Covid-19

CPA’s lobbyist Anita Schepker, JD, of Capitol Consulting reached out on our behalf to the CT Department of Public Health to request a change to the CE requirements for Psychologists from in-person to virtual.  Since the CE requirements are in statute, the Governor will need to do an Executive Order to change the in-person requirements.  Keep an eye out for a definitive answer.  

As many of us learned on Monday 3/23, the Commissioner of the CT Department of Public Health signed an order that allows psychologists, among other specified practitioners, licensed in another state to work in CT without obtaining a CT license for up to 60 days.  CPA sought clarification from the DPH and this order does include telepsychology. 

Governor Lamont released a new Executive Order 3/19/20 

The following is CPA’s synthesis of the information relevant to psychologist and mental health services providers. It is intended to facilitate providers in rapidly moving forward in providing continuity of care but should not replace an individual provider’s responsibility to read over the full executive order for themselves.

https://portal.ct.gov/-/media/Office-of-the-Governor/Executive-Orders/Lamont-Executive-Orders/Executive-Order-No-7G.pdf 

Psychologists and Mental Health Service Providers:

1. Telehealth Executive Orders:
   1. Medicaid and In network providers with Commercial Insurance carriers:
      1. The definition of “Telehealth” has been expanded to include audio-only telephone services (for Medicaid and In network providers with commercial Insurance carriers) for patients with EXISTING provider-patient relationship.
      2. Registration or certification of the provider for permission to provide telehealth services, as typically required for commercial insurance carriers, has been waived (for Medicaid and in network providers with commercial insurance carriers). Providers should look for further guidance from the CT Commissioner of Public Health about this.
   2. Non-Medicaid and Out of Network Providers:
      1. Prior to engaging patient in Telehealth, determine if patient is covered by a health insurance plan and whether the plan includes Telehealth services. If you receive payment from the insurance company, providers CANNOT bill a patient for any additional charges beyond reimbursement received under such health plan.  
      2. If the patient is uninsured, or does not have telehealth coverage through their insurance policy, providers can accept payment equivalent to what Medicare typically reimburses for such service.  
      3. If the patient is uninsured or unable to pay for telehealth services, the provider should offer financial assistance in compliance with state and federal laws.  

1. HIPAA:
   1. Providers adhere to modifications made regarding HIPAA as stated by Department of Health and Human Services, which states that attempts should be made to conform to typical HIPAA requirements.  However, during the COVID-19 crisis, providers can utilize non-HIPAA compliant telehealth platforms for continuity of services and penalties will be waived. Please refer to HHS statement released 3-17-20: https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html. 

1. Location of Services:
   1. Providers are not required to provide services from their “facility”, meaning providers can be located in their homes. 

1. Abuse Reports/Investigations:
   1. In-person investigations have been waived.  Investigation times have been extended to 90 days.  

Information on Essential and Non-Essential Employees

NML EO 7H – 9th COVID-19 RESPONSE ORDER 03.20.2020.pdf

Guidance on the Essential Critical Infrastructure Workforce.pdf

Governor Lamont’s administration takes steps to mitigate the economic effects of COVID-19 3-13-20:  

• The CT Department of Social Services expanded telemedicine coverage for those under HUSKY/Medicaid.  We provide more information below.  
• The CT State Department of Education received a waiver from the federal government allowing students who receive meals under the school lunch program to continue receiving those meals during school closures and consume them at home.  They also removed the 180 day requirement for public school attendance.
• The CT Department of Labor announced modifications to unemployment insurance.
• The CT Department of Economic and Community Development is working with small businesses to assist with COVID-19 impact.  If your practice falls in this category, you may be eligible for a small business loan.
• The CT Public Utilities Regulatory Authority ordered a moratorium on all utility shut-offs.