during the pandemic. ADT providers who accept these payments are encouraged to continue delivering services and use flexibility in their service delivery. Some flexibilities may include providing the service in alternate locations or through alternate delivery methods, such as video interactions, offering virtual programming, wellness calls, or conducting home visits if legal representatives allow and precautionary measures are taken e.g., face masks and/or gloves). Providers may not submit claims for those services in which a retention payment is received.



•  NEW  If an Adult Day Training provider is not accepting a retention payment, what are some best practices with service delivery?

If the ADT provider is not receiving an advance payment, ADT services should be provided per the service authorization, but may be provided in alternative settings. For example, ADT may be provided in the group home, family home, or other locations.



•  NEW  Can Adult Day Training providers deliver other services to clients?

Yes. ADT providers may deliver any waiver services they are enrolled to provide when chosen by the client. For example, if an ADT provider is also enrolled to provide Life Skills Development Level 1 – Companion services, the WSC can work with the provider to obtain a service authorization to render the Companion services.



•  NEW  Is the Agency going to give the ADTs guidelines to follow for reopening the ADTs that chose to close?

Response: Phase 1 of the Governors’ orders state that businesses may open up at 25% occupancy. If the ADT wishes to open back up, the ADT should ensure compliance with the Governor’s 25% occupancy orders, ensure that proper distancing is maintained and that those in attendance wear masks. Additionally, the facility should ensure that they follow sanitation protocols, take daily temperatures of all attendees prior to entering the facility and continue to use the visitor checklist.

Financial Hardship

• If facility programs are required to close, providers indicate their business risk insurance will likely not cover the expenses they will incur, such as staff salaries, during the time they cannot bill for services. Are there emergency funds to assist with this loss?

The State of Florida is exploring potential options for affected businesses. Providers are encouraged to complete the Business Damage Assessment Survey at www.floridajobs.org.

Providers may also want to consider applying for an emergency small business loan authorized by Governor DeSantis. For more information, providers should contact the Florida Small Business Development Center Network at (866)-737-7232 or via email Disaster@FloridaSBDC.org.

In addition, AHCA will be making advanced Medicaid payments to certain iBudget providers to help address the financial hardship sustained during this state of emergency. Please refer to the iBudget Provider Payment Flexibility provider alert distributed by the Agency dated March 18, 2020 for more information.



• Can providers bill more frequently than once per month? This would assist with cash flow to handle additional protective and infection control costs and other support services that may be needed.

Services that can be billed more frequently include quarter hour and daily services. Services must be billed in accordance with the approved service authorization.



•  NEW  Can Appendix K or other relief include Hazard Pay for DSP to assure staffing for our at risk and vulnerable populations that reside in Group Homes?

The Appendix K allows for retention payments for providers of specific services but does not include a provision for Hazard Pay.



•  NEW  As the COVID-19 crisis is expected to continue into the summer, will Advanced Payments for ADT, Residential Habilitation and Personal Supports also be provided in June to assure the health and safety of vulnerable populations?

Per AHCA, retention payments will continue in June.

Supplies

• When will assistance be available to assist providers in obtaining protective and cleaning supplies considering these items are being rationed and in some cases such as barrier gowns are not available?

The entire country is struggling with an extreme shortage of personal protective equipment (PPE), including masks. Please attempt to use your existing supply chain to order any needed masks and other PPE. The County Emergency Operations Center (EOC) is a resource to obtain necessary supplies in an emergency. Although counties do not have excess supplies at this time, if you have not submitted a request already, you can submit a request to your County EOC. This will help to inform the statewide prioritization of supplies as they arrive in Florida.



•  NEW  Has APD, AHCA or another entity provided direction to the DOH and/or the EOC that Group Homes be prioritized for receipt of PPE ?

APD has continued to advocate for PPE for APD licensed homes. APD’s current requests from group/foster home operators of the number of residents and staff in each home is to communicate to the county Departments of Health of the PPE needs in these settings. However, each home should personally contact local Dept. of Health to communicate PPE needs as necessary.

Safety Protocols

• If a client is exposed to or contracts COVID-19 what protocol should the facility take before the person is able to return?

Providers should follow the CDC guidelines and protocols published by the Department of Health. They are providing the most up-to date information as the situation evolves.



• Should individuals be allowed to continue using the coordinated transportation provider for trips to the Adult Day Training program?

Yes. Non-emergency transportation providers have been advised to follow safety precautions to reduce the spread of the virus.



• If a provider staff person provides care to an individual who is under quarantine, can they also render services to others?

Providers should follow the CDC guidelines and protocols published by the Department of Health. They are providing the most up-to date information as the situation evolves.



• If a client has symptoms of a cold or respiratory infection, i.e., a cough, runny nose, or fever, should they be tested for COVID-19?

Providers should follow the CDC guidelines and protocols published by the Department of Health. They are providing the most up-to date information as the situation evolves.



• What are the protocols for dealing with a behaviorally complex client who has been exposed to the COVID-19 virus and requires hands on interventions?

Providers should follow the CDC guidelines and protocols published by the Department of Health. The provider should follow reactive strategies procedures and the client's behavioral treatment plan. Learn more from the CDC:

• Personal protective equipment (PPE): https://www.cdc.gov/coronavirus/2019-ncov/hcp/respirator-use-faq.html
• How to protect yourself: https://www.cdc.gov/coronavirus/2019-ncov/faq.html#protect



• What protocol should a service provider follow when there is concern about entering a client's residence?

The service provider should notify the Waiver Support Coordinator with their concerns. If you have clients with fever and respiratory illness, consider rescheduling non-essential appointments. Also, recommend to the client that they contact their doctor. This general approach can help prevent the spread of disease to others.



• Are providers allowed to continue to render services during this virus outbreak?

Yes, it is of utmost importance that recipients continue to receive critical services. Providers should follow self and client screening protocols published by the CDC and DOH prior to entering a client’s home.



• What are the temporary living options for a client receiving residential services who tests positive for COVID-19?

Providers should continue to follow the CDC guidelines and state regulatory facility guidance related to handling individuals with a positive COVID-19 diagnosis. The Agency has developed a web page to respond to questions and concerns related to COVID-19 at http://ahca.myflorida.com/covid-19_alerts.shtml. The web page provides the most up-to-date information about the flexibilities we are enacting to ensure our recipients continue to receive services and the ways the Agency is responding to the needs of the community

Timelines and Deadlines

• Can recertifications for reactive strategies be extended?

Per APD Emergency order 20-01, the recertification deadline is suspended and tolled for a period of 30 days from the end of the state of emergency.



• Is APD willing to grant an extension on medication validations?

Per APD Emergency Order 20-01, revalidation assessments of medication administration which expire during the state of emergency are suspended and tolled for 60 days after the state of emergency



•  NEW  AHCA has stated that APD will provide the determination for waiving or extending quarterly and annual reports.

The reference to the State requesting federal flexibility on waiver reporting requirements refers to APD’s quarterly performance measures reports and not quarterly and annual reports required for certain waiver services. The quarterly reports are important as they assist the support coordinator in ensuring services are being rendered as outlined in the support plan. The annual report, completed at the time of the 3rd quarter, is actually a summary of that quarter and the annual summary and is critical for the development of the person’s annual support plan. Support planning activities have not been waived during this time.



•  NEW  Qlarant Desk Reviews still require providers to collect information from various places and upload the documents, which is very labor intensive. Can reviews be repurposed so these individuals instead share information or resources to support the health and safety of individuals, to identify any unmet needs and help providers address needs?

Qlarant has implemented new procedures to conduct PDRs and PCRs due to the COVID-19 event which includes cutting the review period in half and suspending the citation of billing discrepancies. On a case by case basis, if a provider who is scheduled to be reviewed indicates it is significantly impacted by the virus, it is to let the Qlarant reviewer know. The reviewer may postpone the review after consultation with the regional office. Updates on the review process can be obtained on the Qlarant website at https://florida.qlarant.com/covid-19-update.html.

Testing

• What is the availability of free testing for provider staff and clients?

Medicaid is covering the cost of testing for individuals enrolled in Medicaid. Contact your primary healthcare provider or your County Health Department with questions regarding the availability of test kits for others.



• What if I feel like I’ve been exposed but don’t need to see a healthcare provider or get tested?

Providers should follow the CDC guidelines and protocols published by the Department of Health. They are providing the most up-to date information as the situation evolves.



•  NEW  Will testing be made available to group home staff and residents, as is being done with Long Term Care Facilities, to prevent the spread of the COVID-19?

There are a number of testing facilities being opened up around the State, including some mobile units which are making testing more available.



•  NEW  Can providers require the testing of Clients and Staff for COVID-19 before reopening programs and services?

That is a business decision each program will need to make individually.

Telemeicine

•  NEW  Are Occupational Therapy, Physical Therapy, Speech Therapy and Behavior Analysis services allowed to render services via telemedicine as they are when billing Medicaid?

Yes, additionally Specialized Mental Health Counseling may also bill using telemedicine protocols for the iBudget waiver.



•  NEW  What are the billing codes that the therapy providers will need to use when rendering services via Telemedicine.

These providers will use the same procedure codes currently used with the addition of the GT modifier for any services rendered via telemedicine.



•  NEW  Can therapy providers render both face to face and telemedicine services to the same person?

Yes, however the provider should reflect how services are being rendered in the progress notes. Additionally, the provider must use the GT modifier on telemedicine claims and must put these on a separate line on the claim.



•  NEW  What proportion can be used for telehealth service delivery and what proportion can be direct/ face to face?

This is individualized to the client and the clients living situation as well as the client’s health status whether services are rendered via face to face or via telehealth.



•  NEW  If the behavior analysis services are rendered via telemedicine, can the provider still bill for the 25% of indirect services allowed in the iBudget Handbook?

Yes.



•  NEW  Will the therapy services which will be utilizing telemedicine, need to have adjustments made to the current service authorizations?

No, there will be no revisions needed to the service authorization, however the provider must ensure that the GT modifier is added to any line in the claim in which telemedicine was used.



•  NEW  Is the guardian required to be present when telemedicine is used?

The guardian will need to be present if the service recipient is a minor and resides with the legal guardian. Adults who have a legal guardian do not need to have the legal guardian present regardless of living setting.



•  NEW  If initiation of new Behavior Analysis Services is needed during this time, will there be a telemedicine billing code for Behavior Assessment?

No, there is no telemedicine code for behavioral assessments.



•  NEW  Is telehealth allowed as an option when the group home will not allow the behavior analysis provider to come into the home? If so, can the behavior analyst bill for participation in the support plan if conducted via telehealth?

Yes.



•  NEW  Do Telehealth codes also apply to someone served through CDC+?

No, the telemedicine codes related in the WSC advisory only apply to individuals on the iBudget waiver. However, telemedicine is allowable under CDC+.



•  NEW  Can Personal Supports, ADT and companion also be provided virtually? If so, what procedure codes should be used?

Telemedicine codes are limited to Occupational Therapy, Physical Therapy, Speech Therapy, Specialized Mental Health Counseling and Behavior Analysis services. However, providers who accept retention payments may render the services via alternate formats (i.e. virtually) but may not bill for these services.



•  NEW  What is the effective date of the use of telemedicine codes?

March 9, 2020.



•  NEW  If behavior analysis providers provide services using telemedicine exclusively to a client, can they still bill for indirect hours and if so, using what codes?

Yes, the provider would use the codes reflected on the service authorization for indirect hours billed.



•  NEW  Page 11 – The Guidance indicates: "In order to conduct the service or function telephonically, the service or function must effectively achieve the intended outcome and must contain both a telephonic and video format.” Does this apply to the Supported Employment (SE) service and can SE be billed if it is only conducted by telephone?

Supported Employment is not a service that can be rendered and billed via telemedicine.

Questions Related to AHCA Hospital Emergency Rule 59AER20-1

Qualifying Hospital Visit

•  NEW  Is testing required for patients receiving services in outpatient diagnostic care departments of the hospital?

No, the requirement only applies for patients admitted to the hospital.



•  NEW  Is testing required for patients seen only in the Emergency Department and not admitted to the hospital?

If the long-term care resident is sent to the ER for a situation unrelated to COVID-19 and the resident is not admitted to the hospital, they may be discharged/returned to the long-term care facility without testing. However, if the hospital has the ability to perform a rapid test they should do so.



•  NEW  Is testing required for patients placed in observation?

Yes. Patients in observation should be tested within 48 hours prior to returning to a long-term care facility.



•  NEW  Does the emergency rule apply to a patient discharged from a mental health facility? If the person was never positive, are 2 negatives still required?

The emergency rule only applies to any patient discharged to a long-term care facility from a hospital licensed under chapter 395, F.S, (general acute care hospital, long-term care hospital, psychiatric hospital, comprehensive medical rehabilitation hospital, etc.). It does not apply to patient’s discharged from a residential mental health facility licensed under Chapter 394, F.S.

Discharges Requiring Tests

•  NEW  Does the requirement to test prior to discharge apply to hospice inpatient facilities or other settings?

The requirement to test only applies to patients discharged to nursing homes, assisted living facilities, intermediate care facilities for the developmentally disabled and group home facilities licensed by the Agency for Persons with Disabilities. However, hospitals are encouraged to test prior to transfers to another health care facility.



•  NEW  If a hospital discharges to a hospital-based skilled nursing unit operating under the same hospital’s license (Chapter 395, F.S.), is testing required?

The emergency rule does not apply to patients transferred within a hospital (i.e. patients transferred from an acute care unit to a hospital-based skilled nursing unit or comprehensive medical rehabilitation unit operated under the hospital’s license). It would apply if the patient is then transferred from the hospital-based skilled nursing unit or hospital comprehensive medical rehabilitation unit to a long-term care facility.



•  NEW  Does the testing requirement also apply to patients discharged from a general acute hospital to a long-term acute care hospital or comprehensive medical rehabilitation hospital?

The emergency rule does not require testing of patients transferred from hospital to another hospital, such as a patient transferred from an acute care hospital to a comprehensive medical rehabilitation hospital. However, hospitals are encouraged to test prior to transfers to another health care facility.



•  NEW  If the patient comes from a long-term care facility and is returning to that same facility, does the hospital need to test them prior to return or is this only for patients discharging to that level of care for the first time?

The testing requirement applies to both residents being returned to a long-term care facility as well as patients being transferred to a long-term care facility for the first time.

Testing

•  NEW  When should the test be performed? If the hospital is testing all patients upon admission (or those with suspected COVID) and they test negative, does the hospital have to test them again before discharge? If so, what is the recommended timeframe to test before discharge? What do we do about the delays in getting the test results back?

This testing requirement is expected to be a part of the discharge planning process, not admission. If the patient has never tested positive they should be tested within 48 hours prior to discharge. If a patient has tested positive, the individual must have 2 negative test results separated by 24 hours prior to discharge unless the receiving long-term care facility has a dedicated wing, unit or building with dedicated staff to accept COVID-19 positive residents. If the hospital has the ability to perform a rapid test they should do so.



•  NEW  Does the requirement to test twice apply only to positive cases? In the case where the patient has tested negative and has not previously had symptoms do we still test twice?

A patient is only required to be tested twice prior to discharge if they have previously tested positive.



•  NEW  If the testing isn’t readily available in the hospital (with a quick turnaround time), can these tests be sent to the state lab?

If you have a hospitalized patient who needs to be tested for COVID-19 for either diagnostic purposes or for medical clearance prior to transfer to another facility, testing remains available from the Florida Department of Health (DOH), Bureau of Public Health Laboratories. DOH’s current turnaround time is 24 to 48 hours. Please refer to the Agency’s COVID Website for additional information regarding obtaining a PUI# for these requests.

COVID Discharge

•  NEW  The emergency rule states that a hospital can discharge a patient to a long-term care facility if they have a dedicated wing, unit, or building and dedicated staff to accept COVID patients. How can hospitals obtain a list of these facilities?

The Agency is working with the Department of Health to identify facilities with COVID - Designated areas and will share this information with hospitals.