Updates to Telehealth Policies for Assessment Services

Providers are encouraged to confirm member benefits and coverage provided by their health plan at the time of service due to the rapidly changing situation.

• Optum will review claims that may be impacted by cost-sharing waivers and reprocess them automatically. The provider will not need to request a claim adjustment or appeal.
• Due to the rapidly changing environment around patient cost-sharing waivers, providers may want to allow their claim to be fully processed before collecting any patient cost-sharing responsibility.

Optum is taking action to ensure health plan members affected by COVID-19 (coronavirus) have the support and resources they need. Optum recognizes that assessment (psychological and neuropsychological testing) plays an important role in the provision of mental health and substance use disorder treatment.

To support continued, necessary assessments for members, consistent with an applicable Notice of Enforcement Discretion from the Office for Civil Rights (OCR) at the Department of Health and Human Services (Notice), on a temporary basis, health care providers, qualified and licensed in accordance with applicable regulations,  may use audio or video communications technology immediately to deliver telephonic or telehealth care to members served by Optum Behavioral Health to conduct psychological and neuropsychological testing assessment services. Providers are responsible for adhering to the American Psychological Association (APA) guideline for the practice of telepsychology particularly Guideline 7: Testing and Assessment located at: https://www.apa.org/practice/guidelines/telepsychology.

During the COVID-19 nationwide public health emergency, providers should provide telehealth services in accordance with the OCR Notice. The OCR Notice contains information regarding applications that may be used to provide telehealth without risk that OCR might seek to impose a penalty for noncompliance with the HIPAA rules related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency.  

Optum has temporarily expanded our policies around telehealth services to make it easier for UnitedHealthcare members to connect with their behavioral health provider during the COVID-19 public health emergency. The Centers for Medicare and Medicaid (CMS) have waived telehealth originating site restrictions and extended the expansion of telehealth access for UnitedHealthcare Medicare Advantage members in accordance with the time frames listed below:

Commercial Membership:  The above flexibilities are effective for in-network providers through July 31, 2022 and are set to end effective August 1, 2022.  For out-of-network providers, these flexibilities may be applicable in accordance with the member’s benefit plan and as mandated by the state.

Medicare Advantage Membership:  This change in policy is effective as follows:

For in-network providers and out-of-network providers through the national public health emergency period, currently in effect through January 10, 2023.

Medicaid Membership:  State Medicaid guidance/mandates apply. If no mandate was issued, the expanded policy was applicable through June 17, 2020.

For information regarding our post-COVID Telehealth policy that will be in place after the  Flexibilities end, please review our Frequently Ask Questions here.

Links to other Health Plan COVID-19 sites can be found here.

In addition, providers should continue to:

• Be consistent with directives from the CDC and SAMSHA, health services that are not urgent should be postponed where possible. Providers should weigh potential benefits from rendering needed care against the potential weakened validity and reliability of assessment results if choosing to conduct testing via telehealth or virtual visit care. 
• Ensure the integrity of the psychometric properties of the tests or assessment procedures used:
  • Modifying the test environment as necessary to prevent access to cell phones, the Internet, or coaching from other persons during administration
  • Minimizing any potential distractions which could affect performance
• Ensure that additional consideration is given to issues that arise with testing diverse populations that could further lower reliability and validity of scores due to changes in administration procedures and the test environment
• Ensure the quality of the technologies being used and the hardware requirements needed are considered prior to starting testing:
  • Consideration should be given to the availability of back-up technologies should technical problems be encountered during administration
• Use HIPAA approved telehealth technologies as well as temporarily allowed popular applications that allow for video chats to provide telehealth in accordance with the OCR Notice:
  • Notify patients that these third-party popular applications potentially introduce privacy risks, and providers should enable all available encryption and privacy modes when using such applications
• Ensure that documentation of the following issues is made in the member record:
  • Potential difference in obtained scores due to telehealth administration
  • Any accommodations or modifications that were made to standard administration procedures
  • Potential limitations of all assessment results or conclusions when test norms used for interpretation are not based on a telehealth administration

Optum is continually monitoring this situation and if any further modifications to our normal processes are necessary to accommodate individuals impacted by COVID-19 we will communicate immediate updates on Provider Express here.