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Frequently Asked Questions from BCBSRI COVID-19 provider call Q: Many other payers (UHC and Cigna) have waived preauthorization requirements for post- acute care for any patients being discharged from the acute care setting and discharging to LTAH, SNF, IRF and home care. Is Blue Cross planning on doing the same? A: At this time authorizations are suspended for the following services: urgent and emergent inpatient level of care (FEP only if COVID-19 related) long term acute care acute inpatient rehabilitation level of care skilled nursing services There are still requirements for each service. Please review the information pertaining to the authorization change on our Alerts and Update section of our provider portal Referrals: At this time referrals are still required for all Commercial plans except the State of Rhode Island. They have decided to waive the referral requirement for their employees. CMS has directed all Medicare Advantage plans to waive the referral requirement effective 03/01. No changes have been made to commercial plans and all existing referral requirements remain in place. Q: If a physician provides an audio, telephone call only that cannot be considered a virtual check- in (G2012), are we allowed to bill for and receive payment for the most appropriate CPT codes 99441-99443? A: All BCBSRI normal coding and policy rules would apply. For example, BCBSRI’s Non-Reimbursable Health Service Codes policy is still in place. Codes 99441-99443 are non- covered. Q: I am an LMHC, and I have been utilizing the opportunity for conference calls to my patients. Would this be something that Blue Cross Blue Shield-would consider as a permanent option in the future, after the coronavirus? A: At this time BCBSRI’s TEMPORARY Telemedicine/Telehealth and Telephone Services During the COVID-19 Crisis Effective 3/18/20 (and its prior temporary policies) are in fact temporary as outlined in those policies. BCBSRI has not contemplated the expansion of benefits/coverage after the time the COVID-19 crisis has subsided. Pleases be assured that BCBSRI will keep its provider community updated via BCBSRI.com related to this and any other policy updates. While we’re allowing for phone calls during this crisis, we feel strongly that best practice for mental health treatment involves a visual component, where you are able to both see and hear your client. Because of this, after this temporary policy expires, we would return to covering telemedicine visits with both audio and video components and face to face treatment only. Q: What are the evaluation and management codes for Telemedicine visits Allowed by Blue Cross Blue Shield?

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Page 1: Frequently Asked Questions from BCBSRI COVID-19 provider ... · Frequently Asked Questions from BCBSRI COVID-19 provider call Q: Many other payers ... Why aren't dental providers

Frequently Asked Questions from BCBSRI COVID-19 provider call

Q: Many other payers (UHC and Cigna) have waived preauthorization requirements for post-

acute care for any patients being discharged from the acute care setting and discharging to LTAH,

SNF, IRF and home care. Is Blue Cross planning on doing the same?

A: At this time authorizations are suspended for the following services:

• urgent and emergent inpatient level of care (FEP only if COVID-19 related)

• long term acute care

• acute inpatient rehabilitation level of care

• skilled nursing services

There are still requirements for each service. Please review the information pertaining to the

authorization change on our Alerts and Update section of our provider portal

Referrals: At this time referrals are still required for all Commercial plans except the State of

Rhode Island. They have decided to waive the referral requirement for their employees. CMS has

directed all Medicare Advantage plans to waive the referral requirement effective 03/01. No

changes have been made to commercial plans and all existing referral requirements remain in

place.

Q: If a physician provides an audio, telephone call only that cannot be considered a virtual check-

in (G2012), are we allowed to bill for and receive payment for the most appropriate CPT codes

99441-99443?

A: All BCBSRI normal coding and policy rules would apply. For example, BCBSRI’s Non-Reimbursable Health Service Codes policy is still in place. Codes 99441-99443 are non-

covered.

Q: I am an LMHC, and I have been utilizing the opportunity for conference calls to my patients.

Would this be something that Blue Cross Blue Shield-would consider as a permanent option in

the future, after the coronavirus?

A: At this time BCBSRI’s TEMPORARY Telemedicine/Telehealth and Telephone Services

During the COVID-19 Crisis – Effective 3/18/20 (and its prior temporary policies) are in fact

temporary as outlined in those policies. BCBSRI has not contemplated the expansion of

benefits/coverage after the time the COVID-19 crisis has subsided. Pleases be assured that

BCBSRI will keep its provider community updated via BCBSRI.com related to this and any other

policy updates. While we’re allowing for phone calls during this crisis, we feel strongly that best

practice for mental health treatment involves a visual component, where you are able to both see

and hear your client. Because of this, after this temporary policy expires, we would return to

covering telemedicine visits with both audio and video components and face to face treatment

only.

Q: What are the evaluation and management codes for Telemedicine visits Allowed by Blue

Cross Blue Shield?

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A: BCBSRI is currently allowing for any clinically appropriate codes/services that is provided in-

office to be provided via Telemedicine/Telehealth and/or Telephone. BCBSRI has not placed any

restrictions on coding at this time. BCBSRI expects that providers will only file for clinically

appropriate services to be filed through Telemedicine/Telephone and/or Telephone where all the

aspects/components of the service can be provided.

Q: I am a primary care physician. We are doing Telemedicine consult during this pandemic. My

question is, will this be covered if we did the consult from home during evenings and weekends?

At least for next 4 weeks we should be allowed to do this?

A: Yes, BCBSRI has not put any restrictions on the place of service that either the patient or the

provider is physically located during the timeframe its temporary policies are in place.

Q: In regards to billing specifically for physical therapy Telehealth/Telemedicine, do we have to

use modifier's GP,GT, and CR on claims with place of service 02?? Or are we only supposed to

be submitting claims with the "CR" Modifier when billing with place of service 02??

Clarification on what modifier or modifier's we need to use when billing will significantly cut

down on claim rejections and confusion with physical therapy practices.

A: All providers; including physical therapists should continue to file all appropriate modifiers as

it would prior to the TEMPORARY Telemedicine/Telehealth and Telephone Services During the

COVID-19 Crisis – Effective 3/18/20 policy being in effect. Providers should add the CR

modifier in an additional modifier field after reporting the modifier it would normally file.

BCBSRI’s system will recognize the CR modifier in any modifier field on a claim and react to

multiple modifiers.

Q: My question is regarding the cost-share waiver (copay/deductible/co-insurance) indicated in

your most recent communication: Does this apply only to members who have BCBSRI as their

home plan? For example, I have many clients who have BCBS claims billed through RI because

that is where our practice is located, but the member's BCBS home plan is from a different state.

Does the cost-share waiver apply to all claims processed through BCBSRI or does it specify

BCBSRI as home plan in order for the waiver to apply?

If it is members with BCBSRI home plan only, is there any guidance you can provide on how to

expedite identification of clients covered? Perhaps specific alpha-prefixes on member numbers or

some other way to identify BCBSRI members more readily than going through each insurance

card individually?

A: As outlined in BCBSRI’s TEMPORARY Telemedicine/Telehealth and Telephone Services

During the COVID-19 Crisis – Effective 3/18/20, the cot-share waiver does not apply to out of

state Blue Cross Blue Shield of BlueCard members. BCBSRI will send claims to the member’s

Home Plan to apply their applicable benefit as is with the normal course of business for BlueCard

claims. BCBSRI is aware that Blue Cross Blue Shield plans throughout the country are adopting

different benefits for their members e.g. waiving costs share for telemedicine/telephone services

during the COVID-19 crisis. BCBSRI has over 600 prefixes for our plan. We recommend when

asking the member for their member identification number, they advise you who their plan is

through or taking a picture of the front and back of their member ID card for you and

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emailing/texting it to you. You can then document what plan this member has. Member benefits

for BlueCard HOST members can be obtained by calling the number on the back of their card.

Q: Why aren't dental providers allowed to receive reimbursement for treatment that is rendered

over the phone? For example: A patient who contacts the dentist on the emergency number with

a complaint of facial pain and swelling and the dentist reviews the patient's medical history and

symptoms. The dentist then prescribes an appropriate antibiotic and pain medicine until that

patient can be seen in the dentist's office.

A: We are currently working with our Medical Directors and our dental partner UCD related to

establishing a policy/identifying allowable services through Telemedicine/Telephone during the

COVID-19 crisis. We will notify our providers via an Alerts and Updates notice on BCBSRI.com

as well as providing a response on the FAQ document that is maintained on BCBSRI.com.

Q: How do phone sessions affect those who have HSA’S and deductibles? And will there be a

delay in reimbursement for services?

A: The cost-share waiver applies to HSA’s and all deductible plans as well as copays and

coinsurances. The deductible will be waived and the monies will not need to be collected by you.

The claim will reimburse 100% of the allowance of the code you file following BCBSRI’s

TEMPORARY Telemedicine/Telehealth and Telephone Services During the COVID-19 Crisis –

Effective 3/18/20.

BCBSRI does not expect any significant delays related to claims processing. BCBSRI is currently

making the necessary updates to its systems to process claims in accordance with its updated

policy. As per our Alerts and Updates notice on 03/20/2020 we are asking providers to hold

claims until such time our system is updated. If providers elect to file claims they will suspend

until such time as our system is updated at which time BCBSRI will release all suspended claims.

We appreciated our providers understanding in these unprecedented times.

Q: What type of visits can be conducted via telephone/or telemedicine? Our visits consist of

wellness, routine follow up, and urgent. What CPT codes can we bill- is it just 99211 or 99213?

A: As outlined in our TEMPORARY Telemedicine/Telehealth and Telephone Services During

the COVID-19 Crisis – Effective 3/18/20, any in office visit or other service that you would

regularly bill for that is clinically appropriate to render over telemedicine/telephone and for which

you provide all the services/components of the code/service you may bill for and it will be

covered with no member cost share for dates of services on and after 03/18/2020.

Q: Do you find many primary care offices closing there office- and only doing telemedicine?

A: During these unprecedented times, BCBSRI is seeing its participating providers adjusting their

practices to meet the needs of their patients and to ensure compliance with social distancing

guidelines provided by the CDC, the State of Rhode Island as well as other governmental

agencies. BCBSRI has made changes to its policies and procedures to ensure that providers are

able to be in compliance with these requirements/recommendations.

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Q: Will BCBSRI cover telemedicine visits for patients who do not have telemedicine benefits

during the COVID-19 crisis who cannot be seen face to face at this time?

A: BCBSRI will cover telemedicine visits for patients who do not have telemedicine benefits

during the COVID-19 crisis in accordance to with our Temporary Policy

Q: We are getting questioned about providing oximeters E0445 HCPC for COVID- 19 discharges

from hospitals. These have never been a covered item for spot checks. Unless for severe pediatric

or adult cardiac issues where medical documents show the need for continuous monitoring. Is this

being considered and will a PA be needed.

A: BCBSRI covers and separately reimburses for code E0445 when billed/provided by a

professional provider e.g. physicians and Durable Medical Equipment providers when medically

necessary and ordered by a physician/provider. Services are covered under the member durable

medical equipment benefit and the services do not require prior authorization/PA. Note: BCBSRI

does not cover when billed by a facility e.g. hospital as the item is considered not separately

reimbursed.

Q: I have a question on how a provider should document for elements of an Annual Physical and

AWV such as a BMI, BP that the provider was unable to obtain.

A: BCBSRI is currently reviewing if it will be allowing AWV via Telemedicine/Telephone.

There are considerations related to ensuring that all of the elements of a AWV can be completed

as well as ensuring that CMS will recognize/accept the visit in terms of diagnosis identified, etc.

BCBSRI will post a final answer to this questions on the FAQ document on BCBSRI.com once a

decision is determined. Until such time we ask that our providers hold off on preforming any

AWV.

Q: Why are you not addressing the reimbursement to dentists who are providing care via

telemedicine? Our practices have been virtually closed by the governor and she has mandated

that insurers pay all providers who render care remotely.

A: We are currently working with our Medical Directors and our dental partner UCD related to

establishing a policy/identifying allowable services through Telemedicine/Telephone during the

COVID-19 crisis. We will notify our providers via an Alerts and Updates notice on BCBSRI.com

as well as providing a response on the FAQ document that is maintained on BCBSRI.com.

Q: Are the cost sharing fees waived for all services or just COVID related services?

A: Cost sharing is waived for services rendered under our TEMPORARY

Telemedicine/Telehealth and Telephone Services During the COVID-19 Crisis – Effective

3/18/20 policy. The cost sharing waiver is not specific to COVID 19 diagnosis.

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Q: For ABA codes can we please review 97153 and 97155 for technician delivered sessions with

telehealth and BCBA supervision?

A: All ABA codes are covered during the pandemic. You are allowed to bill the above two codes

with the CR modifier and POS 02.

Q: But what if a patient conducts a telehealth visit NOT related to COVID? Does that mean their

cost sharing is waived? For example, they are having a musculoskeletal issue?

A: Cost sharing is waived for all services regardless of diagnosis rendered under our policy titled,

TEMPORARY Telemedicine/Telehealth and Telephone Services During the COVID-19 Crisis –

Effective 3/18/20. All normal benefits apply to all other services.

Q: Will claims that have been submitted be held or will they be denied and need to be re-

submitted?

A: Currently BCBSRI is pending all claims filed with a place of service 02 related to our

TEMPORARY Telemedicine/Telehealth and Telephone Services During the COVID-19 Crisis –

Effective 3/18/20 policy. BCBSRI will be pending all claims until such time as our system is

configured to apply benefits and reimbursement correctly. We expect our system configuration to

be complete by April 3, 2020 and claims will be released for processing at that time. BCBSRI has

asked providers to hold claims until April 3rd to avoid the work effort related to releasing large

numbers of claims.

Q: How do we treat out of State Blue Cross claims? Do they follow RI rules?

A: Yes, all normal Out of Area claim submission rules continue to apply. Providers should file all

claims for BlueCard members following BCBSRI billing/claims filing requirements. Please note

that BCBSRI accepts all national recognized modifiers e.g. GT.

Q: Can doctors and NPP provide telehealth for patients resides at a long term care facility. The

code range from 99307 through 99310. Thank you.

A: As outlined in BCBSRI’s TEMPORARY Telemedicine/Telehealth and Telephone Services

During the COVID-19 Crisis – Effective 3/18/20 policy, BCBSRI will temporarily allow for all

clinically appropriate, medically necessary covered health services to be provided through

telemedicine/telephone for all/any health conditions in an effort to reduce the need for in-person

treatment and support social distancing efforts, as well as to ensure that providers are able to

continue to provide medically necessary and clinically appropriate care during the course of this

public health emergency. Provider should ensure that they perform all the necessary

components/requirements of the code/service filed/billed. Please remember, BCBSRI reserves the

right to audit medical records as well as administrative records related to adherence to its policy,

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e.g. to verify the nature of the services provided, the medical necessity and clinical

appropriateness to provide such service via telemedicine and/or telephone as well the

appropriateness of the level of evaluation and management coding. Documentation must contain

the details of the provider-patient encounter. Special focus will be placed on a review to

determine that a claim is not billed at a higher level evaluation and management code/service

when a lower level code/service is warranted. BCBSRI specifically requires documentation of the

time spent with that patient in all documentation.

Q: are you considering paying additional for extra PPE expense that dentist will have to incur to

safely treat patients. One N95 mask costs over $6 alone.

A: Personal Protective Equipment would not be separately reimbursed. Providers are encouraged

to outreach to the Department of Health for assistance related to Personal Protective Equipment.

Q: I've suggested practices use BOTH GT and CR so that in state use CR and out of state use GT.

I assume this will work

A: You should continue to bill all applicable modifiers on your claim e.g. GT in addition to ing

the CR if the services is rendered via telemedicine, telehealth or telephone. For local BCBSRI

claims if it is the CR modifier that is used to waive the members cost share.

Q: As many well visits are being delayed now, will you allow well visits to be performed next

year only within a full calendar year of their last well visit. This will make scheduling well visits

challenging next year. Will you waive that need for a full 365 days between well visits?

A: BCBSRI applies the benefit for well visits based on the member’s benefit year. At the current

time, BCBSRI does not expect to make any accommodations related to extending this benefit.

Q: Can we do telemedicine for residents in Long term nursing facility, if there is wide spread

COVID in the facility?

A: Yes, in accordance to our TEMPORARY Telemedicine/Telehealth and Telephone Services

During the COVID-19 Crisis – Effective 3/18/20 policy, BCBSRI will allow for all clinically

appropriate, medically necessary covered health services to be provided through

telemedicine/telephone for all/any health conditions in an effort to reduce the need for in-person

treatment and support social distancing efforts, as well as to ensure that providers are able to

continue to provide medically necessary and clinically appropriate care during the course of this

public health emergency. BCBSRI is not limiting the place of service where the service is

provided.

Q: For physical therapy consult via the phone what codes should we use?

A: Per our TEMPORARY Telemedicine/Telehealth and Telephone Services During the COVID-

19 Crisis – Effective 3/18/20 policy providers must file the appropriate CPT codes for the

telemedicine/telehealth or telephone encounter as they would for a traditional face-to-face visit.

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Q: How frequently can Telehealth visits be provided and be covered?

A: We would not allow Telemedicine/telephone calls that occur the same day as a face-to-face

visit, when performed by the same provider and for the same condition. Outside of that

restriction, BCBSRI will reimburse for all clinically appropriate, medically necessary covered

health services. Frequency should be that of what would be expected in a provider’s office.

Please remember that BCBSRI reserves the right to audit medical records as well as

administrative records related to adherence to all the requirements of this policy, e.g. to verify the

nature of the services provided, the medical necessity and clinical appropriateness to provide such

service via telemedicine and/or telephone as well the appropriateness of the level of evaluation

and management coding. Documentation must contain the details of the provider-patient

encounter. Special focus will be placed on a review to determine that a claim is not billed at a

higher level evaluation and management code/service when a lower level code/service is

warranted. BCBSRI specifically requires documentation of the time spent with that patient in all

documentation.

Q: Is the "no cost share" that RI has adopted being applied by out-of-area plans as well?

A: As outlined in our policy, BCBSRI’s policy is only applicable to members with BCBSRI

coverage not BlueCard HOST members/those members of other Blue Cross Blue Shield Plans

nationally. Just like in office services, the members HOME Plan determines benefits. Please

verify benefit coverage via the member Home plan for out of area members.

Q: I am with a specialist office spine practice. Seeing new patients and offering telemedicine.

But unable to do complete H&P vitals etc... We generally have this info sent to us from PCP.

Can we still bill with New Patient code?

A: Providers should follow the coding guidelines relative to new vs. established patient, if this

patient has not been seen by this provider or another provider in the same group with the same

specialty, they can bill a new patient exam. It appears the provider was questioning the level of

E&M due to the fact that they wouldn’t be able to do a complete H&P. The provider should code

the H&P part of the exam based on the level obtained, in addition the provider should document

to support as much History and MDM as provided or use time to justify the level.

Q: AWV by audiovisual telehealth will not be covered until we are notified otherwise?

A: This is correct, we are currently researching the Annual Well Visit coverage via telemedicine

and telephone.

Q: What CPT codes would we use for physical therapy consult (not actually doing therapy with

patients, but rather consulting them on their plan of care).

A: Per our TEMPORARY Telemedicine/Telehealth and Telephone Services During the COVID-

19 Crisis – Effective 3/18/20 policy all providers must file the appropriate CPT codes for the

telemedicine/telehealth or telephone encounter as they would for a traditional face-to-face visit.

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So, you should code this consult visit as you would in the office assuming that you can perform

all the components/requirements of the code you file.

Q: Is CR modifier to be used only on telehealth claims submitted with date of service between the

temporary policy effective dates (currently 3/18 – 7/31) or on all telehealth visits regardless of

date of service?

A: Per the TEMPORARY Telemedicine/Telehealth and Telephone Services During the COVID-

19 Crisis – Effective 3/18/20 policy, claims should be filed with the CR modifier and POS

02.Claims should not be filed with the CR modifier outside of these dates or for services that do

not meet the guidelines of the policy. BCBSRI will be notifying providers if its policy is extended

past 7/31.

Q: All E& M codes apply to telephone visits? 99212 to 99215?

A: Yes, in accordance to our TEMPORARY Telemedicine/Telehealth and Telephone Services

During the COVID-19 Crisis – Effective 3/18/20 policy. All providers must file the appropriate

CPT codes for the telemedicine/telehealth or telephone encounter as they would for a traditional

face-to-face visit.

Q: Can you document time in EHR stating: 'Spent 20 minutes with patient' or 'Time with patient

11:00 am to 11:30 am.

A: BCBSRI suggests you utilize the same documentation standard that you would use if you saw

a patient in the office, however more specifically identify the time spent with the patient if you

are coding on the time. The actual start and end date of the encounter would meet the requirement

of time documentation. BCBSRI reserves the right to audit medical records as well as

administrative records related to adherence to all the requirements of this policy, e.g. to verify the

nature of the services provided, the medical necessity and clinical appropriateness to provide such

service via telemedicine and/or telephone as well the appropriateness of the level of evaluation

and management coding. Documentation must contain the details of the provider-patient

encounter. Special focus will be placed on a review to determine that a claim is not billed at a

higher level evaluation and management code/service when a lower level code/service is

warranted. BCBSRI specifically requires documentation of the time spent with that patient in all

documentation.

Q: Are Nursing Home Telehealth visits covered and what is the modifier?

A: As outlined in BCBSRI’s TEMPORARY Telemedicine/Telehealth and Telephone Services

During the COVID-19 Crisis – Effective 3/18/20 policy, BCBSRI will temporarily allow for all

clinically appropriate, medically necessary covered health services to be provided through

telemedicine/telephone for all/any health conditions in an effort to reduce the need for in-person

treatment and support social distancing efforts, as well as to ensure that providers are able to

continue to provide medically necessary and clinically appropriate care during the course of this

public health emergency. Provider should ensure that they perform all the necessary

components/requirements of the code/service filed/billed. Please remember, BCBSRI reserves the

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right to audit medical records as well as administrative records related to adherence to its policy,

e.g. to verify the nature of the services provided, the medical necessity and clinical

appropriateness to provide such service via telemedicine and/or telephone as well the

appropriateness of the level of evaluation and management coding. Documentation must contain

the details of the provider-patient encounter. Special focus will be placed on a review to

determine that a claim is not billed at a higher level evaluation and management code/service

when a lower level code/service is warranted. BCBSRI specifically requires documentation of the

time spent with that patient in all documentation.

Q: Is the presentation available online if I didn't see all of it?

A: We will be posting the presentation and the Q&A document each Tuesday and Thursday.

Additional Questions from 04/01/2020 Call

Q: If the person lives in Mass, but has BCBSRI for insurance are counselors licensed in RI

allowed to provide telehealth services.

Also, I read that telehealth clients are not responsible for copays during the COVID-19 crisis. Is

BC going to cover these or are the providers expected to absorb this loss?

A: Yes, you will be able to render services for BCBSRI members who live in Massachusetts (or

another state) and will submit the claim to BCBSRI as business as usual.

Correct, members are not responsible for copays while the TEMPORARY

Telemedicine/Telehealth and Telephone Services During the COVID-19 Crisis – Effective

3/18/20 policy is in place. This will not take away monies from the provider, this will cover 100%

to the provider. If the charge of your claim is $100.00 and the claim usually pays the provider

$50.00 and applies a $25.00 copay as the member responsibility, the claim will pay the entire

$75.00 to the provider.

Q: How should we bill a new patient telehealth visit?

A: As indicated in the TEMPORARY Telemedicine/Telehealth and Telephone Services During

the COVID-19 Crisis – Effective 3/18/20 policy, all claims should be coded with the CR Modifier

with a place of service 02.

Q: Are you paying for telephone encounters 99441 – 99443? Also does MDM trump time on

coding for telehealth visits?

A: No, 99441-99443 are found in our Non Reimbursable Health Service Codes policy. The policy

is still in place and if providers are to bill codes that are currently non reimbursable, the claim will

deny as a provider liability.

Q: Some telehealth behavioral health claims sent in with CR modifier did not pend - they

processed and paid with a copay. Do we need to send in an adjustment request for each claim or

will BC RI be performing global adjustments?

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A: Claims received before the pend will be automatically adjusted by BCBSRI. Providers will not

need to put in an adjustment request.

Q: What about a BCBS of Massachusetts or Connecticut client that I see in RI typically. Would

they need to pay their copay?

A: it is up to that members plan. Blues Plans are trying to be consistent but are falling under

different state requirements.

Q: Can providers obtain a temporary Rhode Island license to render telemedicine services?

A: The federal guidance (applicable to Medicare) alleviated the requirement to hold a licensure in

the state where the member is. That guidance is here:

https://www.phe.gov/emergency/news/healthactions/section1135/Pages/covid19-13March20.aspx

(see para. 1b)

In RI, DOH has announced that it will issue an emergency license to a provider licensed in

another state to practice in RI. The Director described this as a simple process with a quick turn

around. That guidance is here: https://health.ri.gov/licenses/

It appears MA does not require a registration, see https://www.mass.gov/doc/march-17-2020-

registration-of-health-care-professionals-order/download, para (3).

Providers are responsible for ensuring compliance with licensure laws.

Q: Any update on billing for electronic communication (email and portal messages) IF the care

delivered meets E&M standards?

A: No update at this time. There is a report that other insurers are covering email visits.

Q: Will you follow CMS in allowing DME providers the signature requirements updated by

CMS? • Signature Requirements: CMS is waiving signature and proof of delivery requirements

for Part B drugs and Durable Medical Equipment when a signature cannot be obtained because of

the inability to collect signatures. Suppliers should document in the medical record the

appropriate date of delivery and that a signature was not able to be obtained because of COVID-

19.

A: Yes, we are following CMS and waiving the signature requirements for DME. Both the

signature on the order and the signature at delivery (providers should note in the record). Lower

level providers can also sign at this time.

Q: Normally claims filed have a place of service filed on the claim that is the providers primary

location within the office. If different offices are closing within our group and providers are

rendering services at other locations, is it okay that the location submitted on the claim to be the

provider’s usual location and not necessarily the physical location services are being rendered?

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A: Yes, this is acceptable at this time.

Q: We have residents that are being granted Disaster Privileges and obtaining an Emergency RI

Medical License so they can provide the necessary coverage we need for this crisis. Will your

health plan credential these residents under our current State of Emergency?

A: BCBSRI will accept provider applications if the resident has a RI Medical License. The

application should be submitted via our existing online process. Please be sure to indicate the

application is being submitted as part of the COVID-19 response. Please also be sure to indicate

what department the new provider will be providing care.

Q: For other providers joining our group that have agreed to start early for emergency coverage,

do you have anything in place to process these applications immediately and/or allow for retro

effective dates?

A: For all new providers who are not already credentialed with BCBSRI, the application should

be submitted via our existing online process. Please indicate on the application that the provider is

being credentialed in response to COVID-19. Please also specify what department, or in what

capacity, the new provider will be providing care. All clean applications will be expeditiously

processed. BCBSRI will not honor retroactive effective dates. As a reminder, providers who are

already participating with BCBSRI, that are being added to a new practice/TIN only require a

Practitioner Change Form. Updates to those providers are effective as of the date indicated on the

Practitioner Change Form.

Additional Questions from 04/03/2020 Call

Q: If a provider is working from home conducting telemedicine visits with patients who live out

of state, do they need to be provisionally licensed in the state where the patient lives?

For example, a provider at home who would normally be in the office (in Rhode Island), filing a

claim for their patient who would normally be seen in the office (in Rhode Island), but is now at

their home (in Mass.) is there additional credentialing/licensure required?

A: We are covered by the Federal mandate waiving the requirement for license in the state you

are practicing. As long as you have a valid license in any US state, you will be able to render the

services during this time.

Q: If a provider lives in a state other than the one where they typically practice and provide care

telephonically to patients in RI what are the credentialing and licensing issues?

For example, the provider resides in Massachusetts, but usually practices in Rhode Island and is

conducting telephonic “visits” to a BCBSRI patient in RI is there additional

credentialing/licensure required?

A: That is allowed because the rendering provider has a RI license, and is performing telephonic

visits to RI patients.

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Q: We submitted claims from 3/18 until 3/29 (then unaware of the policy regarding Telehealth

counseling sessions) therefore we did not know to code using the 02 location and the CR

modifier. My question is in regards to resubmission of these claims: do we need to wait until they

are denied/paid etc before we can resubmit them or can we go ahead and resubmit them now?

What do we need to know so processing is most efficient?

A: You will need to submit corrected claims for those claims once they are paid/denied on your

remittance advice. We recommend you continue to join the BCBSRI COVID-19 calls, as we will

confirm once our system is configured for the 3/18/20 Policy updates and you can then submit

your corrected claims..

Q: I just wanted to report that I was billing all of the claims for the telephone and video visits,

and they are either denying as not covered or are having deductibles or copays apply. I had been

billing these up until I was notified last week that we should hold onto these claims until after

April 3rd. My question is, do I need to adjudicate these claims to get them paid correctly? Or will

Blue Cross be reprocessing claims like this?

A: Blue Cross will be automatically reprocessing any claims that were denied with the POS 02,

providers will not need to submit in corrected claims for claims filed with POS 02 and CR

modifier.

Q: Would BCBS of RI allow Masters level counselors (supervised by licensed counselors) to see

clients? Currently you do not. This would help us to help more BCBS of RI clients. We are an

LLC, does that count as a facility?

A: There is no plan to change the policy because we have enough social workers right now. Only

Butler or Bradley would be facilities.

Q: With audio consultation, are we limited t the 99211 and 99212 codes, or can we code at a

higher level? How does the 99211 code work, since technically it is a nursing code, which

historically was not paid anyway?

A: In this case, since some of the calls might be low level complexity and decision making that

was allowed initially but now the policy is updated to encompass more complex codes, whatever

you feel is clinically appropriate and is an allowable code.

Q: With cost sharing being waived, and providers being reimbursed at 100% of the allowed

amount, I assume this also applies to members who have a deductible on their policy, and these

claims would not apply to the deductible cost?

A: Yes. Deductible, coinsurance and copayments are waived.

Q: Is consent necessary to initiate a telehealth visit and if so how should that be documented in

the chart?

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A: Your practice might have a consent form or when using a secure system it asks for the

member to consent as well.

Q: What happens if an out of state plan requires a different modifier (such as GT) for telehealth?

A: As long as you place the CR modifier on the claim you can also use other modifiers on the

claim. So if another plan requires another modifier, use both.

Q: Are new patients eligible to receive telehealth services?

A: Yes.

Q: Is hospital inpatient care covered?

A: OHIC guidance is for anything medically necessary and clinically appropriate. From Dr.

Collin’s experience, he finds it hard to see how full care can be done. He hasn’t heard back from

any of the hospitalists asking for it. It is up to the MD to determine which code/service is

clinically appropriate at this time.

Q: Pandemic aside, it has been refreshing to handle some issues over the phone and via

telehealth. Is there any possibility that Blue Cross would continue to let us use both in the future?

It would make our job a little easier and would fairly reimburse us for the "free" care we have

been used to giving.

A: BCBSRI has had a telemedicine policy effective since January of 2019. Traditionally

telemedicine pays 75% of the E&M codes and now 100% for BH services. We anticipate

continued changes but not the cost share waiving.

Q: Are clinicians able to bill annual exams, well child visits and annual wellness visits? If so

how would one document elements of the exam that cannot be performed?

A: At this time, render the services you can and complete the rest later such as the vaccine admin

then document everything.

Additional Questions from 04/06/2020 Call

Q: Can patients continue their acupuncture treatment via telemedicine during and after COVID-

19 pandemic? Acupuncture includes other modalities like acupressure, ear seeds etc besides

inserting needles can effectively help patients.

-If yes, anything changes in terms of billing code and fee schedule compare to in-person visits?

-If yes, can a new patient have acupuncture treatment via telemedicine or only for established

patients?

-If yes, can the acupuncture provider offer telemedicine via his/her own platform (zoom, skype

etc) or have to be on BCBSRI Doctors online?

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A: No, acupuncturists are not an allowed provider type to file for clinically appropriate and

medically necessary services using telemedicine/telehealth or telephone only services during this

pandemic.

Q: Any word on when claims submitted before the pend was put in place will reprocess? These

claims processed with cost share and we've been told they will automatically reprocess.

A: A claim extract will be pulled for claims that were processed before the pend to be processed

correctly.

Additional Questions from 04/08/2020 Call

Q: I am a LMHC with a private practice. In your earlier conferences provided to practitioners it

was advised to hold claims until April and make sure to indicate the proper code CR and also 2

for place of service. In error, I submitted several claims for individual psychotherapy sessions in

advance of April 3rd. 2 claims were paid and I received partial reimbursement with copayments

still due by patient. According to the previous seminars copayments are being covered by Blue

Cross. How do I proceed to receive the full amount and to ensure my patients are not being

required to pay for their copayments at this time?

A: The pend was released the weekend of April 4th. Your claims may have been processed before

the pend was lifted. Those claims will be adjusted through our claims extract.

Q: Are our claims being processed normally during this time? Should we resubmit them when

people are back at work?

A: Yes all claims are being processed normally during this time. We have a claims pend in place

for only claims filed with a place of service 02, but that pend has been lifted and claims are being

processed.

Q: Are BlueCHiP for Medicare products still required to have an online PCP referral for physical

therapy? A patient was referred to our office by a specialist; we have been unable to obtain the

online referral from PCP it appears the office staff is not working. Are there any exceptions to

this policy secondary to COVID-19?

A: Yes, PCP referrals are still required for all Commercial plans except the State of Rhode Island.

CMS has directed all Medicare Advantage plans to waive the referral requirement effective

03/01. We understand some PCP offices may be closed at this time. You should still see the

member for services. We have expanded the look back period for specialist to obtain referrals for

these members. Instead of a 90 day look back period, it is now changed to 180 days. We will send

a communication once the look back period returns to 90 days.

Q: Should we submit Blue Cross (BC) Federal claims in a different way than claims submitted

for BCBSRI patients? Based on the policy we found on the website BC Fed is looking for

different modifiers and allowing for codes that BCBSRI considers not separately payable (i.e.

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99441-99443). Should we follow that guidance or the new BCBSRI telehealth rules for these

patients?

A: We have to follow their rules and in some cases they have different requirements. We have an

FEP Informational Guide on our provider portal. Specific questions can be answered by the FEP

call center.

Q: Are Medicare Wellness visits considered medically necessary and clinically reasonable via

telemedicine? And if so, would that have to be audio/visual or could it be audio-only?

A: There will be a policy posted later today. Yes – for adult and pediatric patients. It’s true that

the exam cannot be done via telephone or video. Policy will allow you to render the initial portion

of the exam and bill for it, then at a later date, have the follow up interaction when you can test

blood pressure and BMI in person after the crisis subsides. Only one claim will be submitted after

both interactions have taken place. Everything should be documented and BCBSRI reserves the

right to audit records to ensure that both interactions have been done.

Q: With out of state carriers and Federal Blue Cross that require a GT modifier - which modifier

should go first on the claim - CR or GT?

A: Multiple modifiers can be on the claim. Put the GT first and CR second if another plan is

requiring the GT.

Q: Are we able to bill for Telephone calls with new patients? What procedure code would we

use?

A: Yes, you can use standard coding with the POS 02/CR mod.

Q: Is there a limit to the number of telemedicine visits per patient and can they be billed on back

to back days?

A: There is no limit and you can bill back to back days.

Additional Questions from 04/10/2020 Call

Q: Is cost share waived for patients afraid to come in for their follow up visits due to pandemic or

only for COVID related issues?

A: Yes. As long as the provider codes the claim correctly with the CR modifier and 02 POS, any

telemedicine/telephonic services will waive the cost share.

Q: Is there a timeline for BC to do their mass adjustment for claims that processed incorrectly?

A: We are working to identify all impacted claims this week associated with our

Telemedicine/Telehealth and Telephone Only Temporary Policies. Once identified the claims will

be reviewed and submitted for reprocessing. Please allow 30 days for the reprocessing to be

completed, however we are working to complete in a more expedited timeframe. Additional

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system updates for waiving the cost sharing on confirmed COVID 19 diagnosis will be handled in

the same manner once our system is updated to match our policy. WE will continue to provide

updates on our weekly Provider Conference Calls. .

Q: Are you following CMS regarding inpatient telehealth guidelines?

A: Following the Governor’s Executive Order and OHIC’s Insurance Bulletin as well as

BCBSRI’s TEMPORARY Telemedicine/Telehealth and Telephone Services During the COVID-

19 Crisis – Effective 3/18/20 policy, BCBSRI is covering all clinically appropriate, medically

necessary covered health services via telemedicine. To the extent, an inpatient medical

code/service meets these guidelines, BCBSRI will allow for reimbursement. As a reminder,

BCBSRI requires provider file claims with a 02 Place of Service and a CR modifier to waive

members cost share.

Q: Cost sharing for BCBS RI clients was to be covered through April 17th. Has that been

extended? If so, until when.

A: As announced by the governor that telemedicine coverage is extended until July 31st BCBSRI

will update the end date in our policy, post the updated policy to our website and announce it in

our COVID-19 meetings.

Q: If a physician is placing a telephone “audio” only call and provides services that include all

elements of an E+M billed with CPT codes 99201-99215, are we allowed to bill BC using CPT

codes 99201-99215 with the appropriate modifier? Telephone “audio” only CPT codes 99441-

99443 are currently on the NSR list.

Are you allowing hospitals to bill for PHP/IOP services during the PHE using telehealth (video +

audio two-way communication)? If so, are you expecting those services to be billed on a 1500

claim form using the behavioral health CPT codes for psych and addiction services? Currently,

IOP/PHP services are submitted to BC on a UB and we receive a per diem rate.

A: Yes, you are allowed to bill for any covered in-network CPT code. 99441-99443 are NSR and

will not be reimbursed if billed to BCBSRI. Yes we are allowing hospitals to bill for PHP/IOP.

You will bill on the UB-04 form with a type of bill 013X with the CR modifier in any position.

Q: I am doing teletherapy for both individuals and couples and families. Why are we not allowed

to bill 90847 if we are working with more than one person?

A: You are allowed to bill for 90847 as it is a covered in-office code.

Q: I am a billing service and have been holding Bcbs claims as requested and am wondering if it

is safe to submit them now for correct claims processing? They are behavioral health telehealth

claims.

A: Yes, the pend that was in place for any telemedicine/telehealth or telephone services has been

lifted as of 4/4. As a result you may begin to submit claims following BCBSRI policy.

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Q: I have a client who has a BC BS of Texas policy that goes through BCBS Rhode Island and is

then farmed out to the TX plan. I am a high risk person for COVID-19 since I have asthma. My

patient was quarantined since she had been overseas when I initially "saw" her through telehealth.

Her telehealth claims have been denied by BCBS Texas since they do not cover telemedicine,

even under this crisis (only the state run plans are covering it) Do you know of someone I can

speak with at BCBS TX to get an exception made? The patient and I both reside in a state that is

telling us to use telemedicine, which we are doing. We are not in TX, where the insurance

company is located, and where the current guidelines might be different.

A: You or the member can appeal the denial. The member can send an appeal to their Home Plan,

or you as the provider can appeal on behalf of the member. Submit an appeal to BCBSRI and our

GAU department will submit the appeal to the member’s Home Plan.

Q: Does Blue Cross Blue Shield of RI plan on lifting the frustrations for the physician practices

for a short period of time on High Tech Radiology authorizations, since most offices had to

downsize staff.

A: At this time BCBSRI will not be waiving any authorization requirements unless it is related to

a COVID treatment. However, during the COVID-19 pandemic, eviCore has increased their

authorization span from 90 to 180 days. Any authorizations that are already loaded into our

system prior to eviCore updating their system will be updated on April 20, 2020. This will

eliminate the burden of you as the provider having to call and/or request a new authorization.

Obtaining new authorizations will result in overlapping dates and could result in claim denials.

This information was loaded to our Alerts and Update section on March 30th and placed in our

April 1st provider update.

Q: What happens if / when the patient loses blue cross coverage between the telehealth well visit

and the subsequent face to face visit? Do we get paid for both parts?

A: We have reviewed our subscriber agreement and the regulatory language. If the member’s

coverage terminates between the telemedicine visit and the in-person/physical exam, we will not

cover the in-person/physical exam.

Q: What is the anticipated time for the claims pend?

A: Two weeks up to 30 Days

Q: We are doing Telemedicine with a diagnosis that may have nothing to do with Covid-19 but

to keep them out of the office. Should these claims also be paid with no cost sharing or

deductibles? This weeks settlements have a lot of telemedicine that processed with

copays/deductibles, etc.

A: Yes they should be paying with no cost sharing as long as it was billed with a CR modifier and

the 02. If the claims did not have the CR and or 02 you can submit a corrected claims to re

adjudicate. If they did you can contact provider relations at [email protected].

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Q: Is it possible to bill out a UB04 claim for outpatient department visits? For example a Diabetes

Education visit that we would usually bill via a UB04 claims submission.

A: Yes, because you wouldn’t be putting a place of service on the UB we will be looking for the

CR modifier on the UB claim which tells us that is being performed for Telemedicine with a type

of service 013X.

Q: Medicare is allowing more than one Critical care visit per day during this crisis. Is Blue Cross

allowing the same?

A: Yes we would.

Q: Please clarify which modifier is to be used for the Medicare Advantage product. GT or CR?

A: For BCBSRI Medicare Advantage product, it would be the CR modifier.

Q: If a specialists is consulting on inpatients by reviewing the patients chart, testing is this

billable as a telemedicine if the patient is not involved in the visit.

A: Yes as long as all elements are billable through telemedicine. Ensure documentation.

Additional Questions from 04/15/2020 Call

Q: What happens if / when the patient loses blue cross coverage between the telehealth well visit

and the subsequent face to face visit? Do we get paid for both parts?

A: We have reviewed our subscriber agreement and the regulatory language. If the member’s

coverage terminates between the telemedicine visit and the in-person/physical exam, we will not

cover the in-person/physical exam.

Q: Regarding the waiver of cost sharing, how do we identify if a policy is eligible?

A: Confirm the benefits and eligibility through the provider portal. We are still working to finalize

the list of self-funded employers who have opted out of the TEMPORARY Cost Share Waiver for

Treatment of Confirmed Cases of COVID-19 and the TEMPORARY Encounter for Determination

of Need for COVID-19 Diagnostic Testing policies and will communicate an update once finalized.

Q: Many patients that have been serviced through telemedicine visits would prefer to continue

this in the future. Will your requirements change when the pandemic is over?

A: At this time BCBSRI’s TEMPORARY Telemedicine/Telehealth and Telephone Services

During the COVID-19 Crisis – Effective 3/18/20 policy and its prior temporary policies) are in

fact temporary as outlined in those policies. BCBSRI has not contemplated the expansion of

benefits/coverage after the time the COVID-19 crisis has subsided. Pleases be assured that

BCBSRI will keep its provider community updated via BCBSRI.com related to this and any other

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policy updates. While we’re allowing for phone calls during this crisis, we feel strongly that best

practice for mental health treatment involves a visual component, where you are able to both see

and hear your client. Because of this, after this temporary policy expires, we would return to

covering telemedicine visits with both audio and video components and face to face treatment

only.

Q: For Annual Wellness Visits (Medicare) If we have a nurse, working remotely, is she able to

perform the components of the annual wellness visit (majority of this portion of the visit is driven

by assessments) without a doctor a being present, and then bill that visit under the PCP? One of

the practices has a nurse that is furloughed, because that is what she was doing in the office.

A: BCBSRI allows for PCP practices flexibility in how they elect to perform the components of

the AWV either in the office or via Telemedicine/Telephone during the timeframe the Temporary

Policy is in place. If a practice believes it is reasonable and the RN is adequately trained to

administer the assessments and document the responses etc., BCBSRI does not prohibit it.

However, BCBSRI requires the billing NP, PA or PCP to review the assessments/medical record,

document any necessary notes in the chart/medical record, document the need/order for any labs,

follow up referrals, visits, etc. and document in the chart if the BP wasn’t taken and needed on a

subsequent visit, etc. and indicate the scheduling of follow-up exam after COVID crisis. By way

of the review of the AWV encounter the NP, PA or PCP is allowed to bill for that visit under their

NPI number.

Q: They know the visit is broken into two components, is there a timeframe to return for the

visit?

A: The policy doesn’t specify a time frame for the return visit as it is not clear when it will be

safe to resume regularly scheduled in office visits.

Q: In the first part/telemedicine annual wellness visit, they tell you their height, weight, bp, is that

acceptable?

A: Yes, if the patient has a home scale and a BP machine and those readings can then shown to

the clinician via video during that visit that is acceptable. BCBSRI does not believe that is

reasonable for the member to provide this information over the phone as the clinician that is

documenting the information is not able to tell if the patient is properly taking/interpreting the

results or if the devices are in reasonable working order.

Q: What if you complete the first part and you cannot get the patient back for the second part of

the visit and how should Coastal providers indicate the second half of the visit could not be

rendered?

A:

A claim should be submitted for the first half of the visit on the date of service the

encounter takes place.

Attempts noted to bring the patient into the office should be noted in the EMR.

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If the patient does not present for the second half of the visit, there would not no notice to

BCBSRI or claim made. Please note that if the practice was not able to perform part of the

visit e.g., BP or weight then the practice/BCBSRI wouldn’t have the information for

HEDIS and gaps in care, etc.

Q: Knowing there are separate (and overlapping) components of an annual wellness visit

compared to an annual physical. The provider performs the first half of the visit. When safe to see

the patient for the second half of the visit, can we bill for the second half of the annual wellness

visit AND the annual physical (when those elements are completed).

A: When the 2nd part of the AWV exam happening on the same date of service as the annual

physical exam, BCBSRI would in fact allow the code for the annual physical exam to be billed

and reimbursed on that day along with any other services that were provided. However, BCBSRI

wouldn’t expect to be billed for the AWV G code on that date of service because that would have

presumably be billed on initial Telehealth/Telephone DOS.

Q: Annual wellness visits and physicals can each be done once a year – is the timeframe for

which these visits can be completed based on 12 months from the original visit, or anytime within

the following calendar year?

A: Anytime within the next calendar year as for Medicare Advantage these are plan year benefits.

However, for obvious clinical reasons it makes sense to have these visits occur as close to 12

months apart as reasonable possible.

Q: Physicians are doing subsequent Wellness visits telephone only as some elderly patients do

not have audio. Will this service pay as this service is not an exam?

A: We would expect the second visit to be in person and not billed with POS 02.

Q: Are referrals being waived for All Blue Cross plans now?

A: No not all. CMS has directed all Medicare Advantage plans to waive the referral requirement

effective 03/01 and State of Rhode Island’s (SORI) referral waiver is specific for their

employee’s. No changes have been made to commercial plans. No changes have been made to

commercial plans and all existing referral requirements remain in place.

Q: Is Federal Blue Cross following the same guidelines. I was told the no cost share policy only

applies to COVID related visits?

A: FEP is only waiving cost share for COVID19 related visits. FAQ sheet for FEP questions on

Provider Portal.

Q: We have a hospital based PHP/IOP program. Billing for this service takes place on a UB04.

We would like to provide this service using telehealth. We can append the GTCR modifier on the

HCPC/CPT line item but cannot provide POS on a UB04. Will the claim be accepted and paid

using our PHP/IOP case rate?

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A: Yes we are allowing hospitals to bill for PHP/IOP. You will bill on the UB-04 form with a

type of bill 013X with the CR modifier in any position.

Q: Did CMS release the dates of service where referrals would be waived for Medicare plans?

A: They will be backdated to 03/01/2020.

Additional Questions from 04/22/2020 Call

Q: As we are getting ready for the stream of discharges coming out of the hospitals, we are

putting together a plan for patients to have follow up visits with a PCP in 3-5 days from

discharge. Because of the current situation we may have providers covering for each other. One

of the questions that came up is, if a patient sees a provider for follow up but that is not their

“assigned” PCP will their claim be paid?

A: If a BCBSRI member sees a PCP that is not assigned to them, the claim will process according

to that member’s benefit (PCMH / PCP / Specialist) for an in-person visit. It should not deny. The

covering PCP under the same TIN is the best scenario for claims processing. If the provider does

a telephonic visit and files with the place of service 02 and CR modifier there will be no member

cost share, per the temporary telemedicine policy.

Q: Regarding the waiver of cost sharing, how do we identify if a policy is eligible? It has been

said that some self-insured companies may opt out of the cost sharing for telephone visits,

although, it was also said that so far none had. How do we identify patients of self-insured

companies? Is it indicated on their insurance card? Maybe by the prefix?

A: BCBSRI has six self-insured groups noted below who have opted out of the TEMPORARY

Cost Share Waiver for Treatment of Confirmed Cases of COVID-19 During the COVID-19 Crisis

Policy. Claims processed for these groups with a confirmed COVID 19 diagnosis will apply the

members plan benefits as defined. Other COVID-19 policies apply to these groups. If you have a

question regarding what cost sharing will be applied please confirm the benefits and eligibility

through the provider portal.

Group Name: Prefix:

AmWins AFI

Encore Holding NRE

Toray Plastics VVT

South County Hospital ZBF (Check benefits for group name)

ATW WAT

Athena Healthcare ZBF (Check benefits for group name)

Q: How do we address the claims from Plan 65 where the CR modifier wouldn’t be appropriate

for Medicare, but needed for Blue Cross Plan 65?

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A: Our policies do not apply to Plan 65 plans it would be up to CMS guidelines according to

Medicare Requirements.

Q: For FEP members, what POS and modifier should be used for telehealth? Differences for

telephone vs video?

A: Yes they follow different guidelines. Please review our FEP guideline on our provider portal

where it speaks to coding for FEP telemedicine services.

Q: Are the out of state Blue Cross claims also being processed with no cost share to patients? I

am finding that I have to call the home plan and a lot of them are on the same page which then

requires another call to BCBSRI. Is that going to have to be the process going forward?

A: No. Different states have different payment policies. However, some plans may require

different modifiers like GT or 95. If you have examples of Blue Card claims not waiving cost-

share, please contact our Provider Relations team.

Q: How can I bill out the tent testing?

A: In BCBSRI's COVID-19 Diagnostic Testing Policy the following code is listed; G2023

Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2)

(Coronavirus disease [COVID-19]), any specimen source. This is the appropriate code to bill if a

provider is collecting a COVID-19 testing specimen. If the clinician performs the necessary

components/elements of a separately identifiable evaluation and management service (following

correct coding) and documents the services they provided in the patients chart, then the provider

can file for the applicable evaluation and management service. Please note as the service is

performed face-to-face the applicable member cost share will apply to the separately identifiable

evaluation and management service. If the patient already was evaluated over the phone or via

telemedicine and that encounter was billed by the clinician and the specimen collection was a

result of that encounter, it would not appear that a separately identifiable evaluation and

management service would occur or be appropriate to bill for the specimen collection.

Additional Questions from 04/29/2020 Call

Q: Will telemedicine be extended past 05/08 for no member cost share?

A: Per the TEMPORARY Telemedicine Telehealth and Telephone Services During the COVID

19 Crisis – Effective 3/18/20 policy, telemedicine /telehealth is covered until July 31st We

continue to monitor updates from the Governor. If any new updates come from the Governor or

BCBSRI impacting this policy will be communicated as soon as possible via our standard

communication channels on BCBSRI.com and via our weekly Provider Conference Call.

Q: Does BCBSRI require the clinician’s documentation for telemedicine (visual) or telephonic

(phone) service to include a notation that there was verbal consent for the visit?

A: The current Temporary Telemedicine Policy states the following:

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Telemedicine services provided in accordance with this policy are covered when all of the

following criteria are met:

1. The patient is present/participates at the time of service.

2. Services should be similar to real-time services with a patient.

3. Services must be suitable to provide via telemedicine and/or telephone, or clinically

appropriate and medically necessary and otherwise covered under the member’s benefit booklet

or subscriber agreement.

4. Services must be within the provider’s scope of license.

5. A permanent record of the telemedicine or telephone encounter must be

documented/maintained as part of the patient’s medical record.

6. Only the provider rendering services may submit for reimbursement for telemedicine/telephone

services.

There is no consent needed or provider notation of a consent as long as the member knows they

will be present and online with the provider.

Q: We suspect that we will need to maintain "social distancing" for many months. In order to do

so (and not continue with this catastrophic reduction in patient volume), we will Blue Cross

continue to support telehealth, even if not mandated by the state?

A: Right now, we are in the process of updating our TEMPORARY Telemedicine Telehealth and

Telephone Services During the COVID 19 Crisis – Effective 3/18/20 policy to extend the date to

July 31, 2020. When this policy is terminated, we have a telemedicine policy in place that can

still be followed. One this policy is terminated, we will probably include cost share going

forward.

Q: For the telemedicine visits that are covered in the future, will they continue to be paid at the

office visit rate?

A: BCBSRI has established a telemedicine workgroup that is evaluating BCBSRI’s current and

past policies. The workgroup will be making a recommendation regarding BCBSRI’s

Telemedicine Policy post COVID-19. The workgroup is connected with a few BCBSRI network

providers and other stakeholders to ensure a broad-based understanding of the provider

communities’ expectations regarding telemedicine post COVID-19. BCBSRI understands there

are concerns in the provider community related to what BCBSRI’s may allow for COVID-19 as

well as increased expectations from providers as well as members/patients regarding telemedicine

availability. Please be assured that BCBSRI is aware of the timely nature of decisions related to

telemedicine and will be notifying providers as soon as possible regarding any changes to its

current Temporarily Policies.

Q: As of 4/21 and 4/28 payment we are still seeing cost sharing on claims for patients who have

BCBSRI. The claims have been billed correctly with the correct modifier and place of service for

telehealth. Is BCBS going to automatically reprocess these claims? Also, BCMA is waiving cost

sharing for telehealth but all of our patients who have BCMA their claims were processed with

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cost sharing. Are we supposed to call provider services to have all those claims sent back to be

reprocessed with no cost sharing?

A: Claims for telehealth have to be submitted with POS 02 and CR modifier for cost sharing to

be waived. Extracts are being pulled but please email Provider Relations with examples to make

sure there are no other issues occurring. For BCBSMA, we will work with the Blue Card claims

team to determine if we know if Mass will be pulling an extract or what the next best steps are.

Q: Have any of the self-funded groups opted out of cost share? And how do we identify those

patients by their insurance cards?

A: BCBSRI has six self-insured groups noted below who have opted out of the TEMPORARY

Cost Share Waiver for Treatment of Confirmed Cases of COVID-19 During the COVID-19 Crisis

Policy. Claims processed for these groups with a confirmed COVID 19 diagnosis will apply the

members plan benefits as defined. Other COVID-19 policies apply to these groups. If you have a

question regarding what cost sharing will be applied please confirm the benefits and eligibility

through the provider portal.

Group Name: Prefix:

AmWins AFI

Encore Holding NRE

Toray Plastics VVT

South County Hospital ZBF (Check benefits for group name)

ATW WAT

Athena Healthcare ZBF (Check benefits for group name)

Q: Does BCBSRI cover serological (or antibody) tests for COVID-19?

A: Yes, BCBSRI covers in vitro diagnostic tests that are ordered by a physician or advanced

practice provider for COVID-19, including serological tests that meet the requirements of the

Families First Coronavirus Response Act (FFCRA), as amended by the Coronavirus Aid, Relief,

and Economic Security Act (CARES Act), and FAQ guidance issued April 11, 2020.

Additional Questions from 05/06/2020 Call

Q:

1) Will Virtual sessions going to be incorporated as common practice after COVID-19? and

will we be able to bill moving forward? Can we use Doxy.me?

2) I am an APRN-BC and have a solo practice in a building that is all commercial traffic; I

have many seniors who fear returning to office setting if the Governor opens offices

before June. Is there any possibility that BCBS will continue to offer payment for

telehealth visits? For homebound patients as well as providers who may be experiencing

post-surgical illness our businesses could continue without any hitches. Thoughts please?

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A: BCBSRI has established a Telemedicine Workgroup that is evaluating BCBSRI current and

past policies. The workgroup will be making a recommendation regarding BCBSRI’s

Telemedicine Policy post COVID-19. The workgroup is connected with a few BCBSRI network

providers and other stakeholders to ensure a broad-based understanding of the provider

communities’ expectations regarding telemedicine post COVID-19. BCBSRI understands there

are concerns in the provider community related to what BCBSRI’s may allow for telemedicine

post COVID-19 as well as increased expectations from providers as well as members/patients

regarding telemedicine availability. Please be assured that BCBSRI is aware of the timely nature

of decisions related to telemedicine post COVID-19 and will be notifying providers as soon as

possible regarding any changes to its current Temporarily Policies

Doxy.me is a HIPAA compliant platform that can be used once we reference back to BCBSRI’s

Telemedicine Service payment policy.

Q: When we submit claims for BC of Mass members via BC BS RI – do we use the CR modifier

as directed by BC of RI or do we use the GT as directed by BC of MA.

When will telehealth claims that took a copay be adjusted?

A: Plans that require a different modifier can be filed with their modifier and the CR modifier.

You can put the other plans modifier first and CR as the additional modifier.

If you have claims that are taking a copay, please send the claim numbers to

[email protected] to look into.

Q: Are co-pays being charged? If I am reimbursed as if they are, what is procedure?

A: Copays should not be taken on the claim if the claim is filed correctly. If the claim is filed with

POS 02 and the CR modifier and is still taking a copay, can you please send us claim numbers to

research. If you are seeing a member for telemedicine benefits and have verified their benefits

cover telemedicine during the pandemic, you should not be collecting a copay. You should only

be collecting a copay if the member’s self-funded group is not covering telemedicine cost share

waiver at this time. If you have claims that are taking a copay and believe they should not be,

please send the claim numbers to [email protected] to look into.

Q: Settlement claims I have been receiving are STILL indicating that subscribers are being

charged copayments. Can you please clarify the policy regarding copayments?

A: If you have claims that are taking a copay and believe they should not be, please send the

claim numbers to [email protected] to look into.

Q: Has the telehealth policy (by telephone only) been extended?

A: Yes, to July 31st

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Q: Regarding referrals, many of the specialist office still insist on the referral for Medicare

Advantage members even when staff tells them it's waived. Is there a way to get this info out to

the specialist providers?

A: We have communicated this information in our COVID weekly meetings and on our portal. If

you have an office that is making offices put referrals on file when they are not needed, please

contact [email protected] to educate the office.

Q: We are aware that Blue Cross wants time spent listed in all documentation, but claims

processing is not based simply on this, correct? It may be based either on time, complexity, etc.

Can you clarify?

A: Whatever you think justifies the code you are billing via telemedicine. This is to prove the

validity of the code if audited in the future.

Q: What modifiers are needed for New England Health Plans? A member said she called and was

told that GT, GO, or 95 was also needed in addition to CR.

A: If you have an NEHP member, submit both the CR modifier and the modifier of the home plan

GT, GO, or 95 etc.

Q: Is there a specific modifier I need to use to submit RI Medicare claims or do I use CR?

A: For BCBSRI yes you would use the CR Modifier and 02 place of service.

Q: Last week I asked if we need to call provider services for all BCBS Mass claims that

processed with a cost sharing when BCBS Mass is waiving them. Is there any update on that?

A: BCBSMA is doing an assessment on their claims and will be doing an adjustment for the

claims that processed with a cost share.

Q: Is the CS modifier only for COVID diagnosis and treatment visits?

A: No.

Q: Blue Cross of Arizona does not accept the CR modifier. What modifier do I use?

A: You need to call the home plan Arizona to see what modifier they are using.

Q: We have a lot of patients asking us this question..."If I have a deductible on my BCBSRI plan

and they are waiving cost sharing for telemedicine, what happens to my deductible? Does

anything get processed towards that?" We just don’t know exactly what to tell these patients.

A: No, the cost is not counting towards their deductible.

Q: If BCBSRI is secondary is it required claims go paper?

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A: You can submit these electronically as long as you follow the standard rules or drop them to

paper with the EOB from the primary insurance.

Questions from 05/13/20 provider call

Q: Can you please let us know how long the relaxed rules for telemedicine will continue? Many

of us will not be able to go to our offices in the near future because it is impossible to social

distance in a small office and it is also difficult to engage in talk therapy with masks on. Working

from home with the relaxed rulings around virtual platforms, practicing over state lines, etc. have

helped us reach so many people during this pandemic that we would not otherwise be able to

reach. As an experienced behavioral health clinician over 65, I am relying on telemedicine for the

indefinite future.

A: BCBSRI has established a Telemedicine Workgroup that is evaluating BCBSRI current and

past policies. The workgroup will be making a recommendation regarding BCBSRI’s

Telemedicine Policy post COVID-19. The workgroup is connected with a few BCBSRI network

providers and other stakeholders to ensure a broad-based understanding of the provider

communities’ expectations regarding telemedicine post COVID-19. BCBSRI understands there

are concerns in the provider community related to what BCBSRI’s may allow for telemedicine

post COVID-19 as well as increased expectations from providers as well as members/patients

regarding telemedicine availability. Please be assured that BCBSRI is aware of the timely nature

of decisions related to telemedicine post COVID-19 and will be notifying providers as soon as

possible regarding any changes to its current Temporarily Policies

Questions from 05/20/20 provider call

Q: Is there a term date for this temporary telehealth policy?

A: As of right now, it is July 31st.

Q: When the temporary referral requirement rule ends, are providers going to be given enough

time to make sure they obtain any referrals?

A: At the moment, there is no rescinded end date per CMS at this time. When the time comes we

will still allow providers to back date their referrals up to 90 days.

Q: Are RCC testing sites also part of cost share waiving?

A: For now yes.

Q: Will telehealth therapy groups be covered after the temporary policy ends?

A: We will be considering it, and will have more information as time gets closer to July 31st.

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Q: Do you anticipate that the telehealth policy will be extended beyond 06/05/2020 as we are

still encouraging social distancing?

A: We will be looking into what our next steps are within the next week.

Policy: TEMPORARY Telemedicine/Telehealth and Telephone Services During the COVID-19

Crisis – Effective 3/18/20

Questions from 05/27/20 provider call

Q: Are referrals still being waived until 07/31/20?

A: No referral requirement for BlueCHiP for Medicare members. BCBSRI is waiting for CMS to

issue updated guidance.

Q: Is there a resolution for Medicare crossover claims being denied for modifier GT used w/

Medicare

A: Our defect was resolved as of May 5th and an extract for reprocessing the effected claims was

submitted last week. Providers should start seeing adjustments.

Q: When will ambulatory surgery centers be opening?

A: We are not aware of the date but discussed that hospitals were starting to reopen and schedule

services.

Questions from 06/10/20 provider call

Q: The policy for Annual Preventive Visits completed by Telemedicine requires a face to face

visit to complete the elements of the annual well visit that could not be acquired through

video/phone. Does the second visit need to be completed by the same clinician or can another

clinician in the office complete the second visit?

A: From a claim and clinician perspective it does not need to be the same clinician or who

rendered the telemedicine portion of the AWV as long as it is a physician or a mid-level

practitioner.

Q: Is Blue Cross paying ALL patient deductibles and copays? I was told it depended on the plan.

If so, How long will this be happening for?

A: BCBSRI has six self-insured groups noted below who have opted out of the temporary Cost

Share Waiver for Treatment of Confirmed Cases of COVID-19 During the COVID-19 Crisis

Policy. Claims processed for these groups with a confirmed COVID 19 diagnosis will apply the

members plan benefits as defined. Other COVID-19 policies apply to these groups. If you have a

question regarding what cost sharing will be applied please confirm the benefits and eligibility

through the provider portal.

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Group Name: Prefix:

AmWins AFI

Encore Holding NRE

Toray Plastics VVT

South County Hospital ZBF (Check benefits for group name)

ATW WAT

Athena Healthcare ZBF (Check benefits for group name)

For all other plans, when the claim is filed correctly with the POS 02 and the CR modifier,

member cost share will be waived until 07/31 for all products.

Q: Medicare just did a mass adjustment on the audio calls but from the looks of their RA it

doesn't look like they crossed over to secondary’s such as Plan 65....what is the best way to send

those to blue cross...do they all need separate adjustment forms and EOB from Medicare?

A: Providers will need to drop their claim to paper, however providers will have to wait the 30

days per our policy.

Questions from 06/24/20 provider call

Q: It is my understanding that BCBS RI plans to continue to cover cost sharing for telehealth

until July 31st of this year. Is that correct?

Also, is BCBS weighing in on if/when they want providers to return to in person practice? The

general consensus among clients is they prefer to retain telehealth as an option as long as

possible.

A: Correct, at this time the policy is extended until 07/31. BCBSRI has established a telemedicine

workgroup that is evaluating BCBSRI’s current and past policies. The workgroup will be making

a recommendation regarding BCBSRI’s Telemedicine Policy post COVID-19. Provider Relations

will send an email, and post to our communication pages with any changes (alerts and updates

and monthly Provider Update). This workgroup is also evaluating what the future of telemedicine

looks like after 07/31 (or after the final extension date). Any communication regarding the look of

telemedicine after we terminate the temporary telemedicine policy, we will post all the

information through our communication pages (alerts and updates, email blast, & our monthly

provider update)

Q: Is no cost share true for all self-insured and out of state plans?

A: The list of self-funded groups that are not waiving cost share is included in this Q&A. Not all

out of state plans are covering cost share. It is recommended to check with the home plan for

benefits to be sure.

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Q: Is cost sharing waived for face-to face emergency room visits based on diagnosis or do we

need a specific modifier like CS.

A: The diagnosis code is what is needed. Please see our Temporary Cost Share Waiver for

Treatment of Confirmed Cases of COVID-19 policy.