A variety of waivers are currently in place due to the COVID-19 pandemic. The following is not a comprehensive list of all waivers to federal, state, and grant program requirements. We will continue to update this page as more information becomes available. Contact your contract manager with questions.
Adult mental health targeted case management
Verbal acknowledgement of service plans
The Minnesota Department of Human Services (DHS) under the Governor's Emergency Executive Order 20-12 has temporarily waived the policy requirement for a signed service plan when it is not possible to obtain a signature from the client or the client’s parent or legal representative.
Effective Mar. 1, 2020, Child Welfare Targeted Case Management (CW-TCM) and Mental Health Targeted Case Management (MH-TCM) case managers may complete a service plan with the child and parent, legal guardian or legal representative; or the adult and legal representative via telephone or through videoconference.
The MH-TCM service plan effective date is the date the parent or legal guardian or legal representative, adult or legal representative acknowledges the MH-TCM service plan. In addition, the MH-TCM clinical supervisor must acknowledge the MH-TCM service plan and document in the recipients file the clinical supervisor’s review (on agencies time table as in current practice). This clarification applies to fee for service and managed care.
Case manager responsibilities
The case manager must:
- Document who gave verbal acknowledgement and their relationship to the client in the client file
- Document when the verbal acknowledgement was received
- Send a copy of the completed CW-TCM service plan to the child and parent, legal guardian or legal representative
- Send a copy of the completed MH-TCM service plan to the child and parent, legal guardian or legal representative; or the adult or legal representative
- Obtain signatures within a reasonable time after the Governor's Emergency Executive Order 20-12 has been lifted.
Guidance for Hennepin County forms
Hennepin County has been required to obtain an Information Disclosure Form and a Case Opening Form from contracted providers for all case openings and transfer requests with a “wet signature” or digital signature from the person being served.
In response to the COVID-19 pandemic Hennepin County will accept verbally-acquired authorizations on our Hennepin County forms. The provider should document that the client authorized verbally. This could be done by entering the clients name in the signature box and adding a note that says something to the effect, "Client signature was received verbally over the phone due to public health emergency protocols."
Video-conferencing meets face-to-face requirement
Effective Mar. 1, 2020, telephone and video-conferencing (for example FaceTime, Skype and other applications) contacts will meet the face-to-face requirement for all MA-eligible individuals receiving TCM services. MA claiming and reimbursement is permitted for covered TCM services provided through allowable modes.
The following criteria apply:
- Allowable tele-conferencing contacts for MA reimbursement are live audio exchanges by audio (telephone-only), or video, and web-based devices (for example FaceTime, Skype and other applications).
- Unallowable methods of contact remain: emails, texts, faxes and voicemail.
Intersection with existing telemedicine targeted case management services
For the period of the COVID-19 emergency, claiming for targeted case management delivered via telemedicine under existing state law is temporarily suspended. Bill for all forms of targeted case management (including AMH-TCM and VA-TCM which under current law can be delivered following the telemedicine guidelines) using the face-to-face procedure code for the specific targeted case management service at the required frequency.
DHS directs provider entities to use the face-to-face procedure codes to ensure that all claims are paid promptly. Place of service codes could trigger a requirement for manual claims processing.
All contacts made by phone call, or any other means of real-time audio-only (e.g. telephone) or audio and visual communication (e.g. FaceTime, Skype, etc.) satisfies the requirement for a face-to-face contact for the period of the COVID-19 emergency.
Related resources
Assertive Community Treatment
The commissioner temporarily expanded access to telemedicine for Minnesotans enrolled in Medical Assistance and MinnesotaCare who receive health care, mental health treatment, or substance use disorder treatment.
Specifically, the commissioner expanded the providers who are permitted to provide services through telephone and video visits to include the following providers and their tribal provider equivalents:
- Providers who are considered "licensed health care providers" under Section 256B.0625, subdivision 3b, paragraph (e) , and providers who licensed medical providers supervise;
- Mental health certified peer specialists and mental health certified family peer specialists where they are currently authorized to provide services;
- Mental health rehabilitation workers in Adult Rehabilitative Mental Health Services (ARMHS);
- Mental health behavioral aides in Children's Therapeutic Support services (CTSS); and
- Alcohol and drug counselors, alcohol and drug counselor-temps, recovery peers, and student interns in licensed SUD programs.
The commissioner also temporarily expanded telemedicine (including telephone and video visits) to Rule 25 assessments, comprehensive assessments, and group therapy.
These measures help enrollees and providers follow social distancing best practices. DHS has received federal approval for these changes.
This change is effective March 19, 2020, and runs through the end of the public health emergency.
Providers without a telemedicine assurance statement on file with MHCP must submit the Telephonic Telemedicine Provider Assurance Statement (DHS-6806A) (PDF) for coverage of services via telephone or tele-video. Your "Requested Service Effective Date" to the form can be on or after March 19, 2020.
To see covered services changes, refer to the Minnesota Health Care Programs Provider Manual.
Related resources
Children's mental health – outpatient
Providers may use telemedicine to deliver services, which is allowed under existing Medical Assistance requirements. Providers will not be required to originate telemedicine communications from a professional or clinical setting and will be reimbursed for telemedicine interactions that originate from a provider’s home setting. Providers must create and implement policies and procedures to ensure confidentiality and HIPAA compliance while using telemedicine.
We are working to develop the necessary accounting structure to allow providers to bill for services delivered via telemedicine, and we will update this page and contact providers with billing information soon.
Related resources
Children's mental health – targeted case management
Verbal acknowledgement of service plans
The Minnesota Department of Human Services (DHS) under the Governor's Emergency Executive Order 20-12 has temporarily waived the policy requirement for a signed service plan when it is not possible to obtain a signature from the client or the client’s parent or legal representative.
Effective Mar. 1, 2020, Child Welfare Targeted Case Management (CW-TCM) and Mental Health Targeted Case Management (MH-TCM) case managers may complete a service plan with the child and parent, legal guardian or legal representative; or the adult and legal representative via telephone or through videoconference.
The CW-TCM service plan effective date is the date the parent or legal guardian or legal representative acknowledges the CW-TCM service plan.
Case manager responsibilities
The case manager must:
- Document who gave verbal acknowledgement and their relationship to the client in the client file
- Document when the verbal acknowledgement was received
- Send a copy of the completed CW-TCM service plan to the child and parent, legal guardian or legal representative
- Send a copy of the completed MH-TCM service plan to the child and parent, legal guardian or legal representative; or the adult or legal representative
- Obtain signatures within a reasonable time after the Governor's Emergency Executive Order 20-12 has been lifted.
Video-conferencing meets face-to-face requirement
Effective Mar. 1, 2020, telephone and video-conferencing (for example FaceTime, Skype and other applications) contacts will meet the face-to-face requirement for all MA-eligible individuals receiving TCM services. MA claiming and reimbursement is permitted for covered TCM services provided through allowable modes. The following criteria apply:
- Allowable tele-conferencing contacts for MA reimbursement are live audio exchanges by audio (telephone-only), or video, and web-based devices (for example FaceTime, Skype and other applications).
- Unallowable methods of contact remain: emails, texts, faxes and voicemail.
Intersection with existing telemedicine targeted case management services
For the period of the COVID-19 emergency, claiming for targeted case management delivered via telemedicine under existing state law is temporarily suspended. Bill for all forms of targeted case management (including AMH-TCM and VA-TCM which under current law can be delivered following the telemedicine guidelines) using the face-to-face procedure code for the specific targeted case management service at the required frequency.
DHS directs provider entities to use the face-to-face procedure codes to ensure that all claims are paid promptly. Place of service codes could trigger a requirement for manual claims processing.
All contacts made by phone call, or any other means of real-time audio-only (e.g. telephone) or audio and visual communication (e.g. FaceTime, Skype, etc.) satisfies the requirement for a face-to-face contact for the period of the COVID-19 emergency.
Hennepin County will follow this directive for clients who are not MA eligible but receive these services through County funding, so long as providers serve the target population identified in their current contract.
Related resources
Children's school-based mental health
Providers may use telehealth to deliver services, which is allowed under existing Medical Assistance requirements. Providers will not be required to originate telehealth communications from a professional or clinical setting, and will be reimbursed for telehealth interactions that originate from a provider’s home setting. Providers must create and implement policies and procedures to ensure confidentiality and HIPAA compliance while using telehealth.
Related resources
Children's therapeutic supports and services (CTSS) – day treatment
Providers may use telemedicine to deliver the following services: individual and/or family psychotherapy, individual and/or family skills, psychotherapy for crisis, and Diagnostic Assessment. Eligible person attendance for ancillary services has been waived.
No waivers have been approved to deliver psychotherapy or skills for groups settings via telemedicine. We will provide updates as soon as we receive additional guidance from DHS.
Providers should use their best judgment to determine if a face-to-face interaction is urgent for health or safety. Guidance for face-to-face interactions in times of crisis for Hennepin County staff has been shared as a resource for providers here (PDF).
Continue to use current payment structure and payment process when submitting CTSS day treatment claims. When making CTSS day treatment claims for services provided via telemedicine in lieu of face-to-face services, use the face-to-face procedure code and modifier.
Children’s therapeutic supports and services (CTSS) – Structured family therapy (SFT)
Providers are permitted to conduct telemedicine service delivery in lieu of face-to-face services. Providers must create and implement policies and procedures to ensure confidentiality and HIPAA compliance. Provider must continue to operate within the terms of the contract by serving the target population outlined in the contract. Provider is permitted to utilize video and audio to deliver training services.
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Emergency shelters, drop-in centers, outreach services, and housing
Information for housing for partners and providers can be found on the Continuum of Care partnership to end homelessness page.
Family home visiting
The Minnesota Department of Health (MDH) recommends that when possible, home visitors use telephone or telehealth visits in place of in-person visits. MDH is not mandating this, but strongly encourages this as we await further guidance from the Governor, CDC, and our federal funders, and we will send out further information to providers soon.
It is important that home visitors maintain safe connections to their families, help support families in their parenting, assist with access to resources, answer questions, and provide a sense of calm during the COVID-19 global outbreak. Home visitors can regularly check-in with their families by phone, text, e-mails or video conferencing to provide support.
MDH Family Home Visiting will hosting weekly webinars Thursdays at noon to provide brief updates and allow for Q&A time, and will email summaries of webinars to providers. Sign-up to receive MDH bulletins here.
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Functional family therapy (FFT) and Multisystemic therapy (MST)
Hennepin County is in alignment with the Multisystemic Therapy and Functional Family Therapy contractor recommendations for services during the COVID-19 public health emergency. Telehealth/telemedicine (tele-) services are allowable for in-person and in-home sessions. Providers must create and implement policies and procedures to ensure confidentiality and HIPAA compliance.
Consultation and supervision can be conducted by video conferencing. Training will be completed via webinar. Hennepin County will continue to pay according to the terms of the current contracts.
Related resources
Foster care, supervised visitation, and transportation
Supervised visitation or transportation not suspended by Hennepin County
Supervised visitation and transportation should continue as usual. It is vital for children in foster care to stay connected to their parents, and supervised visits between children and their parents are important.
To reduce the risk of exposure to COVID-19, staff, parents, and children should take precautions to stay home if sick, wash hands thoroughly with soap and water, and cover coughs and sneezes. If guidance changes, Hennepin County will notify providers and update this page.
No changes to process for cancelling services
If a provider needs to cancel a service for any reason, follow the process for doing so as usual.
Changes to operations
Please communicate your COOP, changes to services or capacity or other concerns to your contract manager or to your Hennepin County contact person.
Home and community-based waiver case management and Rule 185 case management
Case managers can conduct required face-to-face semi-annual visits with people over the phone and/or secure video conference. Providers will identify which resources they will use to conduct phone and/or secure video conference visits. Providers must create and implement policies and procedures to ensure confidentiality and HIPAA compliance. For visits conducted over the phone or secure video conference, case managers should begin case notes begin with: “Due to COVID-19 this phone visit has been completed in lieu of a face to face visit to ensure safety….”
Providers should determine their own practice to obtain signatures either over secure email or by US Mail. If there is a barrier to obtain a signature, note in case notes that it is related to COVID-19. Document in case notes that the person granted verbal agreement via phone or other means (specify the means).
Related resources
Electronic signatures
Hennepin County has shared the following resources regarding electronic signatures with Hennepin County case managers, and is making this information available here as a resource for contracted case management organizations. Contracted case management organizations are required to consult with their HIPAA Privacy Officer, IT department, and attorney to develop their own guidance. We have not yet received guidance from DHS on this matter.
Minnesota Family Investment Program (MFIP) and Diversionary Work Program
In-person interviews not required to determine eligibility
In-person interviews are not necessary to determine eligibility, to conduct an eligibility review, or to deliver employment services (including orientation and overviews).
Making MFIP and Diversionary Work Program services more accessible
Providers are encouraged to be flexible in making services accessible to participants. Providers should not turn away participants who do not have access to technology to get the services they need.
For documents and signatures:
- Consider sending self-addressed envelope for participant to return for intake and EP forms.
- Use of electronic signatures on applications and documents is acceptable, programs such as DocuSign can be utilized.
- Copies of documents are allowable during this time, should originals or electronic signature not be available.
For support services:
- We are working with Metro Transit to understand their requirements on signatures for bus cards.
- Please continue tracking support service spending per contract requirements until further notice.
Sanctions
Minnesota Human Services Commissioner Jodi Harpstead has temporarily ordered that participants in the Minnesota Family Investment. Program and Diversionary Work Program will not be sanctioned or disqualified for failing to attend meetings, submit paperwork or comply with other specific requirements. This will be in effect for the duration of the public health emergency.
Related resources
Prevention (funded by FHPAP)
Providers are advised to minimize face-to-face contact as much as possible for activities funded by Minnesota Housing’s Family Homeless Prevention and Assistance Program (FHPAP).
Written signatures
Unless and until Minnesota Housing issues additional guidance, providers may temporarily secure verbal consent from each adult in the household for the following documents:
- Release of Information
- Tennessen Warning
- Other enrollment documents such as applications
In all cases where written signature is not possible due to social distancing, providers should 1) note on the release that it was a verbal release 2) put a memo to file that notes COVID 19 safety precautions as the reason for verbal release.
If at all possible, providers should secure electronic confirmation that the verbal signature was given, such as a text message or e-mail from the client acknowledging the verbal signature.
Income verification
Providers may temporarily incorporate self-reporting of income unless and until Minnesota Housing provides additional guidance. Formal documentation and third-party verification continue to be the best methods for verifying household income; however, during this crisis, Minnesota Housing is allowing households to self-report income when necessary.
Self-reporting of income should only be used in extreme situations when other more appropriate methods are unavailable. When self-reporting is used, staff should inquire about a wide variety of potential income sources and document the household’s response in the client file. Include notes that explain the reason for the self-certification and demonstrate the provider has exercised due diligence in attempting to obtain a higher level of documentation. Staff must still calculate annual income and make sure that households meet the income requirements for FHPAP.
Services for people on a lease
On March 23, 2020, Governor Walz announced Executive Order 20-14 Suspending Evictions and Writs of Recovery During the COVID-19 Peacetime Emergency.
Standard Prevention program eligibility requirements include that people on a lease must document that they have a housing crisis and face a housing loss within 30 days. Grantees have often obtained a copy of an eviction notice as documentation of a household’s housing crisis for FHPAP eligibility.
During this Executive Order, Minnesota Housing directed grantees to instead try to secure a late rent notice as documentation of housing crisis. If this isn’t possible and will delay the crisis resolution, grantees may secure verbal verification of late rent from the landlord. Securing verbal verification should be a last resort, and the landlord name and contact information should be noted in the file.
In addition, for people on a lease and seeking Prevention assistance, the requirement to document eligibility based on housing loss within 30 days is waived for the duration of the eviction moratorium. Minnesota Housing guidance is that if, under normal circumstances, the tenant would likely be evicted, then they would meet the spirit of what is intended by the 30-day risk of housing loss requirement.
Minnesota Housing has indicated that case managers should use their best judgement and their understanding of the larger circumstances to determine if individuals on a lease would otherwise meet the 30-day housing loss requirement and should document to the case file accordingly.
This waiver remains in effect until the end of the executive order or eviction moratoriums, at which time providers should resume obtaining eviction notices and assessing housing loss within 30 days.
Providers should complete the M-PAT tool as usual, with the notice of late rent serving to document eligibility under Step 1 of the assessment in lieu of a notice to vacate. In order to accurately assess need and eligibility under the eviction moratorium, case managers may override a person’s score in Section 1 of the M-PAT tool. They may do so if 1) due to the moratorium, a person on a lease is not getting points for risk of housing loss or when housing loss will occur, and 2) the case manager’s assessment is that the individual would otherwise be evicted but for the moratorium, and should be receiving those points.
Note that the individual’s calculated M-PAT score should not be changed; instead the case manager should do an override as follows: 1) record the final score based on information from the client as usual 2) note on the M-PAT form that an override was done and why, including both the rationale for the new score AND that it was related to the moratorium 3) include the revised score in addition to the original score on the final page of the scoring tool, and 4) serve the client based on that revised scoring.
Requirements that providers first document that individuals have exhausted other resources remain in effect.
Note that people in doubled up housing situations and facing housing loss are not affected by this waiver. Providers should document their risk of housing loss as normal.
Related resources
Rapid rehousing (funded by FHPAP, ESG, and CoC)
For Family Homeless Prevention and Assistance Program (FHPAP) funded activities
Providers are advised to minimize face-to-face contact as much as possible for activities funded by Minnesota Housing Family Homeless Prevention and Assistance Program (FHPAP). This may include social distancing or alternative modes of connection such as phone calls, Skype, or video calling.
Written signatures
Unless and until Minnesota Housing issues additional guidance, providers may temporarily secure verbal consent from each adult in the household for the following documents:
- Release of Information
- Tennessen Warning
- Other enrollment documents such as applications
In all cases where written signature is not possible due to social distancing, providers should 1) note on the release that it was a verbal release 2) put a memo to file that notes COVID 19 safety precautions as the reason for verbal release.
If at all possible, providers should secure electronic confirmation that the verbal signature was given, such as a text message or e-mail from the client acknowledging the verbal signature.
Income verification
Providers may temporarily incorporate self-reporting of income unless and until Minnesota Housing provides additional guidance.Formal documentation and third-party verification continue to be the best methods for verifying household income; however, during this crisis, Minnesota Housing is allowing households to self-report income when necessary.
Self-reporting of income should only be used in extreme situations when other more appropriate methods are unavailable. When self-reporting is used, staff should inquire about a wide variety of potential income sources and document the household’s response in the client file. Include notes that explain the reason for the self-certification and demonstrate the provider has exercised due diligence in attempting to obtain a higher level of documentation.Staff must still calculate annual income and make sure that households meet the income requirements for FHPAP.
For Emergency Solutions Grant (ESG) and Continuum of Care (CoC) HUD funded activities
Written signatures
Staff with the local U.S. Department of Housing and Urban Development office have indicated that there is not federal guidance on the topic of written signatures for ROIs or enrollment documents. Local HUD staff are advising grantees to create a COVID-19 policy that would provide direction on deviations from the grantees’ usual practices, such as for ROIs and enrollment documents. Tennessen Warnings are a state requirement not part of HUD programming.
Income verification
For third party documentation, source documents (e.g. wage statements or public benefits statements) are preferred. To the extent that source documents are unobtainable, a written statement by the relevant third party or the written statement by intake staff of the oral verification by the relevant third party is preferred.
To the extent that source documents and third-party verification are unobtainable, a program participant's self-certification of income would be allowable. Self-certification must be accompanied by notes that explain the reason for the self-certification and that demonstrate the provider has exercised due diligence in attempting to obtain a higher level of documentation.
For Emergency Solutions Grant (ESG) funded activities
Temporary waiver of Fair Market Rent requirements
Waiving the limit on rental assistance to rents that are equal to or less than the Fair Market Rent, established by HUD, will assist ESG funded providers in more quickly locating additional units to house individuals and families experiencing homelessness.
For ESG funded projects, The FMR restriction is waived for any individual or family receiving Rapid Re-housing assistance and who executes a lease for a unit during the period of April 13th, 2020 through September 30th, 2020.
Providers must still ensure that units for which ESG assistance is provided meet the rent reasonableness standard.
Case management
Expectations on frequency of case management as outlined in the RRH provider manual remain in place because of multiple funding streams and related requirements. Per guidance on the HHS Partners webpage, alternate means of connecting with RRH clients are permissible and in order to maintain social distancing, such as texting, phone, and video.
Providers who still have issues assuring case management under this broader authority should contact Hennepin County staff to discuss options and additional flexibilities that could be pursued.
Habitability assessments
Habitability assessment requirements for ESG remain in effect under COVID 19 but can be done creatively. Providers should (in order of preference):
- Conduct a virtual assessment themselves using the providers’ standard Habitability Assessment form already in use:
- Virtual inspection can include a video, live stream, or photos. Please include date stamp to the extent possible and per HUD guidance to Hennepin County that this is preferred.
- Note to the case file that the inspection had to be postponed due to COVID 19 and that it was done virtually as a result.
- Complete a physical assessment within 3 months of the date that health officials determine special measures to prevent the spread of COVID-19 are no longer necessary.
- If a provider cannot do a virtual assessment themselves:
- Have the client, landlord or another individual do the assessment to the best of their ability based on provider guidance and using the providers’ standard Habitability Assessment form. Document it to the provider similar to #1 above using video and/or photos.
- Note to the case file that the inspection had to be postponed due to COVID 19 and that it was done virtually instead.
- Complete a physical assessment within 3 months of the date that health officials determine special measures to prevent the spread of COVID-19 are no longer necessary.
For Continuum of Care (CoC) funded activities
Temporary waiver of Fair Market Rent requirements
For CoC-funded projects, The FMR restriction is waived for any individual or family receiving Rapid Re-housing assistance and who executes a lease for a unit during the period of April 13th, 2020 through September 30, 2020.
Providers must still ensure that units for which CoC assistance is provided meet the rent reasonableness standard.
Temporary waiver of one-year lease requirement
Providers receiving CoC funds for Rapid Rehousing ordinarily must assure that program participants obtain a lease for a term of one year and which is renewable and terminable for cause. Waiving the one-year lease requirement as specified below will allow recipients to more quickly identify permanent housing for individuals and families experiencing homelessness, which is helpful in preventing the spread of COVID-19.
For CoC funded programs, the one-year lease requirement is waived for the period of April 13th, 2020 through September 30th, 2020 so long as the initial lease term of all leases is for more than one month.
Case Management
Frequency of case management as outlined in the RRH provider manual remains in effect because of braided funding requirements. Alternate means of connecting with RRH clients to assure staff and client safety are permissible, such as texting, phone, and video.
Recognizing that some clients may not have access to technology, providers who still have difficulty assuring required frequency of case management under this broader authority should contact Hennepin County staff to discuss additional flexibility that could be pursued.
Housing Quality Standards (HQS): Initial physical inspection of unit
Per HUD waiver, the requirement to physically inspect each unit to ensure HQS before providing assistance is waived for the period of April 13th, 2020 through September 30th, 2020 IF AND ONLY IF providers are able to meet the following criteria:
- The provider is able to visually inspect the unit using technology, such as video streaming, to ensure the unit meets HQS before any assistance is provided; and
- The provider has written policies to physically re-inspect the unit within 3 months after the date that health officials determine special measures to prevent the spread of COVID-19 are no longer necessary.
Per CoC rules, providers must inspect all units for which leasing or rental assistance funds are used at least annually to ensure they continue to meet HQS. This requirement to reinspect is waived for the period of April 13, 2020 to March 30, 2021.
Related resources
Ryan White Program
As of May 1, 2020, DHS and Hennepin County will continue to allow for verbal consent in lieu of client signature for documents for Ryan White services including, but not limited to, service consent forms, release of information, data practice, care plans, service plans, and applications.
DHS and Hennepin County will continue to monitor guidance and work collaboratively with subrecipients to determine when we can resume usual operations with client signatures. DHS and Hennepin County will give appropriate notice to providers when this procedural change will end. Our intent is to give four weeks of notice to subrecipients and clients before resuming usual operations with client signatures. This notice period may be adjusted based on federal and state guidance.
The below document provides guidance on continuity of care and programmatic changes, complying with Ryan White Program requirements, and additional resources.
Related resources
Supplemental Nutrition Assistance Program (SNAP)
The Minnesota Department of Human Services (DHS) waived work requirements for able-bodied adults without children who receive Supplemental Nutrition Assistance Program benefits.
Related resources
Wraparound
If providers have approved that wraparound sessions, groups, or meetings may be conducted via telehealth, telemedicine, phone, or video conferencing, Hennepin County supports these service delivery methods. All supervision, staff, team and staff training sessions may also be conducted using these same tools.
The Minnesota Department of Health (MDH) recommends that when possible, home visitors use telephone or telehealth visits in place of in-person visits. The Minnesota Department of Health (MDH) recommends that when possible, home visitors use telephone or telehealth visits in place of in-person visits. Providers will not be required to originate telehealth communications from a professional or clinical setting, and will be reimbursed for telehealth interactions that originate from a provider’s home setting. Providers must create and implement policies and procedures to ensure confidentiality and HIPAA compliance.
All services must continue to maintain fidelity to the Wraparound High Fidelity Model. All services can be billed as if for face-to-face contact, according to contract terms.
Related resources