COVID-19 Medi-Cal managed care guidance

The California Department of Health Care Services (DHCS) has issued information to Medi-Cal managed care plans (MCP) about changes because of COVID-19.  Several fee-for-service policies already issued apply to Medi-Cal including providing care in alternative settings, pharmacy, transporation and telehealth.  MCPs must waive prior authorization requirements, including screening and testing, for services related to COVID-19.  MCPs are strongly encouraged to implement expedited authorization procedures during the COVID-19 public health crisis.

For Health Homes, DHCS encourages MCPs and their contracted Community-Based Care Management Entities to use telephone and video conference assessments.  In-person requirements are suspended until the COVID-19 emergency declaration is rescinded.

The requirement for an Initial Health Assessment for newly enrolled members within 120 days is temporarily suspended.  MCPs can deter Initial Health Assessments until the COVID-19 emergency declaration is rescinded.  However, Initial Health Assessments must be done for these members when the public health emergency is over.  (APL 20-004, April 27, 2020.)

COVID-19 CCS guidance

The California Department of Health Care Services (DHCS) has issued guidance regarding California Childrens Services and Special Care Centers during the COVID-19 public health emergency.  Policies issued by DHCS regarding Medi-Cal services apply to CCS when Medi-Cal beneficiaries are seeking services from CCS paneled providers.

All DHCS telehealth policies for Medi-Cal services apply to CCS.  Medically necessary CCS services can be delivered in-person or by telehealth.  CCS providers and SCCs should implement telehealth to provide remote consultation during the public health emergency.  DHCS and managed care plans must reimburse CCS providers at the same rate whether services are provided in person or by telehealth if the service is the same regardless of how it is delivered.

The requirement for an in-person Annual Team Conference for SCCs is suspended for the duration of the public health emergency.  DHCS has waived the requirement for an Annual Team Conference as a precondition for authorization of other new or re-authorized services for CCS clients.

CCS hearings may be conducted by phone or video conference.

DHCS is temporarily suspending prior authorization requirements.  Treatment Authorization Requests (TAR) and Service Authorization Requests (SAR) are still required but may be submitted after the date of service.

Telehealth may be used for visits related to a durable medical equipment order, including repairs and supplies.  TAR/SAR can be submitted retrospectively.

DHCS is providing flexibility for High Risk Infant Follow-up (HRIF) services for clinic to use individual approaches for follow-up services.  The age-out limit for HRIF is extended so that the third and final standard visit may be performed up to age 42 months.  (DHCS notice, April 28, 2020.)

COVID-19 Medi-Cal subacute care programs

The California Department of Health Care Services (DHCS) has issued guidance Medi-Cal subacute care programs because of COVID-19.  DHCS will not waive Medi-Cal subacute staffing minimums.  DHCS has placed a hold on the lifting of Bans of Admission, bed increases, and new applications until further notice.

Ongoing training requirements are suspended.

Providers can cover CNA staffing hour shortages with excess licensed staffing hours as long as the hour shortages and excesses occur on the same day.

At pediatric subacute care units only, programs can reduce the number of Service Coordinator/Social Worker staffing hours.  (PPL 20-01, April 10, 2020.)

COVID-19 provision of care in alternative settings and hospital capacity

The California Department of Health Care Services (DHCS) has issued guidance regarding several waivers in effect because of COVID-19.  Inpatient facilities can be fully reimbursed for services provided in an unlicensed facility (during an emergency evacuation or because of other need to relocate residents) provided that the California Department of Public Health makes a reasonable assessment that the facility meets minimum standards.

The three day prior hospitalization for coverage of a skilled nursing facility stay is waived for people who need to be transferred because of a disaster or emergency.

The limit of 25 beds and 96 hour stays for Critical Access Hospitals is waived.

Acute care hospitals can house acute care inpatients in excluded distinct part units if the distinct part unit’s bends are appropriate for acute care inpatients.

Acute care hospitals can relocate inpatients from an excluded distinct part psychiatric unit to an acute care bed and unit.

Acute care hospitals can relocate inpatients from an excluded distinct part inpatient rehabilitation unit to an acute care bed and unit.

Ambulance transportation may include any destination that is able to provide treatment in a manner consistent with state and local Emergency Medical Systems protocols.  (DHCS notice, April 22, 2020.)

COVID-19 off-label and/or investigational drugs

The California Department of Health Care Services (DHCS) will cover and reimburse for Fee-for-Service Medi-Cal beneficiaries off-label and/or investigational drugs for use in COVID-19.  A Treatment Authorization Request (TAR) or Service Authorization Request (SAR) is not required.

FDA-approved drugs being used off label to treat COVID-19 must either be used as part of a registered clinical trial, or the treating physician must put appropriate documentation in the medical record.  Non-FDA-approved drugs must be used as part of a registered clinical trial or be used in accordance with the FDA’s Expanded Access pathway (sometimes called compassionate use).

Because of its need for other uses, DHCS is limiting Hydoxychloroquinine to 120 tablets per prescription and Chloroquinine to 60 tablets per prescription.  If a beneficiary needs a larger quantity, a TAR or SAR establishing medical necessity will be required.  (DHCS notice, April 3, 2020.)