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Thank you for serving Health First Colorado (Colorado's Medicaid Program) and Child Health Plan Plus (CHP+) members. The Department knows providers will have many questions about COVID-19 and will post updates on policies, codes and other important information to providers on this site. Communications will continue to be sent out via bulletins and newsletters. Please sign up for updates on the Provider News web page.
For information about COVID-19 in Colorado, refer to the Department of Public Health & Environment website. This website includes special resources for health care providers on Patient Evaluation, Testing, Personal Protective Equipment and many more topics.
The below resources are additional guidance as it relates to Health First Colorado and CHP+ providers.
This information has also been posted on the Known Issues web page under Hospital-General, Independent Lab and Physician Services/Clinics.
Questions related to HCBS case management and service provision may be submitted to: HCPF_HCBS_Questions@state.co.us
Updated April 2, 2020 - Please check back here regularly for up-to-date information. You can also sign up for our COVID-19 newsletter.
Question: What providers are eligible for retainer payments? How do they work?
Answer (A): At this time, retainer payments are only allowable for Adult Day, Day Habilitation (Supported Community Connections and Specialized Habilitation) and Brain Injury Day Treatment providers that have stopped or reduced services in response to the novel coronavirus disease (COVID-19) pandemic. A retainer payment is billing for units authorized in a member’s service plan, even if services are not rendered due to the COVID-19 pandemic. Day Program service providers may bill at the full rate for the service, as indicated on the service plan and prior authorization request (PAR). Provider agencies will not be required to repay the retainer payment at a later date.
Q: How do Day Program service providers get retainer payments authorized and bill for the retainer payment?
A: If services for Adult Day, Day Habilitation (Supported Community Connections and Specialized Habilitation) and Brain Injury Day Treatment are suspended or reduced in response to the COVID-19 pandemic, providers may request authorization from case managers to bill retainer payments. Retainer payments may only be billed for active members in the amount, scope and duration authorized for the provider in the current service plan, with permission from the member and authorized by the Case Management Agency. If a member elects to receive services from a different provider, retainer payments may not be billed.
To authorize retainer payments, the case manager shall:
When billing a retainer payment:
Q: Will other services be approved for retainer payments, such as employment services or missed therapy appointments?
A: At this time, retainer payments are only allowable for Adult Day, Day Habilitation (Supported Community Connections and Specialized Habilitation) and Brain Injury Day treatment providers. The Department is working to determine the appropriateness and priority of expanding retainer payments for additional services, as allowed by the Centers for Medicare and Medicaid Services (CMS).
Q: Is Community Connector authorized to bill for retainer payments?
A: Community Connector (CC) is not considered in the Informational Memo 20-017 - COVID-19 Communication for Adult Day, Day Habilitation and Brain Injury Day Treatment Providers; however, CC providers can limit outings, meet in alternative locations or use technology solutions as necessary. The Department is working to determine the appropriateness and priority of expanding retainer payments for additional services, as allowed by the Centers for Medicare and Medicaid Services (CMS).
Q: Is there emergency funding or relief for Residential Providers at this time?
A: The Department is working with the Centers for Medicare and Medicaid Services (CMS) on additional ways to support our home and community-based services (HCBS) providers that continue to provide services during this time.
Q: What changes have been made to telehealth and telemedicine policies?
A: Throughout the COVID-19 pandemic, Health First Colorado (Colorado’s Medicaid program) is temporarily expanding its telemedicine policy to authorize the following:
Get additional guidance and visit our Telemedicine webpage for the most up-to-date guidance.
Q: May therapeutic services offered through home and community-based services be conducted through virtual visits?
A: Yes, therapeutic services may be conducted through virtual visits. To minimize physical contact between providers and members, the Department has issued an Operational Memo to provide alternative provision allowances. Please review Operational Memo 20-020 - COVID-19 Communication for HCBS Behavioral Therapy, HCBS-Bereavement Counseling, HCBS-Expressive Therapy, HCBS-Mental Health Counseling, HCBS-Movement Therapy, and HCBS-Therapeutic Life Limiting Illness Support Providers for further guidance for the following services:
Providers conducting virtual visits must document services rendered in the virtual format within the care plan. Providers shall bill for services just as they currently do according to the Prior Authorization Request (PAR). Providers will not bill using telemedicine procedure codes, will not change the place of service on the claim to “Telemedicine”, nor do they need to modify their Medicaid enrollment.
Q: What other HCBS services are approved to be provided through virtual visits?
*Brian Injury Waiver (BI), Children’s Extensive Supports Waiver (CES), Children’s Habilitation Residential Program Waiver (CHRP), Children with Life-Limiting Illness Waiver (CLLI), Community Mental Health Supports Waiver (CMHS), Developmental Disabilities Waiver (DD), Elderly, Blind, and Disabled Waiver (EBD), Spinal Cord Injury Waiver (SCI), Supported Living Services Waiver (SLS)
Please refer to Operational Memo 20-024 - Changes to Benefits and Services in Response to COVID-19 for more information pertaining to the temporary changes to waiver benefits.
Q: How do we document or bill for virtual visits? Does the case manager need to be notified?
A: Providers who conduct virtual visits must clearly document services rendered in the virtual format within the care plan and notify the case manager of the change in service delivery. Providers should continue to bill for services just as they currently do according to the approved PAR. Providers will not bill using telemedicine procedure codes, will not change the place of service on the claim to “Telemedicine”, nor do they need to modify their Medicaid enrollment.
Q: Can I use non-Health Insurance Portability and Accountability Act (HIPAA)-compliant free conferencing tools (like Apple FaceTime and Zoom) for assessments or rendering services approved for virtual visits?
A: The new waiver in Section 1135(b) of the Social Security Act explicitly allows the Secretary to authorize the use of telephones that have audio and video capabilities for the furnishing of Medicare telehealth services during the COVID-19 pandemic. In addition, effective immediately, the Health and Human Services Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers who serve patients in good faith through everyday communications technologies, such as Apple FaceTime or Skype, during the COVID-19 nationwide public health emergency. For more information please reference: OCR announces notification of enforcement discretion for TELEHEALTH REMOTE COMMUNICATIONS during the COVID-19 nationwide public health emergency.
Q: Does the Department cover services delivered over the telephone?
A: The Department is covering some home and community-based services (HCBS) when provided over the phone, as a virtual delivery method. The integrity of the service must be maintained when providing services over the telephone. Please review Operational Memo 20-020 and Operational Memo 20-024 for further information. Not all HCBS waiver services may be appropriately delivered via telephone. Providers must use their professional judgment when determining if a service is appropriate for virtual service delivery.
For any questions related to telemedicine and State Plan services, including Physical Therapy, Occupational Therapy and Speech Therapy, please check the Department’s web page Telemedicine - Provider Information for updates.
Q: How should providers contact Case Management Agencies (CMAs) to tell them about agency closures?
A: Providers suspending or reducing services due to COVID-19 are required to notify members and their case managers by phone or email within 24 hours of the decision to suspend or reduce services. Providers should provide the CMA with a list of members impacted. Operational Memo 20-021 - HCBS Provider and Case Management Action Required for Closures Related to COVID-19 further details how to reach a CMA about agency changes in services.
Q: Are there alternative ways to perform the Supports Intensity Scale (SIS) assessments during the COVID-19 public health emergency?
A: SIS assessment interviews shall be conducted by alternative methods, such as video conference and telephone. If a case manager determines the member requires a Support Level Review based on an increased need due to COVID-19, the case manager may send in a Support Level Review request as normal.
Q: Can quarterly monitoring contacts be conducted via video conference or telephone?
A: Case managers should utilize electronic video (such as Apple FaceTime, Skype or Zoom) to complete routine monitoring unless the member only has the option to use a telephone. The case manager shall log a note in the Benefits Utilization System (BUS) indicating the communication method used to complete the monitoring. For non-routine contacts that may require face-to-face interaction, such as performing an investigation into a member’s health and welfare, the case management agency must follow COVID-19 Centers for Disease Control (CDC) guidelines for precautions and social distancing. Any monitoring that does not require face-to-face contact is required to be completed. For more detailed guidance, refer to the Operational Memo 20-018 - Case Management Operational Changes in Response to COVID-19.
Q: Can we use video conferencing and telephone to conduct Case Management Investigations?
A: While components of a case management investigation may be able to be completed via telephone or other video conferencing, there may be activities that require an in-person presence as noted in the Operational Memo 20-018 - Case Management Operational Changes in Response to COVID-19. Any in-person activities should follow COVID-19 Centers for Disease Control (CDC) guidelines for precautions and social distancing.
Q: How does this public health emergency affect the Human Rights Committee (HRC) procedures?
A: HRC meetings can be conducted by alternative methods, such as video conference and telephone. All requirements for HRC, including informed consent, remain.
Q: Has there been any change to emergency enrollment requests for the Home and Community-Based Services Waiver for Persons with Intellectual and Developmental Disabilities (HCBS-DD) waiver?
A: There have been no changes to the emergency enrollment request process. Community Centered Boards (CCBs) may continue to submit requests to the Department for those individuals who are seeking enrollment into the HCBS-DD waiver.
Q: What communications will be sent to Program Approved Service Agencies (PASAs) or approved providers about both Case Management Agency (CMA) core work changes and any provider-specific direction?
A: Department communication regarding PASAs and approved providers about CMA core work changes due to COVID-19 will continue to be made available through the Department Memo Series and captured on the Department COVID-19 website. Changes to case management or provider requirements are combined into joint memos to both audiences whenever applicable. All changes are communicated utilizing the Memo Series.
Q: Do case managers need to complete a Service Plan revision if providers are using a different location to furnish the same services?
A: Case managers do not need to complete a service plan revision for a change in service delivery location. Please refer to Operational Memo 20-024 - Changes to Benefits and Services in Response to COVID-19 for more information pertaining to the temporary changes to waiver benefits.
Q: Is there any change to critical incident reporting? Are presumptive or confirmed cases of COVID-19 required for a member?
A: Critical incidents involving COVID-19 must be identified through the documentation fields in the Benefits Utilization System (BUS). The Department released Operational Memo 20-022 - Critical Incident Reporting for COVID-19 to provide guidance regarding Critical Incident reports when a member reports they have a presumptive or confirmed case of COVID-19. For the Family Support Services Program (FSSP), State Supported Living Services (SLS) and Omnibus Reconciliation Act (OBRA) program, case managers will enter COVID-19 in the Critical Incident Reporting System (CIRs) in the existing DDDWeb/CCMS system and send a notification email to firstname.lastname@example.org. Please note there is not a drop-down option in this system for COVID-19; therefore, the case manager must enter COVID-19 into the text field.
Q. Are case managers able to accept electronic signatures on member paperwork?
A. Case managers can accept an electronic signature on forms requiring a member or legal guardian signature. Please refer to Operational Memo 20-027 - Changes to Signature Requirements for Member Paperwork in Response to COVID-19 for Case Management Agencies.
The Department of Health Care Policy & Financing (Department) knows LTSS stakeholders and providers have many questions about COVID-19 and its implications for service delivery, case management, payment, operational changes, etc. and would like to invite interested parties to participate in an informational webinar to address these questions.
The Department is hosting several COVID-19 informational webinars for different audiences, listed below. The webinars are limited to 500 attendees, so we ask that you please only attend the webinar that most relates to you. Each webinar will largely contain the same information but given the amount to cover information will be targeted to each audience. All webinars will be recorded and posted here.
April 10, 2020 - 12 p.m. - 1:15 p.m. MST
Webinar Call-in Information:
Local: 720-279-0026 / Toll Free: 1-877-820-7831
Participant Code: 303146#Webinar Link
April 10, 2020 - 10:30 a.m. - 11:30 a.m. MST
Webinar Call-in Information:
Local: 720-279-0026 / Toll Free: 1-877-820-7831
Participant Code: 303146#Webinar Link
April 3, 2020
March 27, 2020
March 20, 2020
March 18, 2020
March, 27, 2020
March 19, 2020
For local public health agencies and healthcare providers only:
From Monday through Friday, 8:30 a.m.- 5:00 p.m., please call 303-692-2700.
For after-hours, holidays, and weekends, please call 303-370-9395.
For general questions about COVID-19:
Call CO-HELP at 303-389-1687 or 1-877-462-2911.
Email COHELP@RMPDC.org for answers in English.
Contact the Provider Services Call Center for billing questions.