Advocacy & Policy Updates (2021)
United Healthcare and POS Code 10 (12/29/2021)
Beginning with dates of service on January 1, 2022, United Healthcare will consider POS code 10 for reimbursement.
BCBSNC Insourcing Behavioral Health Service for State Health Plan (12/29/2021)
Starting January 1, 2022, Blue Cross NC will insource Behavioral Health Services for SHP members:
Blue Cross NC’s SHP team will assume care for all Behavioral Health intensive case management (complex case management) and utilization management responsibilities from Beacon Health Options.
The provider community can speak to a Behavioral Health case manager by calling 1-833-298-1069. New options will be available to providers to submit a Prior Plan Authorization (PPA) for SHP members. You can call the telephone number on the back of your membership ID card (1-800-367-6143) to reach an intake specialist directly, complete a fax form and fax it to 1-866-987-4161 or utilize the Blue e Authorization Portal.
Providers can email the Behavioral Health mailbox at BehavioralHealth@bcbsnc.com for questions related to these changes.
Thank Congress for Halting Medicare Cuts (12/22/2021)
From the American Psychological Association
In a significant victory, last week Congress heeded calls from advocates to protect access to mental health services – please take 2 minutes to thank Senators who voted yes.
Last Wednesday evening the House of Representatives passed legislation to postpone significant Medicare reimbursement rate cuts from taking effect in January, and by the end of the day on Friday, the bill had been approved by the Senate and signed into law by President Biden. Originally, the fate of the bill was uncertain in the Senate, prompting advocates from many health care sectors to speak up. As part of this wave of support, nearly 2,000 advocates representing the field of psychology leaned in to ask the Senate to protect access to mental health services - and the Senate did!
Now, it is important to recognize the efforts of the 59 Senators who voted for this legislation. If your Senator is one of those 59 Senators, you will be able to send them a thank you message by clicking on the button below. Several Senators joined the bipartisan effort and thanking them reinforces that you -their constituent – appreciate the vote they took.
Senator Thom Tillis voted yes to protect access to mental health services.
Click here to take action now.
The legislation took important steps to protect mental health, but more action will need to be taken next year. We outline key provisions from the bill and why they matter below.
- It contains a one-year, 3% increase in the Medicare conversion factor for 2022.
- This largely off-sets but does not eliminate a 3.71% cut to the conversion factor which CMS will enact as part of the final physician fee schedule for 2022.
- It also provides a gradual phase-in of separate Medicare sequestration cuts of 2% that were originally taking effect on January 1st. Instead, thanks to this legislation.
- No sequestration cuts will occur in the first three months of the year.
- A 1% reduction in Medicare payments would take effect for the second quarter of 2022.
- Then, the full 2% sequestration cuts will take effect next July.
- A third provision of the legislation exempts Medicare and other programs from automatic cuts in 2022 triggered by increased federal spending under the American Rescue Plan Act enacted earlier this year.
Overall, this means that while most harmful Medicare cuts have been eliminated, some cuts have only been postponed.
By protecting Medicare mental health services reimbursements, the legislation helps ensure the program and its providers can continue meeting the needs of beneficiaries as the COVID-19 pandemic continues. The pandemic has been taking a heavy toll on the nation’s mental health, with psychologists reporting large increases in demand for treatment of anxiety and depression compared with last year, and increased workloads and longer waitlists than before the pandemic.
While the fight is not over, this victory shows that when psychologists, scientists, educators, and students work together, we can make a difference. We will keep you informed on efforts to continue to protect access to mental health in 2022 and hope you will join our efforts. Thank you for your work to elevate the voice of psychology!
New Billing Disclosure Requirements Take Effect in 2022 (12/15/2021)
Psychologists will need to provide estimated costs of services before starting treatment.
The APC is monitoring this new information, including what steps psychologists might need to take in order to be in compliance with these new regulations. The APC will share any additional information in future APC Updates.
Read full article here from the American Psychological Association.
CMS Issues Final Rule for 2022 (12/15/2021)
The final rule includes information about audio-only services, psychological and neuropsychological testing, family therapy, and reimbursement rates.
Cigna Behavioral Health Changes Name to Evernorth Behavioral Health (12/15/2021)
On September 1, 2021, Cigna Behavioral Health, Inc. changed its name to Evernorth Behavioral Health, Inc. With this change, we will accelerate the delivery of innovative and flexible solutions that drive the most value for you and your patients.
Read more from the November 2021 newsletter here.
Extension to NC Medicaid Managed Care Appeals Deadlines (12/8/2021)
From the NC Department of Health and Human Services
Provider appeal rights defined in the Standard Plan Contract, Section V.D.5, Provider Grievances and Appeals and the appeal processes outlined in the Prompt Payment Fact Sheet, include deadlines to submit appeals which may vary by Standard Plans, from 30 days to 365 days after the decision giving rise to the right to appeal.
The Department shared concerns from providers about these deadlines with the Standard Plans. In response, Standard Plans will temporarily extend the following minimum appeal timeframes to support the transition to NC Medicaid Managed Care:
Appeal Submission DateMinimum Appeal TimeframeThrough Jan. 31, 202290 calendar days from the decision giving rise to the right to appealFeb. 1, 2022 through March 31, 202260 calendar days from the decision giving rise to the right to appealApril 1, 2022 and later30 calendar days from the decision giving rise to the right to appeal
For more information, see Extension to NC Medicaid Managed Care Appeals Deadlines.
Help Prevent 3.75% Reimbursement Rate Cuts (12/8/2021)
Please take 2 minutes today to prevent cuts to Medicare that would have a ripple effect across private insurance and other federal programs, including those treating vulnerable populations.
Despite a large increase in demand for mental health services as the COVID-19 pandemic continues to ravage communities and families nationwide, Medicare reimbursement rates for psychologists’ services will be cut 3.75% starting in January unless Congress takes action. Medicare payment rates are already considered low, and these pending cuts will not only impact practitioners' bottom line, they will inevitably lead to reductions in mental and behavioral health services provided to those who are most in need. And because Medicare's payment policies often serve as a benchmark for private insurance and other programs—including Tricare, the Veterans Health Administration, and state Medicaid programs—these changes ultimately will affect EVERYONE, not just providers and patients enrolled in Medicare.
Congress took action at the end of last year to prevent structural changes in Medicare billing codes from triggering a similar across-the-board reduction in Medicare payment rates. We need Congress to act before the end of this year to extend the 3.75% payment adjustment again, through at least CY 2022. Nearly 250 House members have signed a letter saying the support doing this, but we need stronger Senate support.
You can help by contacting your Senators to ask them to approve legislation this year to prevent the 3.75% reimbursement rate cuts from taking effect. Please protect Medicare providers and Medicare beneficiaries’ access to mental health services by preventing the cuts from taking place.
Click here to contact Senator Richard Burr.
Click here to contact SenatorThom Tillis.
NC HIEA (12/8/2021)
The NC Health Information Exchange Authority has revised its Privacy and Security Policy; the new policy will take effect December 16, 2021.
Click here to read more here.
BCBS Quartet Expansion (12/8/2021)
Beginning January 1, 2022, Blue Cross NC will be expanding its Quartet Health program to include State Health Plan members.
Click here to read more.
HHS Telehealth Resources (12/1/2021)
Health and Human Services has a resource-rich page related to telehealth.
Sections include preparing patients for telehealth, legal considerations, best practice guides, and more.
CMS Bulletin Regarding Place of Service Codes (12/1/2021)
The bulletin specifies a new code for telehealth in a patient's home (Place of Service code 10) that will become effective January 1, 2022. You may see some insurers starting to update their systems in anticipation of this change.
Click here to view the CMS bulletin.
Medicare Opting Out and Private Contracting (11/17/2021)
All Medicare-eligible mental health professionals must decide whether they will become credentialed as an in-network provider for the government Medicare plan or choose to “opt-out”.
From APA Services Inc:
“Healthcare professionals are required by law to submit claims to Medicare for services furnished to Medicare beneficiaries under a provision known as mandatory claims submission. Even those who never applied to become Medicare providers must abide by this requirement. Certain healthcare professionals, including psychologists, have the option of privately contracting with Medicare beneficiaries for services rather than submitting claims to Medicare. Known as the “opting out” process, this alternative allows select providers to treat Medicare beneficiaries without Medicare’s payment restrictions.”
Read the full article here.
You can search for providers who have opted out, or confirm your own opt-out status, using this Medicare.gov link:
Additional information can be found in the Online Toolkit, including the Opt-Out Affidavit and information about creating a Private Contract.
BCBS Annual Provider Training and Attestation Requirements (11/17/2021)
This is a reminder that all participating providers in our Blue Cross and Blue Shield of North Carolina Medicare Advantage network are required to complete the Healthy Blue + Medicare (DSNP) MODEL OF CARE training.
Office of the National Coordinator for Health Information Technology (ONC) (11/10/2021)
HealthIT.gov is the official website for the Office of the National Coordinator for Health Information Technology (ONC). https://www.healthit.gov/
Psychologists can find information related to a wide variety of topics, such as privacy, security, and HIPAA. For example:
Click here for tips on how you can protect and secure health information when using your mobile device.
BCBS Update to Family Psychotherapy Coverage (11/10/2021)
Effective January 1, 2022, Blue Cross and Blue Shield of North Carolina (Blue Cross NC) will provide coverage for family psychotherapy without the presence of the patient.
HIPAA Security Rule and Security Risk Assessment (11/3/2021)
The Office of the National Coordinator for Health Information Technology (ONC), in collaboration with the HHS Office for Civil Rights (OCR), developed a downloadable Security Risk Assessment (SRA) Tool to help guide you through the process. The tool is designed to help healthcare providers conduct a security risk assessment as required by the HIPAA Security Rule and the Centers for Medicare and Medicaid Service (CMS) Electronic Health Record (EHR) Incentive Program.
Click here to read more and download the free SRA Tool.
Health Information Exchange (10/27/2021)
To be reimbursed for treatment and evaluation of Medicaid, State Employee Health Plan, and Children’s Health Insurance Program (CHIP) patients, the provider, whether in-network or out of network, must comply with the North Carolina HIE law.
On Monday, October 18, Martha Turner-Quest, Executive Director, participated in a North Carolina Health Information Exchange Agency (NC HIEA) focus group with other health care providers. The NC HIEA will be providing the North Carolina General Assembly with a compliance-related report concerning providers’ and organizations’ connection efforts by March 2022.
The original deadline was June 1, 2020, but due to COVID 19, the deadline is extended to January 1, 2023.
Compliance With The Law
Compliance with the law means that the provider has filled out and submitted a Participation Agreement which could be a Full Participation Agreement or a Submission Only Participation Agreement.
- Full Participation Agreement allows a two-way exchange of information about patient information between the provider and the HIE.
https://hiea.nc.gov/nc-hiea-full-participation-agreement/open
- Submission Only Participation allows only one-way communication from the provider to the HIE. The Submission Only Agreement does not ensure that ONLY state-funded health care patient data is submitted. The onus is on respective providers and their electronic health record (EHR) vendors to make sure that only Medicaid, State Employee Health Plan, and CHIP patient data is submitted.
NC HIEA Submission-Only Participation Agreement | NC HIEA
Acceptance of the provider’s Participation Agreement by the Health Information Exchange Authority (HIEA) puts the provider in a “queue” to be linked to the HIE. When the provider is in the Queue, by having an agreement in place, it means that they are “in compliance.” In compliance further means the provider is showing “good faith” in moving forward with the process as “development underway”. That is, they are not waiting until the last minute to hook up and have identified an HIE-approved method to submit patient information to the HIE. If you are already connected to NC HealthConnex, you are done and in full compliance with the law.
Note: The Law does not require use of an EHR. It states: “Method of Data Submissions–The data submissions required under this section shall be by connection to the HIE Network periodic asynchronous secure structured file transfer or any other secure electronic means commonly used in the industry and consistent with document exchange and data submission standards established by the Office of the National Coordinator for Information Technology within the U.S. Department of Health and Human Services.”
The Law does not define the specific behavioral data that is to be shared through your submission. It states: certain demographic and clinical information pertaining to services rendered to Medicaid and other State-funded health care program beneficiaries and paid for with Medicaid or other State-funded health care funds.
Although HIE “defaults” to talking as if an EHR is necessary, it is not a requirement by the letter of the law. It is just difficult to figure out how to hook up without an EHR.
Helpful Links
The Law:
https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/ByArticle/Chapter_90/Article_29B.html
General FAQs About NC HealthConnex:
https://hiea.nc.gov/faqs/general-faqs-about-nc-healthconnex#what-is-the-hie-act-and-the-state%E2%80%99s-requirements-for-connectivity
HIE and COVID-19 Response
https://hiea.nc.gov/covid-19
HIE Connection Deadline FAQs
https://hiea.nc.gov/faqs/faqs-about-covid-19-legislation
NCPA Has Worked With Two Software Developers
Because many of us have been concerned about patient privacy from this law, NCPA has worked with 2 software developers to define their methods of connecting to the HIE while maintaining privacy of patient records and sending minimal data. If you have attended conferences where these developers have joined us as sponsors and presenters, you may recall:
Mark Dunnagan of Smartlink Health Solutions, (https://www.smartlinkhealth.com/), is a Cary-based software company that has invested in a connection to NC HealthConnex that can support almost any EMR or billing system. They have also constructed a Patient Registry, for paper-based practices, which is capable of securely tracking and forwarding the information required by NC HealthConnex. You may send an email to support@smartlinkhealth.com for more information.
Sean Behan of Therapy Notes (www.therapynotes.com) who, as chief technician for TN on this project, has identified minimal behavioral health information for submission only to HIE.
He states: "TherapyNotes utilizes HL7 ADT messages for the data transmission format, and the content of those messages has a very high degree of overlap with the content of a health insurance claim - things like patient demographics, insurance information, service codes, diagnosis codes, and provider information. . . We do include confidentiality indicators in the diagnosis as well, asking that diagnostics be withheld in the HIE environment unless an end-user indicates a specific need for that information.”
NCPA cannot endorse a particular software company but has had a very positive working relationship with these 2 software entities.
Other EHRs accepted by the HIE are listed on the NC HealthConnex website: https://hiea.nc.gov/providers/electronic-health-record-vendor-connectivity-report
**NCPA strongly recommends that providers work closely with their particular EHR vendor (or other non-EHR“connectors” like SmartLink) to identify the specific data points that the EHR will submit to the HIE. NCPA cannot recommend exact data sets to use with the HIEA but appreciates the care that Smartlink and Therapy Notes have taken to identify the data set in the HCFA 1500 forms. **
Meeting with Executive Director of PsyPact Commission (10/20/2021)
On Friday, October 8, Leslie Feil, PhD and Cristin Saffo, PsyD of the APC and Martha Turner-Quest, Executive Director, met with Janet Orwig, MBA, CAE, the Executive Director of the PsyPact Commission. During the meeting, Ms. Orwig shared information about PsyPact history, governance, and policies. Drs. Feil and Saffo shared information from the NCPA PsyPact survey and raised some specific questions about operating under PsyPact. The following is a summary of the main points addressed in this meeting.
Overview and General Information
The PsyPact Commission (official name Psychology Interjurisdictional Compact Commission) is the governing body of PsyPact responsible for creating and finalizing the Bylaws and Rules and Regulations. The Commission is also responsible for granting psychologists the authority to practice telepsychology and temporary in-person, face-to-face practice of psychology across state boundaries. The first PsyPact Commission meeting was held in July 2019. The Board of Psychology in each PsyPact state has its own commissioner.
ASPPB began taking applications for the E.Passport and associated credentials in July 2020. Ms. Orwig reported that delays in processing applications were due to 1) a higher than expected number of applications (possibly due to increased telehealth use with Covid) and 2) significant staffing shortages. Ms. Orwig reported that the staffing shortages have been rectified.
The PsyPact Commission has appointed several committees, including the Training and Public Relations Committee, to address issues related to operating under PsyPact. Some committee meetings are open to the public. Meeting schedules can be found on the PsyPact website, where interested parties can register to attend.
E.Passport Credentialing
An applicant’s degree program must have been accredited by the American Psychological Association/ Canadian Psychological Association or designated by the ASPPB National Register Joint Designation Project. Psychologists who earned their doctoral degree in psychology from a regionally accredited program may apply for the E.Passport if 1) they were licensed by or before January 1, 1985 and 2) have been continually been licensed since that date.
NOTE: Questions and concerns related to E.Passport credentialing should be directed to the Association of State and Provincial Psychology Boards (ASPPB), not to the PsyPact Commission.
Specific Practice Topics
Uniformity:
1. Compact states can’t impose rules or regulations that the other compact states won’t agree to. For example, no compact state can require an in-person meeting at any point during delivery of remote services.
2. PsyPact supersedes any state law pertaining to the interjurisdictional practice of telepsychology and temporary in-person, face-to-face practice.
3. Psychologists providing virtual services into other states under PsyPact can assume that the receiving state’s regulations allow for electronic provision of services; you do not need to confirm this with each state’s Psychology Board.
Home State:
1. A psychologist needs to be licensed in their designated home state in order to provide services under PsyPact from that state. If you move to another PsyPact state, you will need to apply for a license from that state. This would also apply to temporary relocation (see #3).
2. You are not operating under PsyPact if you are providing remote services from one state into another and are licensed in both states- even if both states are part of the PsyPact compact.
3. Psychologists can change their designated home state, and there is no minimum amount of time required for a home state designation. Example: Dr. X is licensed in both North Carolina and Georgia. Dr. X lives and works in the designated home state of NC. Dr. X plans to spend two months in GA and provide services while there. Dr. X can change the designated home state to GA during those two months.
Legal:
1. PsyPact does not address mental health laws and regulations. Psychologists practicing under PsyPact need to be aware of the receiving state’s laws and regulations regarding mental health. During the meeting, NCPA advocated for the need for easily accessible reference materials related to specific state law (such as duty to protect/warn and duty to report). Ms. Orwig will bring this to the Training and PR Committee.
Note: The NCPA Online Toolkit (available to members at the Investor level and above) contains a document summarizing all states’ Mental Health Professionals’ Duty to Warn. The Toolkit also contains pages related to “Technology and Electronic Records” and “Telehealth and PsyPact”.
Business and Taxes:
1. PsyPact law does not address business regulations. For example, while PsyPact law does not require a “reporting agent” to be designated in a receiving state, this may be required by the laws regulating business operations in the receiving state. Psychologists need to research the specific business laws of the receiving state.
2. PsyPact likewise does not address tax issues; Ms. Orwig advised psychologists to consult with their accountants regarding tax matters.
3. As with legal matters, NCPA advocated for the need for easily accessible, state-specific business information; Ms. Orwig will bring this to the Training and PR Committee.
Insurance:
1. PsyPact does not address insurance issues. Informational materials are available for psychologists to provide to insurance companies if they experience problems while operating under PsyPact. Contact PsyPact directly for these materials.
2. CMS considers practicing under PsyPact to be the equivalent of practicing with a license in the receiving state. (See the recent APC Updates for more on this.)
3. Ms. Orwig reported that the APA Practice Directorate is working on insurance issues related to practicing under PsyPact.
Information and Resources
PsyPact
Website:
https://psypact.site-ym.com/general/custom.asp?page=telepsychology
Contact information:
info@psypact.org; psypro@asppb.org; or use the “Contact us” form on the PsyPact website
Association of State and Provincial Psychology Boards (ASPPB)
Website: https://www.asppb.net/
Main email:
asppb@asppg.org
Mobility program email:
mobility@asppb.org
American Psychological Association (APA) Practice Directorate
Website:
https://www.apa.org/practice
Contact page:
https://www.apa.org/practice/contact
CMS Recognizes PsyPact Licensure Requirements for Interstate Practice (10/13/2021)
Psychologists authorized to practice in states where PSYPACT — the Psychology Interjurisdictional Compact — has been enacted will soon be eligible to bill Medicare Administrative Contractors for services provided across state lines to Medicare beneficiaries.
Medicare Clarifies Recognition of Interstate License Compact
On September 5, 2021, the Centers for Medicare and Medicaid Services (CMS) issued a revised notice regarding recognition of interstate license compact pathways.
Psypact Proposed Rule for Comment
The PSYPACT Commission has released the following proposed rules. The Commission will accept public comment until November 4th, 2021 at 5:00pm EST. To submit public comment, please visit the link at the bottom of the page. The annual Commission meeting which will contain a public hearing regarding these rules will be held on November 18th, 2021 at 10:00am EST. A registration link for this meeting can be found HERE
Proposed Rules
- Rule on Compact Privilege to Practice Telepsychology
- Rule on Compact Temporary Authorization to Practice
- Rule on PSYPACT Commission
New CE Requirements for Psychologists for 2022 Licensure Renewal (10/06/2021)
All licensees must now complete 24 total hours of Continuing Education for every two-year
license renewal cycle. A minimum of 15 of those hours must now be completed in Category
A Continuing Education. Up to a maximum of 9 hours may be completed in Category B
Continuing Education; however, all 24 Continuing Education hours may be completed in
Category A if so desired.
Beginning with the next license renewal cycle (October 1, 2022), each licensee must submit an attestation form documenting completion of the required minimum CE hours as well as copies of certificates of completion in order to renew their licenses.
Fortunately for you, as an NCPA member, one of your NCPA benefits includes a Continuing Education Tracker found in your member portal.
To access and use this, log in to your member portal.
You will see the name tag with your name. Underneath, you will see “Continuing Education Transcript” – Click on that.
You will then see where details have been added for each workshop. You will have an option that says “Upload Certificate” Click and follow the steps.
This is a great place to maintain all of your CE credit and certificates so you have them in one place when it is time for you to renew your license next year.
You may also add additional CE that you take elsewhere.
NC Psychology Board Notice: Psychology Practice Act (9/29/21)
The NC Psychology Practice Act was recently recodified to a different section of the NC Statutes, but, other than different statutory section numbers, the language of the Psychology Practice Act remains exactly the same. Again, it is important to note that none of the requirements under the Psychology Practice Act or the Board's Rules have changed as a result. Board staff is working to update the Board's Rules and forms. In the meantime, a crosswalk showing the citations of the Psychology Practice Act before and after the recodification can be found by clicking here: RECODIFICATION CROSSWALK.
BCBS State Health Plan
As part of the Clear Pricing Project (CPP) copay incentive, the State Health Plan has reduced the copay to $0 if a member visits a CPP behavioral health provider, retroactive to January 1, 2021.
See the pricing chart here.
See the May 17, 2021 Provider Alert regarding this change here.
NC Psychology Board Notice: PsyPact Rules for Comment (9/22/21)
The Psychology Interjurisdictional Compact (PSYPACT) Commission has published Proposed Rules for consideration and comment. The Proposed Rules can be found HERE. These Proposed Rules are open for a period of 60 days for public comment for those stakeholders interested in providing such comments.
The deadline for submission of written comments is November 4, 2021.
Written comments should be submitted via the public comment form found on the PSYPACT website (https://psypact.site-ym.com/page/PublicComment) and submitted to the PSYPACT Commission no later than 5:00 pm Eastern on November 4, 2021.
A public hearing will be conducted as part of the PSYPACT Commission's Annual Meeting via Zoom on November 18, 2021 beginning at 10:00 am Eastern. Interested parties may participate and notification will be posted to the PSYPACT website (https://psypact.site-ym.com/page/Meetings) 30 days prior to the meeting with call-in information provided.
NC Medicaid: Prepaid Health Plan Interest and Penalities for Provider Claims
In accordance with Section V. H.1.d of the NC PHP Contract, prepaid health plans (PHPs) are required to pay interest and penalties to providers if the PHP fails to accurately pay or inappropriately denies a clean claim within 30 calendar days of receipt of medical claims or within 14 calendar days of receipt for pharmacy claims.
- This includes incorrect denials and under-or partial payments that are identified and paid on reprocessed claims.
- It is the PHP’s responsibility to issue interest and penalty payments to providers when applicable.
A clean claim is a claim for services submitted to a PHP by an NC Medicaid Managed Care medical or pharmacy service provider which can be processed without obtaining additional information from the submitter in order to adjudicate the claim.
If the PHP fails to implement fee schedule changes and reprocess impacted claims with the correct rates within 45 calendar days of notification of a fee schedule change from NC Medicaid, the PHP must pay interest and penalties on the adjusted amount.
For more information, please see Medicaid bulletin Prepaid Health Plan Interest and Penalties for Provider Claims.
PsyPact Survey Results (9/15/21)
In July, a PsyPact survey was sent to all NCPA members. 176 of 877 recipients (approximately 20%) responded to the survey. Responses to select survey items are listed below:
1. Have you been credentialed with the E.Passport and APIT (Authority to Practice Interjurisdictional Telepsychology)? 174 responses
Yes 55 31.61%
No 89 51.15%
In Process 24 13.79%
2. If you did apply for the E.Passport and APIT (whether or not you became accredited), did you have problems with the application process? 79 responses
Yes 41 51.90%
No 38 48.10%
3. Have you begun to use the E.Passport and APIT to practice in other states? 91 responses
No 61 67.03%
Yes 30 32.97%
Jurisdictions most frequently mentioned included Pennsylvania, Virginia, DC, and Georgia.
4. Have you experienced any difficulties practicing in other states? 66 responses
No 57 86.36%
Yes 9 13.64%
5. What resources have you used to find information about ethical/legal delivery of services into other states/jurisdictions? 85 responses
The most frequently mentioned resources were: APA, the Trust, NC Psychology Board, ASPPB, other state Psychology Boards, NCPA, the NCPA Online Toolkit, the National Register.
Thank you to all NCPA members who participated in the survey. We will be sharing more information about PsyPact, this survey, and telehealth in future APC Updates- stay tuned!
Providing Services Via Telepsychology (9/8/21)
The following is an overview of the four main avenues through which NC psychologists can provide virtual services to their clients. Please note that: 1) the examples below assume that the psychologist is physically located in North Carolina at the time of service; and 2) this overview addresses only licensing and jurisdictional issues. All psychologists should check with their respective professional liability carriers about plan coverage and limitations.
Psychologists licensed in NC may:
1. Provide virtual services to clients who are physically located in North Carolina at the time of service. According to the NC Psychology Board: “the Board has confirmed that it has no separate view per se with regard to provision of services via electronic means. As long as a licensee is practicing in a manner consistent with his/her training and experience, and is receiving supervision as is appropriate, the medium for doing so is not at issue.” You can read the Board’s full statement here:
http://www.ncpsychologyboard.org/office/ElectronicServices.htm
2. Provide virtual services to clients who live and/or are currently reside in another state or jurisdiction in which you are fully licensed. You will need to check with each jurisdiction’s Psychology Board to determine its policies regarding the provision of virtual services.
3. Provide virtual services to clients who are residing/living in another state or jurisdiction due to the Covid-19 pandemic, utilizing the temporary emergency practice regulations issued by that jurisdiction. A summary of jurisdictions’ emergency Covid-19 regulations can be found below; however, psychologists should check with each particular jurisdiction’s licensing body prior to providing virtual services into that jurisdiction:
https://www.asppb.net/page/temptelepsychologicalpracticecovid-19
4. Provide virtual services to clients who are residing/living in another state or jurisdiction that participates in PsyPact. Psychologists who have been credentialed with both the E.Passport and Authority to Practice Interjurisdictional Telepsychology (APIT) by the Association of State and Provincial Psychology Boards (ASPPB) can provide remote services from North Carolina into other PsyPact jurisdictions. More information can be found here:
https://www.asppb.net/page/telepsychology
Take Action to Protect Reimbursement, Telehealth, and Audio-Only Services (9/1/21)
The Centers for Medicare and Medicare Services (CMS) is proposing a reduction in payment to psychologists by 3.89% in 2022. Additionally, CMS is proposing to reimburse telehealth and audio-only services at a reduced rate after the COVID-19 public health emergency ends.
Whether you are a practitioner, scientist, student, or educator - please make comments to CMS as part of a single effort on behalf of the field. This proposal will not only impact practitioners’ bottom line, but the resulting trickle-down effect will lead to reductions in mental and behavioral health services provided to those who are most in need. Because Medicare’s payment policies often serve as the benchmark for private insurance and other programs, these changes ultimately will affect EVERYONE, not just providers and patients enrolled in Medicare.
A significant portion of the 2022 proposed rule includes provisions to increase access to audio-only and other telehealth services beyond the end of the current public health emergency, including in Rural Health Clinics and Federally Qualified Health Centers.
While these proposals by CMS represent a win for mental health, psychologists must continue the fight to ensure they are enacted as policy. NCPA and psychologists have fought hard to get this far, and now more than ever, all of us must weigh in to keep these changes in place.
You have until Monday, September 13, 2021 by 5:00 PM EDT to make your voice heard.
For additional information, please visit APA's Action Center for the CY22 Medicare Physician Fee Schedule.
Click here to join thousands of your colleagues and add your voice to help protect psychological services.
Extension of Out-of-Network Provisions (8/25/21)
In an effort to ensure optimal access to care for Medicaid beneficiaries, to support providers during the recent COVID-19 surge, and to alleviate potential provider payment concerns, DHHS and the prepaid health plans (PHPs) have agreed to extend the policy for out of network flexibilities to providers who have not yet contracted with a PHP through Nov. 30, 2021. These flexibilities were originally expected to sunset on Aug. 30, 2021.
Under this policy, the PHPs have agreed to:
- permit uncontracted, out of network providers enrolled in NC Medicaid to follow in network provider prior authorization rules and may continue to get a prior authorization retroactively (This exception does not apply to concurrent reviews for inpatient hospitalizations which should still occur during this time period);
- reimburse out of network providers at the in-network rate of 100% of the Medicaid fee schedule;
- delay implementation of the 90% rate reduction following good faith contracting provision;
- allow beneficiaries to change their Primary Care Provider for any reason; and
- extend flexibility for Non-Emergency Medical and Non-Emergency Ambulance Transportation providers through November 2021.
For more information, please see Medicaid bulletin Extension of Out of Network Provisions.
Expedited Hardship Advances for Managed Care Providers
The North Carolina Department of Health and Human Services (DHHS) and Prepaid Health Plans (PHPs) are committed to supporting providers during the transition to managed care. We stand by the Day One goal to ensure providers are paid for services they provide. DHHS and PHPs are aware of potentially delayed payments and increased claim denials during the transition period.
Providers experiencing claim payment issues should initially work with the PHPs to address claim issues and avoid the need for a hardship advance. Refer to the Guidance for Providers Experiencing Payment Issues bulletin for contact information.
As DHHS, PHPs and providers address the various claim processing problems, providers who are at risk of not meeting financial obligations this month as a result of claim processing issues may request a hardship advance to offset the business cost due to pended or denied claims.
Thank you for your patience and cooperation as we work to resolve managed care transition claim issues. For more information, please see the Medicaid bulletin Expedited Hardship Advances for Managed Care Providers.
LME-MCO Disengagement and Megers Update
Source: i2i Center for Integrative Health
There has been much discussion and action in the past year related to the Cardinal Innovations counties that are no longer satisfied with their service management that will bring major changes to the catchment areas of a number of LME/MCOs. Before a county can disengage from their LME/MCO, there are regulatory requirements that provide timelines and steps that must first occur. Click here to look at those regulations. Here’s what we know about potential changes at the time of this writing:
- November 5, 2020: Orange County commissioners vote to disengage from Cardinal Innovations and begin merger actions with Alliance Health. Click here to track Orange’s realignment plan.
- May 20, 2021: Forsyth County commissioners vote to disengage from Cardinal Innovations and begin merger actions with Partners Health Management. Click here to track Forsyth’s realignment plan.
- June 1, 2021: Mecklenburg County commissioners vote to disengage with Cardinal Innovations and begin merger actions with Alliance Health. Click here to track Mecklenburg’s realignment plan.
- June 22, 2021: Davidson County commissioners vote to disengage with Cardinal Innovations and begin merger actions with Sandhills Center. Click here to track Davidson’s realignment plan.
- June 29, 2021: Davie County commissioners vote to disengage with Cardinal Innovations and begin merger actions with Partners Health Management. Click here to track Davie’s realignment plan.
- June 29, 2021: Stokes County send a letter to NC DHHS Secretary indicating a possible disengagement from Cardinal Innovations.
- July 19, 2021: Rockingham County commissioners vote to disengage with Cardinal Innovations and begin merger actions with Sandhills Center. Click here to track Rockingham’s realignment plan.
- September 1, 2021: Cabarrus, Stanly and Union counties will disengage with Cardinal Innovations and move to Partners Health Management. Click here for more information about the realignment of these counties from Cardinal Innovations. Click here for more information about the realignment of these counties to Partners Health Management.
- June 30, 2022: Consolidation of Cardinal Innovations with Vaya is scheduled to be completed for those counties that have not previously disengaged or are not in the disengagement process.
- According to the NC DHHS webpage on these changes, there are four counties (Chatham, Halifax, Stokes and Warren) that are “pending”. At least one of these counties, Stokes, has expressed some level of interest in disengagement but has not yet taken action.
If you want to look at how this may impact the number of Medicaid eligible individuals served by each LME/MCO, click here to see resource of Medicaid beneficiary data:
