CurrentNeighborhood Health Plan of Rhode IslandPolicy N/A

Temporary expansion of telemedicine and telephone-only services

Temporary policy expanding coverage and reimbursement for clinically appropriate, medically necessary telemedicine and telephone-only services for Neighborhood Health Plan of Rhode Island members during the COVID-19 emergency. Applies to Medicaid (excluding EFP), Integrity, and Commercial lines and a wide range of provider types.

Policy Summary

PayerNeighborhood Health Plan of Rhode Island

PolicyTemporary expansion of telemedicine and telephone-only services

Policy CodePolicy N/A

Change TypeContent and operational clarifications

Effective Dateon or after March 18, 2020

Next Review DateN/A

Key ActionPrior authorization requirements are waived for the telemedicine/telephone-only services outlined in this temporary policy.

SourceLink

POLICY UPDATE CHANGES

Language regarding implementation, modification, and termination of policy added.

Added emergency department and OHIC language regarding patient location; updated authorization and documentation requirements.

Format update only (no content changes) on 05/11/21.

100%reimbursement of in-office allowable for telemedicine/telephone encounters

POS 02POS code required to indicate telemedicine/telephone delivery

Modifier CRrequired claim modifier for catastrophe/disaster related services

Trek Health ingests and normalizes Transparency in Coverage data and payer policy updates to give provider organizations a clear view of how commercial reimbursement behaves across markets, payers, and services. Our platform transforms raw payer disclosures into structured intelligence that supports contract evaluation, payer negotiations, and service line strategy. By combining market benchmarks with ongoing policy visibility, Trek helps teams identify variability, risk, and opportunity in commercial reimbursement. The result is faster insight, stronger negotiating positions, and more informed financial decisions.

Coverage Criteria for Telemedicine and Telephone-only Services

General coverage criteria

Telemedicine/telephone-only services are covered when ALL of the following are met:

Telemedicine coverage criteria: The patient is present/participates at the time of service.

Telemedicine coverage criteria: Services are of an amount and nature equivalent to the same service when rendered face-to-face (sufficient to meet the components and/or requirements of the comparable face-to-face service).

Telemedicine coverage criteria: Services are medically necessary and otherwise covered under the member's benefit plan.

Telemedicine coverage criteria: A permanent record of the telemedicine/telephone communication(s) is documented and maintained as part of the medical record.

Follow CMS documentation standards; Neighborhood reserves the right to audit medical and administrative records.

Telemedicine coverage criteria: Services are within the provider's scope of license.

Allowed provider types

Covered provider types (temporary expansion):

Provider types allowed to bill telemedicine/telephone services: Primary care physicians; All medical specialists (MD, DO, NP, PA); Optometrists; Doctors of Podiatric Medicine; Chiropractors; Lactation Consultants; Physical, Occupational and Speech Therapists; Diabetes Educators; Nutritionists; Midwives; Urgent Care Centers; Emergency Departments; Retail Based Clinics.

Per OHIC Bulletin 2020-01, professional providers may provide service regardless of the patient’s originating site (including nursing facility or inpatient hospital).

Services delivered solely via email, text, fax, or patient portal are excluded from coverage under this temporary telemedicine/telephone policy. Likewise, brief patient communications that are incidental to an E/M visit (for example, reporting test results or providing educational materials) are not separately billable as telemedicine or telephone-only services. Administrative interactions such as scheduling, registration, updating billing information, reminders, refill requests, referral/orders, or patient-completed history intake are also excluded. Encounters conducted only by office staff (e.g., RNs, LPNs) without the treating professional present are not eligible for reimbursement as telemedicine/telephone services.

Services that are not clinically appropriate for remote delivery must not be billed as telemedicine/telephone encounters. The policy gives explicit examples: chiropractors may not bill for manual manipulation via telemedicine/telephone, and physical therapists may not bill for manual therapy services provided remotely. Billing for such services when they cannot be appropriately and safely delivered by telemedicine will be considered inappropriate.

Claim Coding and Reimbursement

Claim submission coding requirementsmixed

POS 02	Place of Service code to indicate service delivered via telemedicine/telephone
CR	Modifier CR (Catastrophe/Disaster Related) required on claims

Reimbursement — telemedicine/telephone encounters

Reimbursement rateNeighborhood will reimburse telemedicine/telephone encounters at 100% of the in-office allowable for any clinically appropriate, medically necessary covered health service.

Audit rightNeighborhood reserves the right to audit medical and administrative records to verify services, medical necessity, clinical appropriateness for telemedicine/telephone delivery, and E/M coding levels.

Documentation parityDocumentation requirements for telemedicine/telephone-only services are the same as those required for any face-to-face encounter.

Provider Actions, Authorization, and Documentation

Prior Authorization

Prior authorization waiver — Prior authorization requirements will be waived

Prior authorization requirements will be waived for telemedicine/telephone-only services under this temporary policy.

Prior authorization waived for telemedicine/telephone-only services effective for dates of service on or after March 18, 2020.
This waiver applies only to the telemedicine/telephone-only services outlined in this temporary policy.

Note

Medical necessity verification — Providers must verify eligibility/coverage

All services must be medically necessary to qualify for reimbursement. Providers are responsible for verifying eligibility, coverage, and any remaining authorization criteria prior to rendering services.

Neighborhood may use external criteria to determine medical necessity, including: National Coverage Determinations (NCD), Local Coverage Determinations (LCD), InterQual, EOHHS recommendations, and Neighborhood Clinical Medical Policies (CMP).
Providers should confirm member benefits and any plan-specific requirements via Neighborhood's Prior Authorization Reference page or Provider Services (1-800-963-1001).

Definitions

Telemedicine/telephone-only — definition & scope

DefinitionTelemedicine/telephone-only service: clinically appropriate, medically necessary covered health services delivered via telemedicine or telephone in place of an in-person visit.

Covered provider types (temporary)Primary care physicians; All medical specialists (MD, DO, NP, PA); Optometrists; Doctors of Podiatric Medicine; Chiropractors; Lactation Consultants; Physical, Occupational and Speech Therapists; Diabetes Educators; Nutritionists; Midwives; Urgent Care Centers; Emergency Departments; Retail Based Clinics.

Patient locationPer OHIC Bulletin 2020-01, professional providers may provide service regardless of the patient’s originating site (including nursing facility or inpatient hospital).

Coverage conditionsCovered when: patient is present/participates at time of service; services are equivalent in amount/nature to face-to-face; medically necessary and covered by the member's benefit plan; a permanent record of the telemedicine/telephone communication(s) is documented and maintained; services are within the provider's scope of license.

Background and Policy Scope

This temporary expansion of telemedicine and telephone-only coverage was implemented to support social distancing and reduce in-person visits during the COVID-19 emergency, consistent with Rhode Island state actions and guidance. The policy allows clinically appropriate services to be delivered remotely while maintaining that services remain medically necessary, within the provider’s scope of license, and documented equivalently to face-to-face encounters.