State by state tele-neuropsychology resources and reimbursement
Each state has significant leeway to set rules and regulations governing health and behavioral healthcare. In the context of the COVID-19 pandemic some but not all governors have enacted sweeping orders regarding tele-health/ tele-mental health services. Insurance reimbursement for Tele-NP varies widely by state, and even within a single state based on private insurance company policy.
New! The IOPC and APA Services have collaborated to create a 50 state grid of private insurance reimbursement policies for teleNP during the pandemic.
These charts are the result of the largest collaboration to date between IOPC and APA Services, Inc. (APA Practice’s Legal & Regulatory Affairs including attorneys Alan Nessman, Connie Galietti, and Shirley Higuchi, and Office of Health Care Finance led by Dr. Stephen Gillaspy). The initial research on scores of state insurers was done by a team of neuropsychology grad students, with guidance by Dr. Jonothan Woodhouse, Dr. Jennifer Morgan, and Dr. Karen Postal:
Team leader: Palak G. Singh, MS Rosalind Franklin University of Medicine and Science
Amanda E. Messerlie, MS. Rosalind Franklin University of Medicine and Science
Morgan Tallmam, MA, Southern Illinois University
Janet j. Yanez, MA, CSPP, Los Angeles
Cari Cohen, MS, Roslind Franklin University of Medicine and Science
Travis Shivley-Scott, Ph.D., VA Palo Alto MIRECC fellowship and Stanford University School of Medicine
Jordan Smith, University of North Carolina at Wilmington
Megan Goyer
Rachel M. Kantor, University of North Carolina Wilmington
Christian Terry, M.A., UNC Wilmington clinical psychology
Elaine Schultz
How to read the charts
The national and regional payor chart has tabs for national companies like Aetna, Optum, Cigna and Anthem BCBS, and regional companies that are in multiple states. The state-based chart provides our initial group of companies that are exclusively/primarily in one state.
In each chart, reading from left to rights you’ll see: basic information on the company and web links; which of the common BH procedures/codes are covered by the company’s emergency telehealth (TH) policies; general information on billing, co-pays, out-of-network, etc.; then a list of which less common BH procedures/codes are covered by those policies.
Focus on commercial insurance
These charts focus on commercial insurance, but include some specific information on variations for other programs like Medicaid and Medicare Advantage. Within commercial insurance, a company’s TeleNP policies do not necessarily apply to the large portion of that is self-insured plans of large companies; with those plans the insurer administers but does not control the terms of the plan. Click here for more information and APA’s advocacy re those plans (see 6th FAQ): https://www.apaservices.org/practice/news/psychologists-questions-covid-19
We are evaluating whether to expand the charts to include Medicaid MCOs and Medicare Advantage plans, or whether those companies are primarily driven by directives from state Medicaid agencies and CMS respectively. See the state by state resources below for a description of medicaid teleNP policy.
The charts are a work in progress
Developing this chart was made challenging not only by the scope and complexity of so many companies TeleNP policies, but also by the fact that they are constantly changing. Some larger companies update them very frequently.
We are still finalizing our analysis of several single state companies (e.g., BCBS companies in AL, AR, LA and two in NY) that will be added to the state chart.
We will update the charts periodically, more frequently for major companies. Please send significant updates or corrections to PracLegal@apa.org.
End dates
Most companies are either constantly pushing back their end dates for their TeleNP policies as they approach, or going with when the federal or state government declares the emergency over. While most states are in early stages of re-opening, many of their public health emergency (PHE) orders are likely to stay in place as long as there is some level of COVID-19 restrictions, e.g., prohibitions on mass gatherings. (A few states’ PHE orders have already expire and some are set to expire this summer.) APA is advocating on multiple fronts for payors to keep their TH policies in place for at least 12 months after the federal emergency declaration ends. It is also advocating for payors to permanently adopt appropriate extensions of their TH policies when the crisis is over.
LINK HERE FOR NATIONAL AND REGIONAL INSURANCE COMPANY GRID including Aetna, Beacon, Humana, Magellan, Optum, and Cigna.
LINK HERE FOR STATE INSURANCE COMPANY GRID
Update 9/1/2021:
Commercial insurers’ policies for extended telehealth coverage
state by state Resources
Alabama
The Alabama Psychological Association has helpful COVID-19 resources on their homepage. Alabama is a state asking out of state psychologists to temporary practice in their state. Link here for details.
Arizona
The Arizona Psychological Association has state and national COVID-19 resources.
Governor: issued executive order that mandates that telehealth services be allowable and reimbursed at same rate as in-person. Link here for details.
Arizona Medicaid: All NP codes covered (90791, 96132, 96133, 96136, 96137). Link here.
Alaska
Governor signed HB29 into law requiring health care insurers to provide coverage for telehealth benefits (including mental health). Link here for details.
Medicaid: Coverage for all NP codes. Link here for details.
Arkansas
The Governor signed an order on 3/13/20 that suspends the provisions of the Telemedicine Act. Guidance by the Board of Psychology: For 120 days from 3/20/2020, licensees will not be required to submit a new Statement of Intent (SOI) to practice Telepsychology in Arkansas. The order includes audio only.
California
The California Psychological Association has an extensive state and federal resources for practice in the COVID-19 pandemic
An announcement dated 3/21/20, commercial and Medi-Cal managed care plans were directed to allow members to obtain health care via telehealth.
HCSC: No changes in Telehealth coverage from prior to pandemic. Link here.
Colorado
Governor Polis has put out an executive order for insurance to cover telehealth. Link here for the order. And link here for the emergency rules.
On March 13th, DORA provided guidance in an effort to alleviate the mental health burden in Colorado due to COVID-19. DORA is allowing those with out-of-state or expired licenses to provide clinical mental health services for a cumulative total of 20 days.
Colorado Psychological Association’s resources including Telehealth webinar
The Colorado Neuropsychological Society.
Colorado Medicaid: Colorado Medicaid Directive includes Neuropsych testing in telehealth.
Connecticut
Executive Order No. 7G dated 3/19/20 allows audio- only telephone for Medicaid.
CT is waiving current requirements for licensure, and allowing psychologists licensed in other states to practice in CT. Here is the order.
delaware
The Delaware Psychological Association homepage has state specific resources and webinars. The Governor temporarily lifted the following two restrictions on telemedicine in the state: 1. Patients do not need to have been seen previously to become telemedicine patients. 2. Patients do not need to be in Delaware at the time they are receiving telemedicine services. 3. Out of state providers may be able to provide telemedicine services to Delaware patients if they are licensed in another state. Link here for details.
Delaware Highmark is covering 96116, 96132, 96133, 96137. Link here for details.
Hawaii
Hawaii Psychological Association’s state specificities resource guide to COVID-19.
Idaho
The Idaho Psychological Association’s COVID-19 resources include relevant Idaho state laws and regional insurance coverage issues.
Governor: suspended telehealth regulations to allow greater access to telehealth. Link here.
Illinois
Illinois Psychological Association’s homepage has COVID-19 resources.
The Governor signed an order requiring coverage for telehealth services provided by in- network providers. Audio or video is allowed.
Indiana
The Governor signed an order allows mental health professionals to practice via telehealth.
Medicaid: telehealth restrictions have been removed during the pandemic.
Iowa
Iowa Psychological Association has general COVID-19 resources.
Kentucky
The Insurance Commissioner issued an order stating that insurers cannot require that the patient have a prior relationship with the provider in order to have services delivered through telehealth, if the provider determines that telehealth would be medically appropriate.
louisiana
The Louisiana Department of Health mandates that all tele-NP codes are covered until further notice. Link here.
Medicaid: Audio-only phone telehealth is now allowed when video is not available.
Maine
Guidance from the Maine Bureau of Insurance emphasizes existing state law mandates coverage of telehealth services.
Maine Psychological Association. Optum Has approved Neuropsychological testing codes for tele-health.
Maryland
Maryland Care First is covering 96116/96121 only at this time. Link here for details.
If Medicaid participants cannot access cellphone based video technology, audio only is covered.
Massachusetts
The Massachusetts Psychological Association has extensive state specific resources including local/regional insurance tele-psychology coverage rules for BCBS, Cigna, TUFTS, Optum, Beacon and regional Medicare. Many insurers are covering any medically necessary service via telehealth.
The Governor mandated that all commercial insurers including BCBS and HMOs to cover in-network telehealth services. Audio only allowed.
Medicaid: Link here to Massachusetts specific Medicaid information and FAQ.
Minnesota
The Minnesota Psychological Association has national resources for COVID-19.
missouri
Based on the Governor’s Executive Order and Missouri statutes, health carriers in Missouri are required to provide coverage for health care services provided by a health care provider via telehealth in the same manner as they would provide such coverage if the service was provided in person. This is effective until May 15, 2020 unless extended. Neuropsychology codes are not specifically referenced.
Nebraska
The Department of Insurance invoked an emergency exception to the state law requirement that a provider obtains a patient’s signed written statement agreeing to telehealth. Audio only is allowed when video telehealth is unavailable.
New Hampshire
The Governor signed an emergency order mandating Medicaid and private insurers allow reimbursement to in-network providers for telehealth. This includes audio only.
Optum: Neuropsychological testing codes approved for tele-health
New Jersey
New Jersey Neuropsychological Society. New Jersey is relaxing typical requirements for out of state psychologists, please link here for details.
The Insurance Commissioner requires insurers to encourage in- network providers to use telehealth whenever possible and clinically appropriate and to include telephone only in the definition of telehealth.
New Jersey Medicaid: Health care providers may bill for any Medicaid billable service using the same billing codes and rates that are provided for face-to-face services. There is no need to use any additional procedure codes or additional modifiers. Link here for details.
New Mexico
New Mexico Psychological Association.
The Department of Insurance guidance states insurers should encourage network providers to utilize telehealth. Phone or video are both acceptable.
New York
New York State Psychological Association has extensive federal and state resources, including a joint Statement on Coronavirus and Xenophobia.
NY office of Mental Health has clarified that phone only services are reimbursable under telehealth.
New York State Association of Neuropsychology. Their COVID-19 resource page has federal and state resources. NYSAN is working with their lobbyist to address coverage of neuropsychology codes for telehealth. In the meantime, these are the government communications NYSAN is referring to for guidance.
https://www.dfs.ny.gov/reports_and_publications/press_releases/pr20203171
https://www.dfs.ny.gov/industry_guidance/circular_letters/cl2020_06
https://health.ny.gov/health_care/medicaid/program/update/2020/2020-03_covid-19_reimbursement.htm
https://health.ny.gov/health_care/medicaid/program/update/2020/index.htm
North Carolina
The North Carolina Psychological Association has COVID-19 information on their website.
The Governor has temporarily waived licensure requirements for psychologists licensed in other states to practice in North Carolina. If a psychologist licensed in another state wants to telepsych into North Carolina, s/he must first contact the NC Psychology Board so that licensure in the other state can be confirmed.
The Insurance Commissioner’s bulletin compels insurers to remove all barriers to care, including ensuring their telehealth programs with participating providers are robust and will be able to meet any increased demand
Medicaid: At this point it appears that Licensed Clinical Psychologists are only allowed to use the periodic check-in and assessment codes (98966, 98967, and 98968.) Link here for details.
North Dakota
Governor: issued executive order to suspend select telehealth requirements to be in line with CMS recommendations made on 3/17 – licensure waiver, now allowing audio-only visits and waiving cost-sharing for telehealth visits . Link here for details.
Ohio
The Ohio Psychological Association has state specific pandemic resources. These include specific regional insurance updates and blogs from the OPA leadership.
Departments of Health and Medicaid announced emergency orders reducing restrictions on telehealth, ensuring that every Ohioan has access to behavioral health care via telehealth services by landline or cell phone.
Oregon
The Oregon Psychological Association homepage includes state specific resources and webinars.
Notice from the Oregon Health Authority indicates extension of telehealth coverage, ensure cost-sharing is not greater than in-person visits, and shall maintain access to behavioral health services including psychotherapy. Audio only is allowed. Link here for details.
Oregon Medicaid (OHP). Announcement expanding telehealth coverage for behavioral health providers for members of OHP. Fee Schedule allows for 90791/90792, 96136/96137, and 96132/96133. Link here.
Pennsylvania
The Pennsylvania Psychological Association has extensive state COVID-19 resources including information from Pennsylvania’s Governor, and specific PA insurance issues.
Pennsylvania Independence Blue Cross: Link here for commercial- there appear to be tele-NP restrictions. Link here for Medicare Advantage- there also appear to be tele-NP restrictions.
Medicaid:
PA DHS has contracted with certain behavioral health managed care organizations (BHMCO) to administer behavioral health benefits to Pennsylvania Medicaid recipients. Providers should seek coding and billing guidance regarding telehealth services from PA DHS, the applicable BHMCO or County Authority. As an aid to providers, however, below are links to websites that may be helpful.
CCBHO HealthChoices Contracted Providers: general info, 96116, 96121, 96132, 96133 covered.
PerformCare: General info, providers need to get approved for telehealth first, guidelines
Beacon Health Options: General info, attestation forms, and guidelines.
Magellan Behavioral Health: Announcements and telehealth guidelines.
Rhode Island
The Rhode Island Psychological Association.
The Governor has signed an executive order mandating Telehealth Services, including audio only.
South Carolina
Medicaid: It appears that Licensed Clinical Psychologists are only allowed to use the periodic check-in and assessment codes (98966, 98967, and 98968) with established patients. Link here for details.
Texas
The Texas Psychological Assocation has a strong set of state specific resources including state government coverage mandates and emergency rules.
tennessee
The Governor signed an order allowing any TN licensed health care provide to deliver services using telehealth.
Vermont
Vermont Psychological Association has federal and state COVID-19 resources on their homepage, with pdf downloads for tele-psychology practice, WHO handouts, and CIGNA insurance.
Virginia
The Virginia Psychological Association has COVID-19 resources, with extensive information about telehealth. Here is a link to the Virginia Board of Psychology.
Virginia Medicaid: Psych and Neuropsych assessment services delivered via telehealth are covered. Link here for details.
Washington
The Washington State Psychological Association has state specific COVID-19 resources.
Of note, here is the link to the Office of Insurance Commissioner Emergency order for tele-health, and the Governor’s emergency order that mandates telehealth coverage.
West Virginia
West Virginia Psychological Association
Virginia Medicaid: According to this letter the following codes are covered: 96130, 96131, 96132, 96113 (likely a typo on their part), 96136, 96137, and 96146. Note that 96138 and 96139 were not listed.
wisconsin
Anthem: Psychological assessment is allowed via audio/visual but thus far no neuropsychological codes are covered. Link here for details.
Wisconsin Medicaid: Forward Health provides coverage for all currently covered and medically-necessary services, including neurobehavioral status exams and neuropsychological testing (including audio-only). Link here for details