Indiana Medicaid Issues Temporary Changes to Telemedicine Billing Rules

The Indiana Health Coverage Programs (IHCP) has issued new billing guidelines for health care providers providing services to patients using telemedicine resources. This guidance is effective starting with services provided on March 1, 2020 and will remain in effect as long as Governor Holcomb's Declaration of Public Health Emergency (Executive Order 02-20) issued March 6, 2020, remains in effect. This guidance is applicable to all services covered by the Indiana Medicaid program, both traditional Medicaid and all managed care benefit programs (with a few exceptions for those services that require a physical interaction[1]), and to both in- and out-of-state service providers, as long as the services provided to Indiana Medicaid beneficiaries are within the scope of the health care provider's license. 

During this time period, telemedicine services may be provided using any technology that allows for real-time, interactive consultation between the patient and the provider. This includes the use of computers, telephones and television monitors. It does not include non-voice communication methods such as emails or text messages. IHCP has been able to expand the allowable forms of telecommunication for telemedicine services because of the federal waiver of certain HIPAA requirements and warns that this expansion is subject to change based on federal policy and guidance.

Providers should be aware that the same limitations and restrictions that apply to in-person services still apply to services provided via telemedicine. These include the requirements for providers to obtain the patient's consent prior to the delivery of services and the need for appropriate documentation to substantiate the services provided. Specifically, the documentation must indicate that the services were rendered via telemedicine and clearly identify the location of both the provider and the patient and must be available for post-payment review. During this time, it is permissible for both the patient and the provider to be located in their homes during the provision of the telemedicine services.

As a reminder, Indiana law permits a provider with prescriptive authority to use telemedicine to prescribe a controlled substance to a patient who has not been previously examined by the provider; however, opioids cannot be prescribed via telemedicine unless the opioid is a partial agonist (such as buprenorphine) and is being used to treat or manage opioid dependence.

For more information on the temporary changes to the requirements for reimbursement for telemedicine services and more specific billing information, please go to IHCP Bulletin BT202022 at http://provider.indianamedicaid.com/ihcp/Bulletins/BT202022.pdf or contact Taryn Stone at taryn.stone@Icemiller.com or Margaret Emmert at margaret.emmert@icemiller.com.

This publication is intended for general information purposes only and does not and is not intended to constitute legal advice. The reader should consult with legal counsel to determine how laws or decisions discussed herein apply to the reader’s specific circumstances.