Disaster & Emergency Telehealth and Related Benefit Flexibilities
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Defines temporary Montana Medicaid flexibilities to permit and reimburse telemedicine/telehealth (including telephone and messaging), suspend or extend prior authorizations, adjust prescription day supplies and refills, and add limited waiver supplies during the COVID-19 state of emergency. Affects Montana Medicaid members, providers, and waiver programs during the declared emergency.
Montana Medicaid will permit qualified providers to deliver reimbursable telemedicine/telehealth services (including telephone and live video).
Temporarily suspend Medicaid fee-for-service prior authorization requirements and extend pre-existing authorizations through the termination of the emergency declaration.
Change Montana will cover a maximum of a 90-day supply for all drugs excluding Schedule II drugs and relax 'too-soon' refill edits to allow 50%.
Temporarily add personal health and safety items (gloves, hand sanitizer, masks) to waiver benefits with a $50/month limit per waiver member.
Emergency Coverage Flexibilities for Telehealth and Related Benefits
Emergency Flexibility Criteria
Coverage flexibilities during the declared state of emergency:
Approved effective 3/1/2020; aligned with state of emergency (EO No 2-2020).
Providers should track when suspensions end to reinstate normal PA processes and retain authorization records showing original approval and dates.
Approved effective 3/1/2020; some measures limited through 7/24/2020.
Approved effective 5/1/2020 through 1/26/2021 under 1915(c) Appendix K.
Before the declared state of emergency, Montana Medicaid's telehealth policy explicitly stated that telephonic services were not reimbursable. Effective 3/1/2020, Montana Medicaid changed that stance under emergency authorities and will permit qualified providers to deliver and be reimbursed for clinically appropriate, medically necessary services via telemedicine/telehealth including telephone and live video. This change was approved to align with the state emergency declaration (EO No 2-2020) and is intended to maintain access to care during the emergency.
The emergency flexibilities described in this document do not include any explicit statements designating those flexibilities as not medically necessary. The policy language focuses on temporarily permitting and reimbursing additional telehealth modalities (for example, telephone and messaging) and aligning effective dates with the state of emergency rather than listing emergency flexibilities as noncovered or not medically necessary.
Provider Requirements, Prior Authorization, and Documentation
Temporary suspension and extension of prior authorizations
Prior authorizations in Medicaid fee-for-service and HCBS waivers are temporarily suspended and pre-existing authorizations are extended through the termination of the emergency declaration under Section 1135 authority.
Medication prior authorization automatic renewals
Prior authorizations for certain medications may be automatically renewed during the emergency without clinical review; this automatic renewal policy was approved effective 3/1/2020 and limited through 7/24/2020 per the document.
Document and retain existing authorizations
Pre-existing prior authorizations are extended through the termination of the emergency declaration; providers should retain authorization records showing original approval and dates to support continued services.
Ensure telehealth confidentiality at originating site
Originating-site providers must ensure secure and appropriate equipment to maintain confidentiality for telehealth encounters, including cameras, lighting, transmission safeguards and other necessary electronics.
Risk of denial when PA requirements are reinstated
If prior authorization requirements are reinstated after the emergency, failure to obtain any newly required documentation when extended authorizations expire could result in claim denials.
Background and Context
For the purposes of this policy, telemedicine/telehealth refers to delivery of clinically appropriate, medically necessary Montana Medicaid covered services by qualified providers using remote modalities. Telehealth involves two collaborating providers (an originating provider and a distant provider) who may be in different facilities or communities. Accepted delivery modalities under the emergency flexibility include live video, telephone, secure portal messaging, secure instant messaging, and other audio-visual conversations. Originating-site providers are required to ensure secure and appropriate equipment to maintain confidentiality (for example, camera, lighting, and transmission safeguards).
Key Definitions
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