Premera Blue Cross Blue Shield of Alaska Response to COVID-19

Yes. For commercial plans, to receive/administer COVID-19 vaccine, constituent products, and ancillary supplies, vaccination provider facilities/organizations must enroll in the federal COVID-19 Vaccination Program coordinated through their jurisdiction’s immunization program. Enrolled COVID-19 vaccination providers must be credentialed/licensed in the jurisdiction where vaccination takes place, and sign and agree to the conditions in the CDC COVID-19 Vaccination Program Provider Agreement. These conditions are detailed in the agreement itself.

Each state has developed a draft plan for COVID-19 Vaccine preparedness (Washington & Alaska) addressing a variety of topics. That includes phases of distribution and allocation, identification of critical populations and initial plan for prioritization of administration to different groups.

If you want to enroll in your state Medicaid program as well, reach out to your representative from the State Medicaid Agency Provider Enrollment Contact List.

Alaska has developed a draft plan for COVID-19 Vaccine preparedness addressing a variety of topics. That includes phases of distribution and allocation, identification of critical populations and initial plan for prioritization of administration to different groups.

The FDA Vaccine Advisory Committee voted to approve the Emergency Use Authorization (EUA) for the Moderna COVID-19 vaccine for those 18 and older. The CDC’s Advisory Committee on Immunization Practices (ACIP) recommended use of the Moderna vaccine. The Scientific Safety Review Workgroup, made up of members from Washington, Oregon, Nevada, Colorado and California, met and voted to recommend the vaccine for immediate use.

Earlier in December the Pfizer COVID-19 vaccine for those 16 and older was given an Emergency Use Authorization (EUA).

Two vaccines have made it through all the required trials and have received EUA from the FDA. Vaccines made by AstraZeneca and Johnson and Johnson are expected in the first quarter of 2021.

The CDC Director has approved additional phases of the COVID-19 vaccination program. Note that each state can vary who is included in each phase or accept the CDC recommendations. We expect Washington and Alaska to follow CDC guidelines; we’ll know more in early January. It’s expected that the next phase of vaccinations (phase 1b) will not start before the end of January.

Phase 1a: Healthcare personnel and residents/staff of long-term care facilities

1. Health care personnel. Health care personnel are defined as paid and unpaid persons serving in health care settings who have the potential for direct or indirect exposure to patients or infectious materials.
2. Residents and staff of long-term care facilities. Long-term care facility residents are defined as adults who reside in facilities that provide a variety of services, including medical and personal care, to persons who are unable to live independently.

Phase 1b: Frontline essential workers and Persons aged 75 years or older

Frontline essential workers include:

• First responders (e.g., firefighters, police)
• Education workers (teachers, support staff, daycare)
• Food and agriculture workers
• Correctional/prison facility staff
• U.S. postal service workers
• Public transit workers
• People who work in manufacturing
• People who work in grocery stores

Phase 1c: Persons age 65-74 years, persons aged 15-64 with high-risk conditions, essential workers not recommended in Phase 1b

Essential workers include people who work in the following areas:

• Transportation and logistics
• Food Service
• Shelter and housing (construction)
• Finance
• IT and communication
• Energy
• Media
• Legal
• Public safety (engineers)
• Water and wastewater

The National Academies of Sciences, Engineering, and Medicine (NASEM) and the Centers for Disease Control and Prevention’s (CDC) Advisory Committee on Immunization Practices (ACIP) will provide guidance on who gets the vaccine first when one is available via EUA or FDA approval.

Each state can determine if they’ll follow the CDC guidance on each phase. States have their own Department of Health websites that will be tracking information, providing updates on available vaccine doses, who is eligible to administer the vaccine, and who is included in each phase. Visit the CDC website for specific state information – scroll down to “What you can do right now” and select your state.

The state of Alaska has made the decision to begin providing vaccines to residents 65 years of age and older starting Monday, January 11, 2021. While the CDC recently updated their Phase 1b and 1c guidelines, each state has the authority to modify those guidelines; Alaska has chosen to modify and begin Phase 1b starting Monday. Alaskans age 65 and older can start making appointments through the state’s website at Covidvax.Alaska.gov on January 6, 2021.

NOTE: Not all providers will be administering the vaccine, so it’s important that people use the state’s appointment website to guarantee they’re receiving the correct vaccine.

The state asks that if you’re not in healthcare or 65 or older as defined by Phase 1A or Phase 1B, Tier 1, please cancel your appointment so Alaskans in the earlier tiers can make appointments. New appointments will be added regularly as more vaccine providers sign up and more vaccine is available. Get more information about the COVID-19 vaccine and Alaska’s distribution plans at Covidvax.Alaska.gov.

After the emergency use authorization (EUA) or licensure of each COVID-19 vaccine product by FDA, CMS will identify the specific vaccine code(s), by dose if necessary, and specific vaccine administration code(s) for each dose for Medicare payment. CMS and the American Medical Association (AMA) are working collaboratively on finalizing a new approach to report use of COVID-19 vaccines.

Codes are now available for the Pfizer, Moderna and Astra-Zenica. Use the links below to ensure the new codes are in your system to facilitate efficient claims processing.

It’s recommended that providers download the new release of PC-ACE. This release includes the coding structure, currently comprised of both a HCPCS Level I CPT code structure issued by the American Medical Association (AMA) and a HCPCS Level II code structure issued by CMS. This code structure was developed to facilitate efficient claims processing for any COVID-19 vaccines and monoclonal antibody infusions that receive FDA EUA or approval. CMS and the AMA are working collaboratively regarding which codes to submit for COVID-19 vaccines and administration.  Most of these codes are not currently effective and not all codes will be used.  Specific code descriptors will be issued in the future.  Effective dates for the codes for Medicare purposes will coincide with the date of the FDA EUA or approval.

If you’re having difficulty billing for the COVID vaccine, contact the Express Scripts help desk at 800-922-1557.

Washington received its first allotment of the Pfizer vaccine on December 14 and began administration of the vaccine to high-risk workers in health care settings, high-risk first responders, and patients and staff of long-term care facilities. It’s estimated around 500,000 people in Washington will be eligible for the vaccine in phase 1a.

The Moderna vaccine shipment is currently expected in the next week and vaccinations will begin shortly after distribution.

CVS Pharmacy, which is preparing to begin vaccinations in long-term care facilities, said that December 21 would be the earliest vaccine administration can start in the facilities.

The Pfizer COVID-19 vaccine is a two-dose vaccine given 21 days apart. The Moderna vaccine is also a two-dose vaccine given 30 days apart. The CDC will be issuing a guidance that addresses use in those with vaccine allergic reactions, are pregnant/breastfeeding, and have weak immune systems.

We anticipate that broad scale vaccination across our populations (those not in the first few phases) will likely not be until mid-2021.

Information about vaccines and distribution will continue to evolve.

For general questions about COVID-19 vaccines and vaccine trials, and for the CDC playbook:

• Centers for Medicare and Medicaid Services (CMS)
• Centers for Disease Control and Prevention (CDC)

Washington state has developed a draft plan for COVID-19 Vaccine preparedness addressing a variety of topics. That includes phases of distribution and allocation, identification of critical populations and initial plan for prioritization of administration to different groups.

The CDC conducts webinars on the vaccines and safety measures: February 14: What Every Clinician Should Know about COVID-19 Vaccine Safety Sign up for webinar.

The federal government has mandated that the cost of the vaccine will be $0 for everyone in the U.S. The cost for administering the vaccine will be covered by insurance, for those with coverage, or waived for those without coverage. Providers may bill an insurance company for administrative costs.

The cost of the actual vaccine is being covered by the government currently. The cost of administering the vaccine will be covered by insurers, like Premera. CMS has recently released expected costs for vaccine administration. We expect the vaccines will be billed by dose, similar to how other 2-dose vaccines are billed.

Currently only those in Phase 1a category are receiving doses of the vaccine. For Phase 1b and 1c, you may need a doctor’s note or identification to prove you’re eligible when the vaccine becomes available. We expect to know more about requirements in early January.

Not currently for those under 16. The vaccines were only tested on adults. The Pfizer vaccine is approved for those 16 and older; Moderna is approved for those 18 and older. We’ll need additional studies to determine if these vaccines will be effective for those under age 18.

You may not be fully protected from contracting the COVID-19 virus. There are many vaccines that require more than one dose to ensure adequate immune response (i.e. antibodies) and to protect you from contracting a virus.

For some vaccines (primarily inactivated vaccines), the first dose does not provide as much immunity as possible. So, more than one dose is needed to build more complete immunity. The vaccine that protects against the bacteria Hib, which causes meningitis, and the vaccine that protects against shingles, are good examples.

If you get your second shot too early or too late, you DO NOT need to repeat the dose.

If you accidentally get the wrong vaccine for your second shot, you DO NOT need to repeat the dose. For example, if you get the Pfizer vaccine and then for your second shot you accidentally get the Moderna vaccine, you do not need another dose of either the Pfizer OR Moderna vaccine.

There are no requirements currently that you must get the vaccine. It is, however, highly recommended.

We can’t provide you with employment law advice on this topic. You’ll want to check in with your own legal counsel to determine if there are any restrictions or considerations to that requirement. The vaccine will be covered under your health plan benefits.

Not quite yet. According to studies, we need more than 65% of the population to get the COVID-19 vaccine in order to begin to see protection among the general population. Once you receive both doses of a vaccine, you may be able to resume normal activities. In the meantime, continue to exercise caution, wash your hands frequently, and wear a mask.

We want our community to be healthy. And to be healthy, we need to have a strong provider network. This focus is consistent with Premera’s emphasis on the role of front-line providers in our healthcare system and supportive of our members’ most common needs throughout the months ahead.

We’re funding up to $100 million in advance payments for eligible providers in Washington and Alaska.

We haven’t set an end date for the Advance Payment Program. We’ll continue to disperse funds up to the $100 million available.

Yes. We’ll begin January 1, 2021 for providers that have received funds by August 1, 2020. For providers that receive funds after August 1, 2020, recoupment will begin at a later date dependent on receipt of funds. There’s no interest charged for this advance.

If you have unanswered questions, submit them to AdvanceProviderProgram@Premera.com. We’ll respond within 5 business days.

Legal requirements
Providers must not be in bankruptcy or have filed a petition for bankruptcy; and not knowingly be under an active medical review or an investigation by Premera.

Practice requirements
Contracted professional providers in Washington or Alaska that have billed Evaluation and Management (E&M) codes and behavioral health codes in excess of $4,000 for historical year of experience, resulting in at least a $1,000 advance (for Premera insured members).

Contracted dental providers in Washington or Alaska that have billed dental services in excess of $4,000 for a historical year of experience, resulting in at least a $1,000 advance (for Premera insured members).

We had to make a decision on eligibility that was simple to administer. We realize that does leave a lot of providers out of this process. We made a decision to limit to this group of providers.

Complete the screening questionnaire.

Payments typically are sent within 20 days of the signed contract being returned. That allows Premera to verify eligibility and for the provider to sign an advance payment agreement.

Eligible providers could be eligible for a 3-month advance based on an average of historical E&M, behavioral health codes and dental codes incurred between October 1, 2018 and September 30, 2019 and paid through December 31, 2019.

We’ll be reviewing claims billed between October 1, 2018 and September 30, 2019 and paid by December 31, 2019. Your payment advance will be based your billed charges for fully insured members.

Our repayment options are flexible and will include single lump sum payments, weekly voucher deductions, and invoicing. Emails will be going out shortly to providers that received funds. You must indicate the repayment option and return the document within 30 days. Recoupment for funding received by August 1, 2020 will begin on January 1, 2021.

Yes. Premera will require a signed advance payment agreement. If we don’t receive the agreement, the payment will not be sent.

Earlier this year, Premera made the decision to hold overpayment recoupments due to the pandemic and the effect it was having on our provider offices. Beginning in September, we'll start recouping those overpayments. If you were overpaid for a claim, you will receive a statement indicating the amount of overpayment. The notice will include instructions on how to repay any amount owed back to Premera.

Deferring of recoupment of claims overpayments ended on 9/2/2020.

The new Families First Coronavirus Response Act requires all group health plans, including self-funded plans, to provide coverage for diagnostic testing, including U.S. Food and Drug Administration (FDA)-approved COVID-19 diagnostic testing products and items and services related to testing furnished during an office, telehealth, urgent care center or emergency room visit. We have removed the group waivers that were previously in place to comply with this mandate.

Premera follows state and federal mandates related to end dates for these services. See the COVID-19 Key Dates section in this FAQ for current dates.

Commercial and Medicare Supplement members: We’re waiving in-network cost shares (coinsurance, copays, and deductibles) for members requiring FDA-authorized diagnostic COVID-19 and influenza testing. All other treatments and services including hospitalization not related to a COVID-19 diagnosis will be subject to the usual benefits and cost shares.

Pre-authorization isn’t required for medically necessary and FDA-authorized COVID-19 testing. If a member requires COVID-19 testing and treatment and there isn’t an in-network provider within a reasonable distance, the claims will be paid as in-network.

Cost shares for treatment related to COVID-19 diagnosis is waived through December 31, 2020.

Premera’s Benefit Coverage Guideline is effective for serology tests for dates of service July 1, 2020 and forward. Premera will reimburse for serology tests that are for the purpose of supporting a COVID-19 diagnosis as part of the treatment or management of a patient’s medical condition.

Serology tests provided on an inpatient basis are presumed to be for diagnostic purposes. Tests performed on an outpatient basis require records confirming that the test is for the diagnosis of the disease or condition of a patient.

The Benefit Coverage Guideline for individual plan patients and non-individual plan patients follows CDC guidance on scenarios in which serology testing can be used for diagnostic purposes:

• Serologic testing can be offered as a method to support diagnosis of acute COVID-19 illness for persons who present late. For persons who present 9-14 days after illness onset, serologic testing can be offered in addition to recommended direct detection methods such as polymerase chain reaction.
• Serologic testing should be offered as a method to help establish a diagnosis when patients present with late complications of COVID-19 illness, such as multisystem inflammatory syndrome in children.

Serological tests will not be covered when provided as the sole basis of diagnosis for current infection with COVID-19.

We will be covering claims with dates of service June 30, 2020 or earlier.

Premera will waive member cost shares including copays, deductible and coinsurance for treatment of COVID-19 or health complications associated with COVID-19, including hospitalizations and medical transportation when needed, FDA-approved medications administered inpatient for both in and out of network providers. All other treatments and services including hospitalization not related to a COVID-19 diagnosis will be subject to the usual benefits and cost shares.

For Medicare customers, claims received since February 4, 2020 related to COVID-19 will be reprocessed to waive all cost shares and deductibles.

See the COVID-19 Key Dates section in this FAQ for current dates.

This benefit applies to members of insured group, individual, grandfathered, and non-grandfathered plans, associations, and Premera’s Medicare enrollees. Self-funded group plans have the option to participate. This includes qualified high deductible plan participants. For Premera Medicare customers, regulators have not communicated an end date for this flexibility. Premera will adjust our policy as regulator guidance becomes available.

This will not apply to Shared Admin, FEP, and Self-funded plans that opt-out. Normal plan benefits apply in this situation for our members. You can check eligibility and benefits on our website.

FDA-authorized COVID-19 home test kits are only covered when ordered by a licensed physician or pharmacist. Home test kits will not be covered if used for non-diagnostic purposes (e.g. travel, return to work, etc.). Members may submit claims for reimbursement for in-home tests only when they are ordered by a physician or pharmacist. There may also be tax implications for using HSA funds to purchase in-home tests that are used for purposes other than diagnostic.

Yes. Drive-through diagnostic testing for COVID-19 is and cost shares will be waived as they are for in-clinic testing.

S.B. 241 is a comprehensive coronavirus-related bill that assumes firefighters, emergency medical technicians, paramedics, peace officers, or health care providers who contract COVID-19 during the public health emergency declared on March 11 is presumed to have contracted it during employment.

When a member of this group seeks care, they should notify you they believe they contracted COVID-19 in the course of their job. You then codes the claim and submit as a workers’ compensation claim. Premera pends the claim and asks the member to complete an incident questionnaire to obtain the worker’s compensation information.

Any member that is presumed COVID-19 with these job titles must file a claim with the appropriate workers' compensation carrier; this could be Office of Worker's Compensation or their Self-Funded Compensation Carrier. The claim will either be processed by workers’ compensation or by Premera, depending on the results of the incident questionnaire.

• Beginning April 20, 2020, health care facilities and providers defined in the Alaska governor’s statute may resume services that require minimal protective equipment and safety protocols for pre-screening. This includes services such as physicals, routine exams, and minimal procedures.
• Beginning May 4, 2020, with consideration of COVID-19 cases across the state, health care providers may perform non-urgent, or elective procedures, with defined safety protocols for patients and staff. This includes services such as biopsies and angiograms.

The Department of Insurance (DOI) recently changed the date for the suspension of prior authorization, concurrent and retrospective review suspension to June 1, 2020.

The following summary of coding instruction is provided by the CDC, the World Health Organization (WHO), and CMS related to COVID-19. We urge you to use this COVID-19 diagnosis and procedure coding for patients so cost shares may be waived appropriately.

There are two new HCPCS codes for lab tests to detect COVID-19: Code U0001 for the CDC test panel and code U0002 for other tests. In addition, two additional COVID test HCPCS codes U0003/U0004 for high throughput technologies are covered.

The American Medical Association added a new CPT code for reporting the novel coronavirus tests: 87635: Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique.

Per the CDC, a new ICD-10 emergency code, U07.1, 2019-nCoV acute respiratory disease, has been established by the WHO for reporting the virus, effective with the next update, October 1, 2020. Premera is accepting this code and encourages you to use it.

To identify patients in the interim who’ve tested positive for COVID-19, current CDC guidance instructs to code first for the presenting illness followed by B97.29 - Other coronavirus, as the cause of diseases classified elsewhere.

For the new serology tests, the AMA created new CPT lab test codes: 86328 and 86769. Use these codes when submitting a claim for the antibody test.

The AMA is offering additional guidance for COVID-19 coding scenarios to help healthcare professionals apply best coding practices. The scenarios include telehealth services for all patients.

COVID-19 testing examples include coding for when a patient:

• comes to the office for an E/M office visit and is tested for COVID-19
• receives a telehealth visit regarding COVID-19
• is directed to come to a physician’s office or physician’s group practice site for testing
• receives a virtual check-in/online visit regarding COVID-19 (not related to an E/M visit)
• is directed to come to a physician's office for testing

There is also a quick-reference flowchart that outlines current procedural terminology (CPT^®) reporting for COVID-19 testing. AMA also outlines CMS payment policies and regulatory flexibilities related to COVID-19. Check the AMA COVID-19 resource center for additional resources.

Premera will not include testing coverage (molecular/antigen or antibody tests) for return to work strategies for our insured book of business just as we don’t cover drug testing for employment purposes, as an example. The CDC said in its Interim Guidelines that antibody test results “should not be used to make decisions about returning persons to the workplace.” The EEOC has stated that because of this, “requiring antibody testing before allowing employees to re-enter the workplace is not allowed under the ADA”. Current versions of the antibody test can’t reliably tell a person that they’re immune, can’t be re-infected or can’t transmit the virus to someone else.

Return to work COVID test aren’t covered by the plan. The member may want to check with their employer on whether they will reimburse the member for this expense or bill directly to the employer.

Some lab companies are charging members a $10 non-refundable service fee for “physician oversight services” when a member orders testing directly through a lab. The $10 fee is for an independent physician who orders test for the member. The member also has the option to consult with this physician to discuss their results. This fee is not submitted to insurance for reimbursement by the lab service or the physician. This type of service fee and claim are not covered by the medical plan. To avoid this type of service fee, members should use their own provider or clinic when requesting COVID-19 testing.

As of November 1, 2020, Personal protective equipment (PPE) will no longer be separately reimbursable effective.

When PPE is worn as part of a dental, medical or pharmacist healthcare visit, it’s considered part of the practice expenses included in the main dental medical or pharmacy related procedure rendered to a patient. PPE will not be separately reimbursable.

Review additional details in the Personal Protective Equipment payment policy.

Telehealth cost share waivers ended on January 1, 2021. Depending on benefit plan design, the expanded telehealth network continues to be available to members.

In addition to our existing Premera contracted behavioral health providers (Talkspace, brick and mortar providers and Employer Assistance Programs), virtual access for behavioral health and substance use disorder treatment (opioid and alcohol) ) may include (depending on benefit plan design):

• Doctor On Demand – Doctor On Demand was added to our telehealth network. These services are available to member adults and children in all states.
• Boulder Care - Boulder Care is a digital care provider, offering long-term support and medication-based treatment for opioid use disorder (OUD) and common co-occurring conditions for members 18 years and older. Their digital platform allows patients to connect with providers 24/7 through secure video and messaging with clinicians, care advocates, and peer coaches. Boulder Care is working towards 50 states licensure. If they aren’t licensed in a certain state they will transition the member to an in-network provider for the appropriate services.
• Workit Health – Workit Health is a digital care provider offering support for alcohol use disorder (AUD). Via Workit web and phone apps, members age 18 and older have a “recovery in their pocket” harm reduction and sobriety solution that provides 24/7 access to interactive therapeutic courses, online support groups supervised by licensed care teams. Workit is working towards 50 states licensure. If they aren’t licensed in a certain state, they will transition the member to an in-network provider for the appropriate services.

Additional covered telehealth services include:

• Applied behavioral analysis (ABA)
• Partial hospitalization programs (PHP) for mental health and substance use disorders
• Intensive outpatient programs (IOP) for mental health and substance use disorders

Yes. Premera offers Talkspace for all our members. This is an online, virtual behavioral health provider resource. Many local mental health providers are also offering virtual services. Your patient should check with their provider first, or they can go directly to Talkspace.com/premera.

Yes. For Premera-contracted providers, your current contract covers telehealth services if the care provided is appropriate within the scope of the provider’s licensure. This change applies to Premera’s individual and commercial members. However, some self-funded employer groups don't cover virtual care, so be sure to check your patient's benefits before providing care.

Note: Telehealth services aren’t coded like in-office visits due to different modifiers and place of service codes needed to identify a telehealth service. There are additional codes that can be used for online video encounters as well as telephone visits in conjunction with the office visit codes.

Refer to your Premera contract for allowable information for virtual care codes. For specific coding information for Premera patients, see our telehealth payment policy for Alaska.

For Medicare Advantage patients: CMS has loosened guidelines around telehealth services during the COVID-19 Public Health Emergency. Starting March 6, Premera will cover telehealth visits for Medicare Advantage members billed by any healthcare facility in the same way as a regular, in person visits with the same cost shares. The previous requirement for services to be provided in certain types of originating sites and locations has been waived for the duration of the COVID-19 public health emergency.

For dental providers: You may bill the following visit types via tele-dentistry adding tele-dentistry modifier code of D9995/6:

• D0140 - Limited Oral Evaluation – Problem Focused
• D0170 - Re-evaluation, limited problem focused (established patient, not post-operative visit): This code is appropriate when assessing a previously existing condition related to trauma, or a follow-up evaluation for continuing issues
• D0190 – Screening of a patient. A screening, including state or federally mandated screenings, to determine an individual’s need to be seen by a dentist for a diagnosis.

Premera wants to emphasize that this is a temporary relaxation of the rules during this nationwide public health emergency. Correct coding and notification to the patient that the provider is using non-HIPAA compliant communication tools is required.

Refer to your Premera contract for allowable information for virtual care codes. For specific coding information for Premera patients, see our telehealth payment policy for Alaska.

Premera will be extending the payment of telehealth visits at the in-person allowed amount, during the national public health emergency, beyond September 1, 2020 as previously communicated. For providers who are delivering services via telehealth, Premera will require providers to continue use the correct telehealth place of service (POS) 02 with the procedure code appended with either modifier 95 or GT. Claims with modifiers indicating they were telehealth, if billed with POS 11, will be rejected up front and will require the correct POS to match the service billed. We will no longer accept POS 11 for telehealth services. 

Premera wants to emphasize that this is a temporary relaxation of the rules during this nationwide public health emergency. As additional information becomes available from CMS or other state regulators, we'll adjust our policies and notify you of the change. Only claims for telehealth visits from providers who members normally see in-person, in-office will be processed in this manner, and claim costs will be no more than what would have been paid had the member been able to see their providers in person.

This guidance is in effect for Alaska group plans, FEP, and Individual plans. Self-funded plans and Shared Admin are excluded from this guidance.

Refer to your Premera contract for allowable information for virtual care codes. For specific coding information for Premera patients, see our telehealth payment policy for Alaska.

Per Health & Human Services and the Office of Civil Rights, a covered physician or healthcare provider who wants to use audio or video communication technology to provide telehealth to patients during the COVID-19 nationwide public health emergency can use any non-public facing remote communication product that is available to communicate with patients. OCR is exercising its enforcement discretion to not impose penalties for noncompliance with the HIPAA rules in connection with the good faith provision of telehealth using such non-public facing audio or video communication products during the COVID-19 nationwide public health emergency. This exercise of discretion applies to telehealth provided for any reason, regardless of whether the telehealth service is related to the diagnosis and treatment of health conditions related to COVID-19. Additionally the criteria that telehealth may only be used with established patients is being relaxed and new patient encounters can be billed with these codes.

Providers can care for new patients via a telehealth virtual encounter and bill those services using the appropriate CPT that reflects the services rendered, in addition to the telehealth modifier and place of service. Virtual care for an established patient should also be billed with an appropriate CPT, many of which are found in Premera’s payment policy. Note that these services must also be billed using the appropriate telehealth modifier and place of service.

Yes, ABA services can be provided virtually for dates of service on or after 3/20/20. This is temporary and will be in effect until government agencies indicate that we no longer need to practice social distancing.

Claims for services provided virtually must be submitted with appropriate telehealth modifiers using the codes that are currently on the ABA fee schedule. See our telehealth payment policy for Alaska.

Reimbursement for virtual care will be at the same amount as if the service were provided in-person.

This change applies to Premera’s individual and commercial members. However, some self-funded employer groups do not cover virtual care, so you’ll need to check benefits for your patient before providing care.

With the increasing use of telemedicine to interact and treat patients, it can be difficult to capture information and do a physical exam. Fortunately, synchronous audio and video platforms make it possible for providers to capture almost all areas of a physical exam. We’ve developed a tip sheet using best practices and information from  Telemedicine: Conducting an Effective Physical Exam to help you conduct an effective physical exam during a telehealth visit.

Per the Alaska State DOI, there are waiver of requirements for:

• Pre-authorization for medical services
• Concurrent review for inpatient hospital services
• Pre-authorization post-acute placements

Retrospective review for inpatient and outpatient services and emergency services and payment of claims (Alaska State DOI mandate)

Yes. We’ve adjusted our refill too soon policy for medications. This allows pharmacies to override refill too soon edits during a declared emergency at the pharmacy counter. Members have access to Express Scripts mail order prescriptions. See the COVID-19 Key Dates section in this FAQ for current dates.

We frequently see drug shortages in the U.S. based on manufacturer issues, raw product issues, etc. We may see new reported shortages based on the COVID-19 impact to Chinese manufacturers. Premera will respond to these shortages the same way we do today, by ensuring the following:

• The pharmacy team will check public and industry resources to identify new shortages that may impact our members.
• We’ll review medical policies to determine if adjustments are needed to ensure access to alternative medications (should we change our preferred drugs or update prior authorization criteria to account for shortages both short and long term).
• Our review processes already account for drug shortages. If a drug we require as first-line therapy is in short supply, we’ll waive this requirement based on market realities and approve coverage when preferred formulary alternatives are in short supply.

We’re also reviewing rejected claims to see if members are getting the medications they need. If we see any drug shortages, we’ll seek other options to meet member needs. We’ll continue to monitor the situation with our pharmacy partners, so members won’t run out of needed medications.

Drugs that have received Emergency Use Authorization (EUA) or full FDA approval for the treatment of COVID will be covered under current policies and according to your health plan benefits.