OASAS Reg. Waiver Draft sent to providers May 12
May 13, 2020
Please see below trail for answers provided by OASAS (very promptly!) to questions from a NYS Council member agency relating to yesterday’s OASAS email to providers with subject line “Regulatory Waiver draft ” (See bottom of this trail for a copy of the email and see attached for the document.)
Question:
- Is this waiver in effect immediately given that the document indicates “draft”?
Answer: Yes, providers should begin and/or continue acting in accordance with this guidance document. Once the guidance is finalized it will be effective retroactive to the beginning of the declared COVID-19 Emergency Period, March 16, 2020.
From a regulatory compliance standpoint OASAS Auditors will not penalize providers who follow the directive to act in accordance with the guidance.
Question
2. Can you explain the Reduction in Minimum Billing Requirements? Is Telephonic being reimbursed differently than other means of Telepractice? What rate codes, procedure codes should we be using?
Answer: The changes reduce the required minimum timeframes required for each service and differ depending on the mode of delivery (telephonic v Telepractice). Generally telephonic services require less time to constitute a billable service than Telepractice (audio/visual) or in person. The reimbursement amount is the same. (see chart below for examples). The rate codes/procedure codes are the same for telephonic, Telepractice or in-person services and are within the OASAS APG Clinical and Billing Guidance.
Example: Individual Counseling, Group Counseling, and Family Collateral w/patient, delivered by telephone and Telepractice other/in-person in a Freestanding Outpatient Program.
| Delivery | Rate Code | Service | Procedure Code | Time Minimum Now | Reimbursement Current | Time Minimum Waiver | Reimbursement Waiver | ||
| Upstate | Downstate | Upstate | Downstate | ||||||
| Telephonic | 1540 | Individual Counseling Brief | G0396/90832 | 25 | $93.16 | $109.00 | 15 | $93.16 | $109.00 |
| Group Counseling | H0005/90853 | 60 | $48.14 | $56.33 | 15 | $48.14 | $56.33 | ||
| Family Collateral w/ Patient | 90847 | 30 | $186.33 | $218.02 | 5 | $186.33 | $218.02 | ||
| Telepractice other/in-person | 1540 | Individual Counseling Brief | G0396/90832 | 25 | $93.16 | $109.00 | 19 | $93.16 | $109.00 |
| Group Counseling | H0005/90853 | 60 | $48.14 | $56.33 | 45 | $48.14 | $56.33 | ||
| Family Collateral w/ Patient | 90847 | 30 | $186.33 | $218.02 | 23 | $186.33 | $218.02 |
Question:
- Do these reduced time frames apply to services delivered by any practitioner including clinician, peer, physician, NP, RN, etc?
Answer: Yes, as long as the practitioner meets the requirements for providing the service.
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From: OASAS Executive Office <ALL-PROVIDERS-L@LISTSERV.OASAS.NY.GOV> On Behalf Of OASAS.sm.Communications
Sent: Tuesday, May 12, 2020 2:59 PM
To: ALL-PROVIDERS-L@LISTSERV.OASAS.NY.GOV
Subject: {EXT}COVID Regulatory Waiver Draft
Dear Provider;
OASAS has requested regulatory relief in response to the COVID Emergency to support the provision of Substance Use Disorder treatment during this emergency. The waiver addresses issues such as Essential Services, Staffing, Consents, Treatment Plan requirements, billing requirements, etc.
The attached draft document outlines the adaptations being sought under the waiver. The waiver is currently being finalized for approval. Providers should act in accordance to the guidance given in this document. Further information regarding this waiver will be provided once it is available.
Please forward your questions to: legal@oasas.ny.gov or PICM@oasas.ny.gov