MSOTA recognizes the professional and personal struggles facing occupational therapy practitioners and occupational therapy students in Mississippi in light of the COVID-19 pandemic.  Guidelines and mandates are ever-evolving due to the changing nature of the pandemic.  Of the utmost importance is to ensure your safety while following guidelines to reduce and prevent community spread.  MSOTA has been working to compile resources that may be beneficial for our members and that information is below.  However, due to the evolving nature, we recommend you revisit the respective resources frequently for any updates.

All resources below are current as of March 30, 2020:

Click here for official statement from the Mississippi State Department of Health

Mississippi Department of Health resources related to COVID-19 in MS:
https://msdh.ms.gov/msdhsite/_static/14,0,420.html 

The State Board of Health has issued us formal notification that they will not be delaying licensure renewal at this time, nor waiving the face to face requirement for CEUs.  We will continue to advocate for the need to be flexible during this unprecedented time. 

Mississippi's Governor Tate Reeves has issued multiple executive orders related to the state of emergency.  The following Executive Order from Governor Tate Reeves is related to the COVID-19 outbreak on nonessential gatherings and access to health facilities:
https://www.sos.ms.gov/Education-Publications/ExecutiveOrders/1463.pdf
 
Centers for Disease Control (CDC) Recommendations for healthcare professionals:
https://www.cdc.gov/coronavirus/2019-ncov/hcp/index.html  

The Department of Homeland Security issued a memorandum on March 18, 2020 listing occupational therapy practitioners as essential critical infrastructure workers.  That memo can be found here:
https://www.cisa.gov/sites/default/files/publications/CISA-Guidance-on-Essential-Critical-Infrastructure-Workers-1-20-508c.pdf 

AOTA is providing a resource page related to OT in the era of Coronavirus.  
https://www.aota.org/Practice/Health-Wellness/COVID19.aspx  

CMS has been issuing new regulations and guidelines for multiple entities.  There are many regulatory changes in effect at this time.  
https://www.cms.gov/files/document/covid19-emergency-declaration-health-care-providers-fact-sheet.pdf
A brief, but not comprehensive, listing is below:

Medicare has issued a waiver of the 3-day qualifying stay for skilled nursing stays for beneficiaries. Patients can be admitted without having had a qualifying stay if they are deemed to need skilled nursing care, or if they are dislocated from the hospital due to other patients requiring more acute care. In addition, for certain beneficiaries who recently exhausted their SNF benefits, it authorizes renewed SNF coverage without first having to start a new benefit period  
 CMS is waiving the requirements that Critical Access Hospitals limit the number of beds to 25, and that the length of stay be limited to 96 hours.   
Medicare has also issued a waiver for replacement of durable medical equipment that has been lost, destroyed, damaged, or otherwise rendered unusable during this timeframe. Where Durable Medical Equipment Prosthetics, Orthotics, and Supplies (DMEPOS) is lost, destroyed, irreparably damaged, or otherwise rendered unusable, contractors have the flexibility to waive replacements requirements such that the face-to-face requirement, a new physician’s order, and new medical necessity documentation are not required. Suppliers must still include a narrative description on the claim explaining the reason why the equipment must be replaced and are reminded to maintain documentation indicating that the DMEPOS was lost, destroyed, irreparably damaged or otherwise rendered unusable or unavailable as a result of the emergency.
CMS has lifted some other regulatory requirements for those in IRFs, LTACHs, and other settings.  Please see the  attached fact sheet for more information

Long Term Care Facilities:
For those working in long term care or assisted living or independent living facilities, the following guidelines related to the role of occupational therapy in these settings may be helpful:
https://www.ahcancal.org/facility_operations/disaster_planning/Documents/Therapy-Personnel-Guidance-COVID19.pdf  

Educational and Early Intervention Settings:
For those working in educational settings or early intervention, you may find many resources from AOTA: 
https://www.aota.org/Advocacy-Policy/State-Policy/StateNews/2020/Provision-School-Based-Coronavirus.aspx 

The Department of Education issued further guidance that can be found here:
https://www2.ed.gov/policy/speced/guid/idea/memosdcltrs/qa-covid-19-03-12-2020.pdf  

Telehealth
Telehealth continues to be a big topic of discussion as states and payers are issuing guidance related to telehealth.   As this is rapidly changing, a good place to review resources is
https://www.aota.org/Practice/Manage/telehealth/coronavirus.aspx  
For Medicare, resources on telehealth e-visits, which are different from our more regularly billed CPT codes can be found here:
https://www.aota.org/Practice/Manage/telehealth/Nonphysician-Evisits.aspx  

It was unclear when the fee schedule was released if CMS intended for occupational therapists to be allowed to use these codes. With today’s telehealth expansion during the COVID-19 outbreak, CMS clarified that occupational therapists can bill for these E-visits.

The G codes to use for Medicare are:
G2061                   Qualified nonphysician health care professional online assessment, for an established patient, for up to 7 days, cumulative time during the 7 days; 5–10 minutes
G2062                   11–20 minutes
G2063                   21 or more minutes
Although the requirements for using the codes are the same as under Medicare, the client’s insurance will dictate which codes are used. For private payers, the parallel CPT codes available are as follows:
98970                    Qualified nonphysician health care professional online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5–10 minutes
98971                    11–20 minutes
98972                    21 or more minutes

AOTA E-Visit Coding Guidance
In order to provide these e-visit services, the client must be established with the practice, and the client must initiate contact. Contact is usually made electronically through a patient portal, but it can also be made through a phone call or an email. Billable time starts when the practitioner reviews the inquiry, and includes any time over the next 7 day period assessing the problem, creating a management plan, ordering tests, and digitally communicating with the client.
However, according to American Medical Association coding guidance, if the client’s inquiry is related to a condition that was treated in-person in the office within the past 7 days, the online service is not billable. Also, if the client comes into the office within 7 days of the inquiry related to the same condition, the online service is not billable.


IMPORTANT:  To lobby members of Congress for reimbursement of OT performing telehealth, visit:
http://cqrcengage.com/aota/app/onestep-write-a-letter?0&engagementId=506864  

Temporary Lifting of HIPAA Technology Compliance Only During Public Health Emergency
It should be noted that as part of the March 17 announcement, CMS indicated that the Department of Health and Human Services, Office of Civil Rights (HHS OCR), the office responsible for enforcing the Health Insurance Portability and Accountability (HIPAA) Act, will exercise enforcement discretion during the COVID-19 public health emergency (PHE). This means that if providers use technology during the PHE that is not fully compliant with HIPAA, HHS OOCR will not impose penalties on providers. After the PHE is lifted, providers must conform by using HIPAA-compliant technology.

Mississippi Medicaid and Telehealth
Mississippi Medicaid has enacted an Emergency Telehealth Policy:
https://medicaid.ms.gov/wp-content/uploads/2020/03/Emergency-Telehealth-Policy-3.20.20_V2.pdf 
https://www.cchpca.org/sites/default/files/2020-03/Misssissippi%20Medicaidl%20-%20Emergency-Waiver-Public-Notice%202020.03.19%20.pdf  
Department Of Medicaid defines telehealth services as the delivery of health care by an enrolled Medicaid provider, through a real-time communication method, to a beneficiary who is located at a different site.
A beneficiary may seek treatment from a non-traditional originating site including the beneficiary’s home
A beneficiary may use his or her personal cellular device, computer, tablet, or other web camera-enabled device to seek and receive medical care in a synchronous format with a qualified distant-site provider.
When receiving telehealth services in the home, the requirement for a telepresenter to be present with the beneficiary is waived. 
 Any limitation on the use of audio-only telephonic consultations is waived.  CPT Codes 99441, 99442, and 99443 are temporarily available for reimbursement of telephone only consultations.
Virtual check-in, including by telephone (HCPCS code G2012) or captured video or image (HCPCS code G2010), are temporarily available.
Any provider who is eligible to bill DOM for services is allowed to serve as a distant site provider.
All providers acting in the role of a telehealth distant site provider will be reimbursed the Mississippi Medicaid fee-for-service rate for telehealth services.  Providers should bill the appropriate code for services rendered as if rendered in person.  Any service rendered via telehealth should include a GT modifier.  Please refer to the Medicaid interactive fee schedule located on the Medicaid website at https://www.msmedicaid.com/msenvision/feeScheduleInquiry.do to view rates for these services.  
Providers acting as both a telehealth distant and originating site provider will be reimbursed either the originating or distant site fee-for-service rate, not both.
**originating site is where the beneficiary is while receiving services; the distant site is the site of the provider
 
Enhanced telehealth services provided during this period must meet the following criteria:
 The service rendered must be safe and medically appropriate for the originating site in which the service is rendered.
Any health benefits provided through telemedicine must meet the same standard of care as if provided in person. 
Providers may only bill procedure codes which they are already eligible to bill. 
Providers must document the member’s consent, either verbal or written, to receive telehealth services.
The availability of services through telehealth does not alter the scope of practice of any health care provider, nor does it authorize the delivery of health care services in a setting or manner not otherwise authorized by law.
Services not otherwise covered by the Mississippi Division of Medicaid are not covered when delivered via telemedicine.
 
Mississippi Authority for Telehealth:
The State Statue that grants licensed health care practitioners the authority to provide health care through electronic means is:: Mississippi Code §41-127-1. Licensed health care practitioners authorized to provide health care services via electronic means; standards of practice Subject to the limitations of the license under which the individual is practicing, a health care practitioner licensed in this state may prescribe, dispense, or administer drugs or medical supplies, or otherwise provide treatment recommendations to a patient after having performed an appropriate examination of the patient either in person or by the use of instrumentation and diagnostic equipment through which images and medical records may be transmitted electronically. Treatment recommendations made via electronic means, including issuing a prescription via electronic means, shall be held to the same standards of appropriate practice as those in traditional provider-patient settings.
For practitioners who may be facing unemployment or reduced hours, please visit the Mississippi Department of Employment Security for information on eligibility: https://mdes.ms.gov/unemployment-claims/  and https://www.mdes.ms.gov/unemployment-claims/covid19/update-more-ways-to-file-your-covid-19-claims/

For our OT/OTA Student Members:
MSOTA values your current and future membership in our state association. Our hope is that this message can offer you some encouragement to know that we are thinking of you, too, during this COVID 19 crisis.  Our state association is actively working to find innovative ways to embrace this “new normal” in which our profession finds itself.  While OTs in clinical environments are working under extraordinary circumstances, OT and OTA academic faculty and students have also been tasked with transitioning to a different type of learning environment almost overnight.
 
As a board, we want to encourage you during this time of extreme change for us all, occupational therapy students (both OT and OTA) learn how important flexibility and resourcefulness is to our clients and profession We are masters of adaptation, and our profession will adapt. During this transition time, we encourage you to stay healthy both mentally and physically. This is a stressful time for everyone, and our profession is uniquely poised to help others during this transition. Yet, we must first remember to help ourselves so that we may help others in the future.
 
We hope, as a student, you find it helpful to know that your state association (MSOTA) and national association (AOTA) are continually advocating for you as student members. Additionally, NBCOT and ACOTE are also working tirelessly to find answers and solutions to many of the questions and concerns you have as current occupational therapy students amid this world-wide crisis.
 
Please remember to utilize your resources to remain informed. While there are some scary things happening around us, there are also unique opportunities for occupational therapy. We have been recognized by homeland security as an essential healthcare service, and we are able to tap into technology to allow continuity and access to care for many of our patients.  We encourage you to visit the following sites regularly to stay current about the various work being done on behalf of you and your future profession.

MSOTA                www.mississippiota.org
AOTA                    www.aota.org 
ACOTE                  www.acoteonline.org
NBCOT                  www.nbcot.org
 
This letter as well as many other evolving resources will be posted on MSOTA’s webpage for you to access at any time. We will continue to seek ways in which we can serve our student members in the upcoming weeks. Be sure to check our website and stay connected to us on social media. 

Finally
Those of you actively treating patients, be assured that your selfless and heroic actions are viewed as essential, needed, and amazing.  Please take care of each other, stay healthy, stay connected, and let us know how we at MSOTA can best support you.  

This content is provided for information purposes only. Though every effort is made to ensure the information is up to date and accurate, no legal liability or other responsibility is accepted by or on behalf of the Mississippi Occupational Therapy Association (MSOTA) for any errors, omissions, or statements, or any link to which these pages connect.  MSOTA accepts no responsibility for any loss, damage or inconvenience caused as a result of reliance on such information.  MSOTA cannot control the content or take responsibility for links maintained by external providers. Where we provide links to other sites, we do not endorse any information or opinions appearing in them. We accept no liability whatsoever over the availability of linked pages.  This content is not intended to provide legal or other professional advice.