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COVID-19 IOP/PHP Telehealth Policy Updates 

Last updated: September 28, 2020

Optum is taking action to ensure health plan members affected by COVID-19 (coronavirus) have the support and resources they need. 

To support this, 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 Optum Behavioral Health plan members in Intensive Outpatient Program (IOP) and Partial Hospitalization Program (PHP) settings consistent with LOCUS and ASAM 2.1/2.5 clinical need criteria. Please note there are other potentially applicable federal and state privacy laws that could impact this temporary accommodation.  For example, please review this COVID-19 Public Health Emergency Response and 42 CFR Part 2 Guidance.

During the COVID-19 nationwide public health emergency, IOP/PHP 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. Optum has waived the Centers for Medicare and Medicaid’s (CMS) originating site restriction and extended the expansion of telehealth access for UnitedHealthcare Medicare Advantage, Medicaid and commercial members in accordance with the timeframes shown below:

Commercial Membership:  This policy change is effective through December 31, 2020 for in-network providers.  For out-of-network providers, this policy change was applicable through July 24, 2020.

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

For in-network providers through December 31, 2020

For out-of-network providers, through the national public health emergency period, currently in effect through October 22, 2020

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

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

In addition, providers should continue to:

  • Maintain substantially similar program structure and duration of services delivered in a virtual setting as offered through in-person services
  • Assess member safety for the virtual delivery of care in this setting which can occur at home or other setting
  • Obtain pre-authorization for in-network and out of network telephonic or telehealth based services
  • Advise members that this policy applies temporarily to all benefit plans to cover telehealth services and that the member’s benefit plan terms regarding standard member cost sharing and benefit plan terms apply
  • Use standard revenue codes and modifier (GT or 95) (or state Medicaid telehealth billing requirements if different) for both video-enabled virtual visits and telephonic sessions to indicate the visit was conducted remotely
  • Use HIPAA approved telehealth technologies as well as temporarily approved popular applications that allow for video chats to provide telehealth to provide telehealth in accordance with 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

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.

We’re listening.

We are monitoring the inquires we’re receiving on an ongoing basis and working hard to answer your questions. We will be making frequent updates to this page. Please be sure to check back often for the latest information. 


The benefits described within this website describe federal requirements and Optum and UnitedHealthcare national policy. Additional benefits may be available in some states and under some plans.