Indiana Medicaid COVID-19 Flexibilities: Telemedicine, Timely Filing Limits, Provider Enrollment, and More

UPDATE ON APRIL 23, 2020: Indiana Health Coverage Programs continues to release new guidance and make temporary policy changes for providers during the COVID-19 pandemic. When billing for services provided to patients who are covered by Indiana Medicaid or one of Indiana Medicaid’s Managed Care Plans, consult the latest IHCP banners for the most up-to-date guidance.

During Indiana’s COVID-19 emergency declaration, the Indiana Health Coverage Programs (IHCP) is implementing temporary changes to provide flexibility for Indiana Medicaid providers and patients. Changes affect many areas of IHCP, including telemedicine, timely filing limits, provider enrollment, and more. Here is a brief overview of several of those changes.

New Provider Enrollments

Indiana Medicaid provider enrollment applications received prior to April 1, 2020, will be processed according to standard enrollment requirements. Provider enrollment applications received on or after April 1, 2020, through the end of the State emergency declaration, will be enrolled on a provisional basis with an assigned risk level associated with their provider type and specialty without the additional screening measures.

These providers with provisional enrollment will then be required to revalidate at the conclusion of the emergency declaration. Each newly enrolled provider’s revalidation date will be set based upon the number of days between the provider’s original date of enrollment and the final date of the emergency declaration plus 90 days. During their revalidation process, providers with provisional enrollment will be required to complete all screening requirements that were temporarily waived during the emergency declaration.

Provider Revalidations

Indiana Medicaid provider revalidations have been temporarily halted. All providers due for revalidation between March 1, 2020, and the end of the State emergency declaration will now be required to revalidate after the emergency declaration has ended. Any enrollments that were terminated during March 2020 because of failure to revalidate will be reactivated, and those providers also will be required to revalidate after the emergency declaration has ended.

Providers who have already submitted their revalidation to the IHCP will be processed based upon normal revalidation requirements. However, no outstanding revalidations can be submitted now until after the emergency declaration has ended. In fact, all revalidation functionality through the IHCP Provider Healthcare Portal, including the ability to start or complete the revalidation process, will be disabled through the duration of the emergency declaration.

All providers due for revalidation during the emergency declaration (who had not already submitted their revalidation to the IHCP) will be given at least 90 days to complete revalidation after the conclusion of the emergency declaration. Each provider’s revalidation date will be set based upon the number of days between the provider’s original revalidation date and the final date of the emergency declaration plus 90 days. The new notification will include the updated revalidation date.

MCE Provider Credentialing

Based on guidance from the National Committee on Quality Assurance (NCQA), Indiana has waived the requirement that managed care health plans must fully credential providers before permitting those providers to bill claims for services to Indiana Medicaid members. For more information on each MCE’s individual policies, please contact the MCE directly.

Provider Locations

During the state’s emergency declaration, IHCP will allow enrolled rendering providers to participate with any currently enrolled group location without requiring the rendering provider to be linked to the group’s service location enrollment. However, claims requiring reprocessing after the conclusion of the emergency declaration may be denied.

As well, rendering providers may bill for services through any enrolled service location. Services provided at a practice location that is not currently enrolled should be documented through provider records. Providers should include the place of service (POS) code that corresponds with the service location under which they are billing.

Medical Students or Residents

The IHCP will not require medical students or medical residents who are authorized to practice under Governor Holcomb’s Executive Order 20-13 to be enrolled themselves. Instead, they can be reimbursed under a supervising practitioner’s National Provider Identifier (NPI). Provider documentation must clearly indicate the services were performed by a medical student or medical resident.

For more information about temporary changes to Indiana Medicaid’s Provider Enrollment processed, review IHCP Bulletin BT202029 from March 31, 2020 and IHCP Bulletin BT202039 from April 7, 2020.

Managed Care Timely Filing Limits

Effective with March 1, 2020, dates of service through the duration of Indiana emergency declaration, IHCP has extended the timely filing limit on managed care claims from 90 to 180 calendar days from the date of service (DOS). The timely filing limit on claims for services rendered through the fee-for-service (FFS) delivery system remains at 180 calendar days.

For more information about the extension of the managed care timely filing limits, review IHCP Bulletin BT202036 from April 7, 2020.

COVID-19 and Related Diagnosis Codes Added to Emergency Department Autopay List

IHCP had added the following diagnosis codes to the managed care health plan Emergency Department Autopay List, effective for dates of service (DOS) on or after April 1, 2020:

B97.29 – Other coronavirus as the cause of diseases classified elsewhere
U07.1 – 2019-nCoV acute respiratory disease
Z03.818 – Encounter for observation for suspected exposure to other biological agents ruled out
Z20.828 – Contact with and suspected exposure to other viral communicable diseases

The managed care health plan Emergency Department Autopay List is accessible from the Code Sets page at in.gov/medicaid/providers.

These diagnosis codes are also considered emergency diagnosis codes for fee-for-service (FFS) claims.

For more information about updates to the managed care health plan Emergency Department Autopay List, review the following IHCP bulletins:

Member eligibility

Indiana Medicaid members with full health coverage will not be terminated during the public health emergency. Member coverage will only end if a member voluntarily withdraws or moves out of the state.

This does not apply to members with presumptive eligibility (PE), however. PE members must still complete a full IHCP application.

Cost-sharing

All cost-sharing is suspended for the duration of Indiana’s emergency declaration.

Members who typically had copayments will not have any copayments applied, starting April 1, 2020, through the end of the emergency declaration. This applies to all IHCP programs, including HIP, and includes pharmacy copayments.

For more information about member eligibility and cost sharing, review IHCP Bulletin BT202033 from April 2, 2020.

Telehealth

Several temporary changes also have been made to Indiana Medicaid’s telehealth requirements.

Coverage of telehealth services during the emergency declaration is not limited to the codes on the Telemedicine Services Codes. However, the following provider types and services may not be reimbursed for telehealth (or what the payer refers to more specifically as telemedicine) by Indiana Medicaid: surgical procedures, radiological services, laboratory services, anesthesia services, audiological services, chiropractor services, care coordination without the member present, durable medical equipment/home medical equipment providers, and provider-to-provider consultation.

As well, Indiana Medicaid also will allow telehealth services to be offered to both established and new patients. In addition, any IHCP-covered service – aside from the exclusions listed above and speech, occupational, and physical therapies – can be provided through audio-only visits, given that the service can reasonably be provided through audio only communication.

When billing telehealth services to Indiana Medicaid from the IHCP designated list of Telemedicine Services Codes, use POS code 02 and modifier -95, as specified in the IHCP Telemedicine and Telehealth Services Provider Reference Module. For IHCP covered codes not on the Telemedicine Services Codes list, use the POS code most relevant to the member’s location. If the member is located in his or her home, use POS code 12. Additionally, the GT modifier is strongly encouraged when billing these “new” telehealth services to Indiana Medicaid, but it’s not required, especially if there are already four modifiers being used. If the GT modifier is not used on the claim, the provider must maintain and be prepared to provide documentation that notes that the service was provided via telehealth.

For more information about temporary changes to Indiana Medicaid’s telehealth guidelines, review IHCP Bulletin BT202034 from April 2, 2020, and IHCP Bulletin BT202037 from April 7, 2020.