Frequently Asked Questions (FAQs) Regarding Coronavirus Disease 2019 (COVID-19) Updated 7/24/2020

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Preguntas Frecuentes (FAQs) Sobre la Enfermedad por COVID-2019 (Actualizado 7/24/2020)


As a result of flexibilities and changes made in response to the COVID-19 emergency, information presented in some FAQs will not align with various provisions set forth in the AHCCCS Medical Policy Manual (AMPM), the AHCCCS Contractor Operation Manual (ACOM) Policies; the AHCCCS billing requirements; and/or other AHCCCS directives. In these instances, the FAQs take precedence and are controlling.


On March 17, 2020 and March 24, 2020, AHCCCS submitted requests to the Centers for Medicare and Medicaid Services (CMS) to waive certain Medicaid and KidsCare requirements in order to ensure ongoing access to care over the course of the COVID-19 outbreak.

  • BILLING & CLAIMS

  • 1. (updated 3/30/20) Question: Does AHCCCS have a centralized resource for medical coding resources related to COVID-19?
    Answer: Yes, the AHCCCS Medical Coding Resources webpage includes a COVID-19 Medical Coding Information section and COVID-19 Emergency Medical Coding guidance.
    2. (updated 5/7/20) Question: Are there billing codes available for COVID-19 testing outside of Centers for Disease Control and Prevention (CDC) testing laboratories?
    Answer: Yes. The Centers for Medicare & Medicaid Services (CMS) created a new Healthcare Common Procedure Coding System (HCPCS) code for COVID-19 tests administered outside of Centers for Disease Control and Prevention (CDC) testing laboratories. This code corresponds with a Food and Drug Administration policy that allows certain laboratories to develop their own tests. Providers should use existing HCPCS code U0001 for CDC testing laboratories and the new HCPCS code U0002 for non-CDC lab tests. In addition, the American Medical Association has added a new Current Procedural Terminology (CPT) code: 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.

    CMS has created additional codes to be used for tests performed with high throughput technologies, in which cases U0003 should be used to identify tests that would otherwise be identified by CPT code 87635, and U0004 should be used to identify tests that would otherwise be identified by U0002. Neither U0003 nor U0004 should be used for tests that detect COVID-19 antibodies.

    3. (added 3/19/20) Question: Will AHCCCS issue guidance regarding prior authorization expectations related to COVID-19 testing and treatment?
    Answer: Prior authorization is not permitted for COVID-19 testing or treatment.
    4. (added 3/20/20) Question: Is there a claims modifier for services related to the COVID-19 emergency?
    Answer: Yes, AHCCCS has designated the CR modifier to be used on all claims for services provided as a result of, or related to COVID-19. It is imperative that providers begin utilizing this modifier immediately in all appropriate instances in order for AHCCCS to identify the costs of services attributable to this emergency. All other guidance regarding use of modifiers continues to be applicable.
    5. (added 5/6/20) Question: Does AHCCCS cover testing for COVID-19?
    Answer: Yes, AHCCCS covers COVID-19 testing. HCPCS U0001 and U0002 have an effective date of February 4, 2020. CPT 87635 has an effective date of March 13, 2020. HCPCS U0003 and U0004 have effective dates of March 18, 2020. All codes have been entered in the AHCCCS PMMIS system.
    6. (updated 3/19/20) Question: Is there an ICD-10 diagnostic code for COVID-19?
    Answer: Yes, The World Health Organization has developed an emergency ICD-10 code for the coronavirus: U07.1, 2019-nCoV acute respiratory disease. The U07.1 is effective in PMMIS for dates of service February 4, 2020 and thereafter. Additionally, CDC’s National Center for Health Statistics will implement a new diagnosis code into the ICD 10th Revision, Clinical Modification, effective with the next update on October 1, 2020; CDC issued interim coding guidance and guidelines for health care encounters and deaths related to COVID-19.
    7. (added 3/25/20) Question: How should hospitals that are reimbursed by APR-DRG bill for inpatient services related to the new ICD-10 diagnosis code for COVID-19?
    Answer: AHCCCS has been notified that the 3M software will not recognize the new ICD-10 diagnosis code for COVID-19 prior to April 1, 2020. Until the April 1, 2020 software release, hospitals should bill for other related conditions such as:
    • Pneumonia
    • Acute Bronchitis
    • Lower Respiratory Infection
    • ARDS - Acute respiratory distress syndrome

    The April 1, 2020 release of 3M software will recognize the newly defined ICD-10 diagnosis code, U07.1, mapped to an existing APR-DRG code under the April 1, 2020 software release.

    8. (added 4/22/20) Question: Is IHS required to report CPT and modifiers on UB-04 claims (pertaining to COVID-19)?
    Answer: IHS facilities are not required to report CPT/HCPCS and modifiers on UB-04 claim forms when billing the All Inclusive Rate (AIR).
    9. (added 8/6/20) Question: Does AHCCCS reimburse IHS and 638 providers for services rendered at an Alternate Care Site (ACS)?
    Answer: Per the COVID-19 Emergency Declaration Blanket Waivers & Flexibilities for Health Care Providers document released by CMS, AHCCCS will reimburse for services provided at or through an ACS, with a retroactive effective date of March 1, 2020 through the end of the emergency declaration. Such services shall be reimbursable, so long as those services performed are administered to a Title XIX or Title XXI eligible AHCCCS member, and are medically necessary, cost-effective, federally and state reimbursable, provided by an AHCCCS-registered provider.

    To qualify for reimbursement, services must be performed by an ACS that is operated by a hospital or clinic owned or operated by the Indian Health Service, or tribes or tribal organizations with a 638 agreement.

    For additional information about ACS reimbursement, including fee for service billing guidelines, please refer to the Division of Fee-for-Service Management (DFSM) Alternate Care Site Memo.
  • CLINICAL DELIVERY

  • 1. (updated 6/8/20) Question: Does AHCCCS have guidance about Prior Authorization (PA) and Concurrent Review procedures during the COVID-19 emergency?
    Answer: Yes, please see the AHCCCS May 1, 2020 memo. This guidance does not apply to AHCCCS Fee for Service Programs. Fee for Service guidance, in coordination with tribal stakeholders, is available in this Fee for Service memo.
    2. (updated 6/5/20) Question: Is AHCCCS willing to suspend medical record review audits and behavioral health chart audit review processes at this time?
    Answer: AHCCCS temporarily suspended medical record review/behavioral health chart audit efforts for providers without quality/utilization concerns through the end of the COVID-19 emergency. While this will continue for the vast majority of audits, AHCCCS has reinstated the System of Care Practice Review (SOCPR) process effective June 1, 2020.
    3. (added 3/27/20) Question: Will AHCCCS consider relaxing the timeframe for issuing Notice of Adverse Benefit Determination (NOABD) letters for non-urgent prior authorization requests? Due to the need to print securely we have been unable to deploy these staff home while complying with this AHCCCS requirement.
    Answer: No, AHCCCS will not be extending the timeframe for Notice of Adverse Benefit Determination (NOABD) letters for non-urgent prior authorization requests.
    4. (added 5/6/20) Question: Has AHCCCS received any additional grant funding to help providers address COVID-19 emergency?
    Answer: Yes, the Substance Abuse and Mental Health Services Administration (SAMHSA) awarded a $2 million grant to AHCCCS on April 16, 2020 to increase mental health services infrastructure in response to the COVID-19 national emergency. Funding will be distributed through the Tribal Regional Behavioral Health Authorities/Regional Behavioral Health Authorities to serve individuals with co-occurring Serious Mental Illness (SMI) designations and Substance Use Disorder (SUD) service support needs. The grant requires: 70 percent to provide direct services to those with co-occurring SMI and SUD needs; 10 percent for healthcare workers with mental health needs (less severe than SMI) requiring mental health care as a result of COVID-19; and 20 percent for all other individuals with mental health needs less severe than SMI.
  • GENERAL COVID-19 QUESTIONS

  • 1. (updated 4/24/20) Question: Where can I get information and updates about the coronavirus and COVID-19?
    Answer: Information about COVID-19 is available from the Centers for Disease Control (CDC) and the Arizona Department of Health Services. Additionally, the general public in Arizona can call the Arizona Poison Control System at 1-844-542-8201 or the statewide COVID-19 Hotline, available 8 a.m. to 8 p.m. daily, in English and Spanish, by dialling 2-1-1 in Arizona. The COVID-19 hotline is administered by 2-1-1 Arizona and the Crisis Response Network, and can address questions about how to prepare for and prevent COVID-19 spread; testing information for COVID-19; at-risk populations; what to do if an individual gets sick; COVID-19 and animals; and other resources for accurate, reliable, and up-to-date information.

    CMS publishes regular guidance and FAQs on this Medicaid.gov web page.
    2. (added 4/17/20) Question: Where can providers find further information about the CARES and Families First Coronavirus Response Acts?
    Answer: CARES and FFCR Act guidance and FAQs on Medicaid.gov.
    3. (updated 3/24/20) Question: Is COVID-19 laboratory testing available outside of the ADHS State Lab?
    Answer: Yes, as of March 16, 2020 COVID-19 testing is now available through private labs as well as the state lab. However, the COVID-19 test requires a specimen to be collected by a physician or other authorized healthcare providers. Do not visit a laboratory location to request the COVID-19 test. Instead, contact your physician or other authorized healthcare provider for guidance regarding getting tested. Your healthcare provider can best advise whether you meet criteria for testing and their office's availability of testing supplies.
    4. (updated 5/6/20) Question: Is AHCCCS covering COVID-19 antibody testing?
    Answer: Yes, as outlined in Section 6004 of the Families First Coronavirus Response Act (FFCRA). Further information is available at the CDC and on the ADHS websites.
    5. Question: Who does ADHS notify when there is a confirmed positive case of COVID-19?
    Answer: ADHS notifies the member’s ordering provider and the member’s County Public Health Department.
    6. (updated 3/19/20) Question: Does AHCCCS have a centralized resource for members who have general questions or are experiencing flu-like symptoms?
    Answer: Yes. AHCCCS has created a web page to address Medicaid-related questions from providers and contractors about COVID-19 at azahcccs.gov/AHCCCS/AboutUs/covid19.
    • For ACC Health Plan members experiencing symptoms: Call the 24-hour Nurse Line for your Health Plan. The Health Plans’ 24/7 Nurse Line numbers are posted on the AHCCCS COVID-19 web page.
    • For FFS Members, including those enrolled in the American Indian Health Program (AIHP), Tribal ALTCS, or a Tribal Regional Behavioral Health Authority (TRBHA): Please contact the nearest American Indian Medical Home (AIMH) 24-hour Nurse Line, your doctor, or the nearest IHS/638 facility. The AIMH Nurse Line phone numbers are posted on the AHCCCS COVID-19 web page.
    7. (updated 3/24/20) Question: Who is at high risk for serious illness?
    Answer: According to the CDC's Situation Summary,, pandemic COVID-19 poses a serious public health risk. Per the Arizona Department of Health Services Frequently Asked Questions, those at higher risk for serious illness include older adults, and people who have serious chronic medical conditions like heart disease, diabetes, and lung disease. It is recommended that these individuals practice enhanced prevention strategies. Check the ADHS website often for the most current information on COVID-19.
    8. Question: Should I keep doctor appointments for routine visits?
    Answer: Please call your health care provider regarding scheduled, routine visits.
    9. (updated 3/23/20) Question: What is the guidance on well-child visits during the COVID-19 pandemic?
    Answer: Please see the most recent guidelines from the American Academy of Pediatrics.
    10. (updated 4/29/20) Question: Should elective and non-emergency medical procedures be delayed or postponed?
    Answer: Following a CMS recommendation, Governor Doug Ducey announced an Executive Order on March 19, 2020 that halts all elective surgeries in the state of Arizona in order to free up medical resources and maintain the capacity for hospitals and providers to continue offering vital services. On April 22, the Governor announced an Executive Order removing restrictions on elective surgeries. Effective May 1, hospitals, health care facilities and providers that meet certain preparedness criteria can resume elective surgeries. Arizona Department of Health Services has posted FAQs about elective surgeries and an exemption request form.
    11. Question: Arizonans are understandably stressed and anxious right now. What mental health resources do you recommend?
    Answer: AHCCCS covers a full array of behavioral health services for members, and crisis services are available to anyone in Arizona, regardless of insurance coverage. In addition, we have added behavioral health resources offered by the CDC and SAMHSA on the COVID-19 webpage.
    12. (updated 4/20/20) Question: What businesses are deemed “essential” under the Governor’s Executive Order issued March 23, 2020?
    Answer: To stem the spread of COVID-19, Governor Ducey issued an executive order clarifying businesses and operations that are deemed “essential” by the state, including, but are not limited to, the following roles and/or job functions:
  • Healthcare and Public Health Operations:
    • Hospitals, clinics, dental offices, pharmacies
    • Public health entities, including those that compile, model, analyze, and communicate public health information
    • Pharmaceutical, pharmacy, medical device and equipment, and biotechnology companies (including operations, research and development, manufacture and supply chain)
    • Home healthcare services providers
    • Mental health and substance use providers
    • Other healthcare facilities and suppliers
    • Includes doctors, nurses, and any other classification of medical personnel necessary to operate those functions in this category
    • This category of essential services shall be construed broadly to avoid any impacts to the delivery of healthcare, broadly define
  • Human Services Operations (including but not limited to):
    • Long term care facilities
    • Residential settings and shelters for adults, seniors, children, andor people with developmental
    • disabilities, intellectual disabilities, substance use disorders, and/or mental illness
    • Transitional facilities
    • Home-based settings to provide services to seniors, adults, and children with physical, intellectual, and/or developmental disabilities, substance use disorders, and/or mental illness, including caregivers such as nannies who may travel to the child’s home and provide care and other in-home services including meal delivery
    • Field offices that provide and help to determine eligibility for basic needs including food, cash assistance, medical coverage, child care, vocational services, rehabilitation services
    • Developmental centers
  • Transportation:
    • Taxis, transportation network providers (such as Uber and Lyft), paratransit
  • Home-based care and services & residential facilities:
    • Home-based care for adults, seniors, children, and/or people with developmental disabilities, intellectual disabilities, Residential facilities and shelters for adults, seniors, children, and/or people with developmental disabilities, intellectual disabilities and substance use disorders and/or mental illness
    13. (updated 5/8/20) Question: Will members lose coverage during the COVID-19 emergency?
    Answer: No, per the Families First Coronavirus Response Act, AHCCCS will not disenroll members during the emergency (with the exception of death, those who move out of state, or those who voluntarily withdraw).
    14. (added 7/24/20) Question: Are non-Medicaid members who are covered under state-only funding, also protected from disenrollment?
    Answer: No, members who are not federally funded under Title XIX (for example, members with a Serious Mental Illness determination who do not qualify for Medicaid) are not exempt from disenrollment during the public health emergency.
    15. (updated 5/8/20) Question: Is AHCCCS continuing to process Medicaid renewals during the COVID-19 emergency? Should providers assist members with their renewals?
    Answer: Yes, while we are not disenrolling members (with the exception of death, those who move out of state, or those who voluntarily withdraw), we are continuing to process annual renewals. Providers are encouraged to continue to assist members with their renewals.
    16. (added 4/14/20) Question: Will AHCCCS reinstitute Prior Quarter coverage during the declared emergency?
    Answer: Prior Quarter, or retroactive coverage, is currently available to children under age 19, pregnant women and women in a post partum period. For individuals other than children, pregnant women and women in a post partum period, approved applications are effective as of the first day of the month in which the application is submitted. Individuals are encouraged to submit an application immediately if they are experiencing a health issue, become uninsured or experience a change in circumstance that may make them eligible for AHCCCS Medical Assistance. Apply for AHCCCS.

    Federal authority to expand Prior Quarter Coverage beyond children under age 19, pregnant women and women in a post partum period is not under consideration. AHCCCS has taken many steps to ensure ongoing access to health care during the emergency period including suspending premium payments and suspending disenrollments.

    17. (added 3/30/20) Question: Is AHCCCS aware of any opportunities for providers to secure loans during the COVID emergency?
    Answer: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act of 2020 (CARES) passed, including immediate loan assistance for small businesses. Providers may wish to review loan opportunities authorized under the Act to determine if they qualify for this stimulus funding. Stimulus loans are not under the purview of the Medicaid program and AHCCCS does not play a role in the administration of small business loan assistance.
    18. (added 4/2/20) Question: During the COVID-19 emergency will AHCCCS members be required to pay premiums?
    Answer: No. For the duration of the COVID-19 emergency, AHCCCS has suspended premium payments for the KidsCare and Freedom to Work programs as well as copayments for the Transitional Medical Assistance (TMA) and Adult populations. Members who have already paid March 2020 premiums will be credited, and individuals who were disenrolled in March will be reinstated for the duration of the emergency.
    19. (updated 5/26/20) Question: How does AHCCCS plan to use the additional 6.2 % in federal matching funds appropriated for Medicaid programs under the Families First Coronavirus Response Act?
    Answer: We are aware of stakeholder interest in how AHCCCS plans to use the enhanced federal funding available through the Families First Coronavirus Response Act. We continue to evaluate how to best use the funds, in light of the expected member growth due to the COVID-19 emergency. In order to receive the match, AHCCCS is required not to disenroll members, and expects membership growth as the existing members remain enrolled and new members are added. As such, AHCCCS must first ensure that the additional funding will cover the cost of the enrollment growth that will occur. AHCCCS is prohibited from disenrolling members through the end of the month in which the declaration ends.
    20. (updated 6/10/20) Question: Does the one-time COVID-19 stimulus payment and/or the unemployment benefit increase affect AHCCCS eligibility?
    Answer: The one-time COVID-19 stimulus payments and the Unemployment Insurance Federal Pandemic Unemployment Compensation (FPUC) benefits will not affect AHCCCS eligibility. See the Arizona Department of Economic Service PEUC website for more information on how FPUC, Unemployment Insurance, and Pandemic Unemployment Assistance payments may affect Medicaid eligibility.
    21. (updated 4/7/20) Question: Due to the COVID-19 emergency, CMS is granting State Medicaid programs the flexibility to waive and/or modify certain Medicaid requirements. What flexibilities has AHCCCS requested?
    Answer: AHCCCS has requested various flexibilities to waive and/or modify certain Medicaid requirements under the 1135 and 1115 Waivers and the State Plan Amendment. CMS has begun to review and grant approval of these requests. As approval is granted, AHCCCS is making operational decisions regarding implementation, and tracking progress in the Status of AHCCCS Emergency Authority Requests document on this page.
    22. (added 4/3/20) Question: How does Governor Ducey’s March 24th Executive Order freezing all evictions in Arizona related to COVID for 120 days affect persons determined Seriously Mentally Ill (SMI) or persons with behavioral health needs (GMH/SU) in AHCCCS supported residential programs, including Permanent Supportive Housing, and/or Behavioral Health Residential Facilities (BHRFs), in which members pay room and board?
    Answer: AHCCCS intends for the Executive Order to apply to all AHCCCS and/or Medicaid funded permanent supportive and transitional housing programs as well as services settings in which AHCCCS members pay for room and board such as BHRFs, assisted living facilities, and group homes. Residential stability is critical for members to comply with mandated stay at home orders. To this end, there should be no disruption of service or alteration of existing subsidies for persons residing in AHCCCS funded Permanent Supportive and Transitional Living programs for persons determined SMI. Similarly, these protections should be broadly applied to any service setting whereby AHCCCS members pay for room and board.

    In all situations during this crisis, AHCCCS encourages increased care coordination of members with behavioral health needs in housing or residential programs/settings to ensure housing/placement security during this crisis. This will allow members to maintain their residential setting and comply with social distancing and stay at home practices required under our State and National COVID response orders for their own health and the health of our community.
    23. (added 4/15/20) Question: Will cell phone text and minute limits be increased or lifted for the free or low cost cell phones provided by the federal government under the Lifeline Act?
    Answer: AHCCCS has learned that some Lifeline Act cell phone providers are lifting limits and providing unlimited minutes and texting due to the COVID-19 emergency. Information is available at: www.obamaphone.com and www.usac.org/lifeline.
  • HEALTH PLANS & AHCCCS FEE FOR SERVICE PROGRAMS (AIHP, TRBHAs and TRIBAL ALTCS) GENERAL GUIDANCE

  • 1. (updated 3/19/20) Question: Should Health Plans be educating their members and contracted providers about COVID-19?
    Answer: Yes, Health Plans and FFS Programs should be proactively educating members and providers utilizing information from the Centers for Disease Control (CDC), the Arizona Department of Health Services (ADHS), and other applicable entities outlined in the AHCCCS Contractor Operations Manual (ACOM) 404, Attachment A. If the only source of information in member education materials is one of the entities listed in ACOM 404, Attachment A, it does not need to be submitted to AHCCCS for review or approval.
    2. (updated 3/19/20) Question: Should Health Plans and FFS providers continue routine staff visits to healthcare facilities, provider practices, and members’ homes?
    Answer: We highly recommend that, when feasible, both Health Plans and FFS Programs and providers leverage technological platforms to conduct virtual visits whenever possible. For example, a 180 day case manager visit for an Arizona Long Term Care System (ALTCS) member located at a Skilled Nursing Facility (SNF) can be done via telehealth.
    3. (updated 3/19/20) Question: Should Health Plans continue to go onsite to provider locations to investigate immediate quality of care concerns?
    Answer: In accordance with CMS guidance, AHCCCS is requesting that Health Plans and FFS Programs maintain investigative efforts for serious health and safety threats (e.g. allegations of abuse). Health Plans and FFS Programs should do their part to support sound infection control protocols, including limiting the number of staff that go onsite for the investigation, implementation of preventive practices such as handwashing and use of hand sanitizer before engaging with members and staff, and assessment of staff health before entering the facility. If Health Plans and FFS Programs encounter issues with ability to conduct onsite/in-person investigation of immediate quality of care concerns, please notify AHCCCS QM of the limitation at CQM@azahcccs.gov.
    4. (added 3/19/20) Question: Should ALTCS Health Plans and Tribal ALTCS programs continue to conduct in-person case management and support coordination visits with members?
    Answer: Per AMPM 1620-E, case managers (and support coordinators) must conduct in-person visits for members residing in a skilled nursing facility every 180 days and to a member receiving HCBS or acute-only services every 90 days. AHCCCS is suspending the in-person requirement at this time. Case managers should continue to reach out to members telephonically to complete monitoring/reassessment efforts to the extent possible. If members are not able to be reached via telephone or other electronic means, outreach attempts should be documented in the member’s case management file.
    5. Question: Are Health Plans permitted to conduct targeted outreach to members at risk to ensure they know the warning signs, understand precautions, and are prepared to take appropriate action should they become ill?
    Answer: Yes, AHCCCS encourages health plans to conduct targeted outreach to at risk members. We highly recommend that Health Plans leverage technological platforms to conduct virtual visits whenever possible.
    6. (added 3/30/20) Question: Is the newborn notification requirement continuing during the COVID19 emergency?
    Answer: The Newborn notification requirements have NOT changed and remain in place.
    7. (added 4/17/20) Question: Will AHCCCS release rules that allow SNF-based dialysis instead of only free standing dialysis centers?
    Answer: AHCCCS is adopting CMS guidance for dialysis treatment for the duration of the COVID emergency. CMS is waiving the requirement that dialysis facilities have to provide services directly on its main premises or on other premises that are contiguous with the main premises. Dialysis facilities may enter nursing home/skilled nursing home facilities to provide dialysis service to its patients in those settings in order to limit community exposure. CMS continues to require that services provided to these nursing home residents are under the direction of the same governing body and professional staff as the resident’s usual Medicare-certified dialysis facility. Further, in order to ensure that care is safe, effective and is provided by trained and qualified personnel, CMS requires that the dialysis facility staff: furnish all dialysis care and services, provide all equipment and supplies necessary, maintain equipment and supplies in the nursing home, and complete all equipment maintenance, cleaning and disinfection using appropriate infection control procedures and manufacturer’s instructions for use. Dialysis services delivered in a nursing home or skilled nursing facility should continue to be billed to Medicare as appropriate for dual eligible members.
  • HEALTH PLAN REQUIREMENTS & DELIVERABLES

  • 1. (added 3/23/20) Question: Will AHCCCS consider waiving or suspending certain deliverables to allow greater flexibility to MCOs considering much of our workforce is telecommuting and focused on member care?
    Answer: Yes, AHCCCS is currently evaluating where flexibility can be offered for deliverables. Additional guidance will be issued in the near future. If an MCO has a specific request, please send it to your AHCCCS Operations/Compliance Officer.
    2. Question: Do the Health Plans need to request and review COOP documents from providers?
    Answer: During the MCO-AHCCCS Weekly COVID-19 call on 3/16, Director Snyder conveyed the message that AHCCCS expects the health plans to check in with critical provider types to ensure these providers, such as Mobile Crisis providers, Stabilization Crisis providers, Long Term Care facilities, and Outpatient Treatment Program (OTP) providers have Continuity of Operations Plans (COOP) and have reviewed them with staff. This expectation to check in does not mean that the health plans need to request copies of providers’ COOP documents.
    3. (added 3/19/20) Question: Is AHCCCS willing to halt hybrid performance measure efforts in light of COVID-19?
    Answer: After careful consideration, AHCCCS has directed HSAG to suspend all medical record procurement and abstraction activities for the CYE 2018 Hybrid Performance Measure Calculations. At this time, AHCCCS is prioritizing MCO and provider response to COVID-19. Once the COVID-19 emergency response has passed, AHCCCS will re-evaluate project timelines and determine next steps for hybrid audits.
    4. (added 3/20/20) Question: Are there any changes to timeframes for behavioral health service delivery during the COVID-19 emergency for members in DCS custody?
    Answer: No, there are no changes to behavioral health response timeframes for children in DCS custody. For example, the Rapid Response is still required within 72 hours after referral from DCS. Please refer to ACOM 417 and ACOM 449 for additional information on AHCCCS timeframe requirements for children in DCS custody.
    5. (added 3/24/20) Question: Will AHCCCS consider relaxing the mandatory 72-hour turnaround time for Behavioral Health Residential Facility (BHRF) prior authorization (PA) determinations due to high volume and possible capacity issues?
    Answer: No, as there are concerns that expanding the 72-hour turnaround time on BHRF determinations could impact the continuity of care between inpatient facilities and transitions into the community.
    6. (updated 5/4/20) Question: Will Corporate Compliance Audits be suspended during the COVID-19 emergency?
    Answer: Yes, AHCCCS is suspending Program Integrity/Corporate Compliance audits through the end of the COVID-19 emergency.
    7. (added 4/1/20) Question: Can MCOs delay sending Quality of Care (QOC) Concern acknowledgement and closing letters to the member when a QOC concern is being processed based on the member’s grievance/request?
    Answer: The MCOs must still comply with this requirement; however, electronic signatures shall be permitted. MCOs must maintain a process for printing and mailing letters in a timely manner. Alternatively, if a concern originated via electronic means (e.g. an email), an email response may be sent to the member in lieu of a hard copy mailed letter. If an email is sent, it should be documented in the QOC file.
    8. (added 4/1/20) Question: Can MCOs delay or suspend redaction of the Seclusion and Restraint reports or Incident, Accident, Death (IAD) report/Quality of Care (QOC) Concern report documentation?
    Answer: AHCCCS will not suspend or delay the redaction requirement. This must be maintained in order to ensure timely submission to the Independent Oversight Committees for review.
    9. (added 4/2/20) Question: Is AHCCCS considering any modifications to the CYE 2020 Performance Measure calculations or requirements?
    Answer: Depending on the length and extent of the current COVID-19 emergency, it is likely that most CYE 2020 performance measures will be impacted nationwide.AHCCCS is aware of this potential impact and is monitoring/awaiting CMS guidance for CMS reportable measures. AHCCCS will post additional guidance for performance measures and performance improvement projects once it becomes available; however, it is anticipated that AHCCCS performance measure calculations and reporting will align with associated technical specifications [CMS Adult and Child Core Set or NCQA HEDIS® (for HEDIS® only measures)] for the measurement period and related reporting requirements.
    10. (added 4/15/20) Question: Does AHCCCS have guidance about Pre-Admission Screening and Annual Residential Review (PASRR) procedures during the COVID-19 emergency?
    Answer: As of March 23, AHCCCS has received federal approval to implement programmatic changes, including the suspension of Pre-Admission Screening and Annual Resident Review (PASRR) Level I and Level II Assessments. Effective March 23, 2020, AHCCCS will not forward any Level II PASRR to the RBHA Contractor for evaluation completion. All PASRR Level II requests forwarded to the RBHA Contractor after March 23, 2020 are now considered cancelled and do not need to be completed by the practitioner. The AHCCCS PASRR team will outreach to the appropriate Nursing Facilities and hospitals to make staff and patients aware of cancelled PASRR Level II evaluations. Any PASRR evaluations forwarded to the RBHA Contractor prior to March 23, 2020 should be completed within the mandated timeframes and returned to the PASRR program mailbox. PASRR invoices will be processed for all completed Level II evaluations. AHCCCS will inform the contractor when PASRR operations will resume. Please forward any questions/concerns to the PASRR Program mailbox at PASRRprogram@azahcccs.gov.
  • PHARMACY & SUPPLIES

  • 1. Question: Will AHCCCS relax refill requirements for medications?
    Answer: Yes, AHCCCS will relax refill requirements including allowing “refill too soon” and allowing 90-day refills for medications that are not Controlled Substances. Many major pharmacy chains are offering free prescription delivery. Please inquire with your pharmacy for more details.
    2. Question: Will AHCCCS allow a 30-day prescription for a Controlled Substance to be filled early?
    Answer: Yes, the pharmacy staff may contact the prescribing clinician to request approval for the early refill. If the prescribing clinician approves the early refill, the pharmacy staff will contact the health plan's Pharmacy Benefit Manager (PBM) Help Desk for an override.
    3. (added 3/20/20) Question: Are pharmacy supplies and durable medical equipment (DME) supplies available for 90-day fills?
    Answer: Yes, supplies, including but not limited to insulin pump supplies, glucose testing strips, lancets, syringes, tubing and other supplies for sleep apnea equipment, nutritional supplements, and incontinence briefs are available for 90-day fills.
  • PROVIDER ENROLLMENT & REQUIREMENTS

  • 1. (updated 4/2/20) Question: Will provider credentialing requirements be relaxed during the COVID-19 response?
    Answer: AHCCCS is requiring that all providers be considered for provisional credentialing, both to limit the immediate burden to providers as well as expedite their availability to serve members during this crisis. Additionally, to reduce burdens on providers, AHCCCS will allow a 6-month extension on the re-credentialing process for all providers in good standing (those with no quality or utilization concerns). Please see the AHCCCS Credentialing/Recredentialing Standards memo.
    2. (added 3/19/20) Question: Do providers still need to conduct in-person supervisory visits of Direct Care Workers?
    Answer: Per AMPM 1240a (Direct Care Services), Direct Care Worker (DCW) agencies are required to perform periodic supervisory/monitoring visits to assess the DCW’s competency in performing the assigned duties in accordance with member’s individualized service needs and preferences. At this time, AHCCCS is suspending in-person supervisory visits. Supervisory review of case notes/charts should continue to the extent possible, as well as supervisory engagement with staff via available telephonic or other electronic means.
    3. (added 3/19/20) Question: Are quality monitoring requirements at facilities being revised?
    Answer: AHCCCS is recommending that quality monitoring visits, including desk-based audits, be suspended unless there are known quality or utilization concerns with the provider. If a known concern exists, the MCO should conduct a desk audit, including review of member charts, personnel files, etc. AHCCCS is still contemplating a provider attestation statement in lieu of the onsite quality monitoring process.
    4. (updated 3/26/20)Question: Providers have expressed concerns about the availability of personal protective equipment (PPE). What resources are available? How can providers obtain some of the FEMA allocated PPE?
    Answer: The Arizona Department of Health Services has issued this COVID-19 Infection Control and Personal Protective Equipment (PPE) Guidance for Arizona. The FEMA allocated PPE initially comes through ADHS and then is distributed to county health departments. Providers are to submit requests directly to their County Health department. See this provider guidance from Maricopa County.
    5. (added 4/16/20) Question: What are the recommendations for Non-Emergency Medical Transportation (NEMT) providers to protect themselves?
    Answer: This Arizona Department of Health Services flier provides information to help NEMT providers understand the signs and symptoms of Coronavirus, how it spreads, the recommendations for how to protect yourself and others, when to use personal protective equipment (PPE), and where to request it.
    6. (updated 4/3/20) Question: What is the expectation for coordination and continuity for Opioid Treatment Program (OTP) providers specific to Medication Assisted Treatment (MAT) in the event that an OTP clinic or OTP network becomes compromised?
    Answer: Each OTP should develop a business continuity plan that is inclusive of the recommendations from ADHS, the Substance Abuse and Mental Health Services Administration (SAMHSA) and the Drug Enforcement Agency (DEA). Should there be a disruption to services, notification should be made to AHCCCS and the Health Plans with which the provider is contracted, or to AHCCCS and the FFS Program(s) with which the member is enrolled, to ensure coordination of care efforts are implemented and access to care is not compromised. Providers should reference and utilize SAMHSA's TAP 34: Disaster Planning Handbook in the development of their plans. Providers should also work with Health Plan and FFS Program Emergency Response Coordinators for additional support. Please see SOTA OTP guidance memo on strategies for OTP Emergency Preparedness; Prevention and Education; Dosing for Take-Homes; Clinic Hours and Self-Administered Medication.

    Please see SAMHSA guidance, issued March 19, 2020, on the provision of methadone and buprenorphine for the treatment of Opioid Use Disorder during the COVID-19 emergency.

    The Drug Enforcement Administration (DEA) has created new exceptions for the prescription of controlled substances via telemedicine for the duration of the COVID-19 public health emergency. In order to ensure access to quality care, the DEA is waiving requirements for prescribers to obtain additional registrations in additional states where the prescribing and administering of controlled substances occurs. This new exception also applies to the prescription of controlled substances via telemedicine to patients in states in which a provider is not DEA-registered. Read the full guidance from DEA. Further guidance may be found in this SAMHSA/DEA letter.
    7. (added 3/24/20) Question: Will AHCCCS consider temporary changes to the Direct Care Worker (DCW) requirements for family members who reside with a member over age 18 to streamline hiring of family members in cases where there is no provider or where there are concerns of exposure due to providers coming into the home?
    Answer: The 90-day training requirement has been suspended, which allows DCWs to provide care while receiving training. The DCW agencies should consider remote learning opportunities to support DCWs, with evaluation of in-person skills and completion of required training following the conclusion of the COVID-19 emergency.
    8. (added 3/19/20) Question: Will AHCCCS relax the requirement for NEMT drivers to collect a passenger’s signature, whether on paper or electronically?
    Answer: Yes, this requirement has been waived.
    9. (added 4/22/20) Question: In areas where there are Stay at Home Orders and curfews for the closure of businesses on tribal lands, are NEMT providers exempt?
    Answer: Providers should defer to local guidance issued by the tribes.
    10. (added 3/24/20) Question: Can CPR/First Aid classes be completed online?
    Answer: CPR/First Aid classes can be completed via a credible online/virtual format sponsored by a nationally-recognized organization with in-person evaluation occurring following the conclusion of the COVID-19 emergency.
    11. (updated 4/8/20) Question: Should providers continue to conduct supervision of staff work, such as LPNs providing home health nursing services or BHTs providing behavioral health care?
    Answer: AHCCCS policies AMPM 1240-G (Home Health Services) and AMPM 320-O (BH Services and Treatment/Service Planning) outline requirements for care and service delivery by LPNs or BHTs, which includes supervision by appropriate professional staff. Clinical professionals as well as technical-level staff should check with their licensing entities on current requirements and/or specific questions regarding professional-level supervision.
    12. (added 3/30/20) Question: Should providers continue to conduct supervision of staff, such as Licensed Professional Nurses (LPNs) providing home health nursing services?
    Answer: Yes, clinical supervision requirements have not changed during the COVID-19 Emergency. Specific to LPNs, AHCCCS Medical Policy Manual (AMPM) 1240-G Home Health Services outlines requirements for service delivery by LPNs, which includes supervision requirements.
    13. (added 4/3/20) Question: Should health plans make exceptions for providers not registered with AHCCCS for payment of a claim?
    Answer: No. Providers (in-state and out-of-state) need to be registered with AHCCCS in order to receive payment.
    14. (added 4/3/20) Question: Will AHCCCS permit providers located out of state to offer both emergency and non-emergency care to Arizona Medicaid and CHIP enrollees?
    Answer: Yes. AHCCCS has created a “short-form” for out-of-state providers in order to streamline the provider enrollment and approval processes for the duration of the emergency. The form, called the Out-of-State Packet, is posted on the AHCCCS Provider Enrollment web page.
    15. (added 4/3/20) Question: Will AHCCCS streamline provider enrollment requirements for out-of-state providers?
    Answer: Yes. AHCCCS will provisionally and temporarily enroll out-of-state providers for the duration of the public health emergency and in order to accommodate members who were displaced by the emergency. Approved out-of-state providers will be terminated from AHCCCS enrollment at the end of the COVID-19 national emergency; no extensions will be granted beyond the duration of the public health emergency. The out of state provider must be a certified provider enrolled in Medicare or with another State’s Medicaid program and be in good standing.
    16. (added 4/3/20) Question: Will AHCCCS suspend revalidation of providers who are located in Arizona or otherwise directly impacted by the disaster event?
    Answer: Yes, AHCCCS has suspended the provider revalidation process at this time.
    17. (added 4/3/20) Question: Will AHCCCS waive the provider enrollment application fee?
    Answer: Yes. The provider enrollment application fee is currently waived at this time, including for Out-of-State provider applications.
    18. (added 4/3/20) Question: Will AHCCCS waive requirements for site visits to enroll a provider?
    Answer: Yes, provider site visits are waived at this time.
    19. (added 4/3/20) Question: What strategies can providers consider to minimize exposure to newborns that require immunizations?
    Answer: One strategy providers can consider is using vaccinations with shorter courses, such as Rotarix (2-dose series) over RotaTeq (3 dose series). AHCCCS is continuing to explore other options.
    20. (added 4/7/20) Question: Due to restricted contact at inpatient facilities related to the COVID-19 emergency, what if the providers or outpatient clinics do not have all of the discharge documents when the member comes in for their follow up appointment post discharge?
    Answer: Inpatient facilities must provide discharge documents to the providers and outpatient clinics to ensure coordination of care. In the event that not all discharge documents are available, the providers and outpatient clinics are required to conduct the follow up appointment based on the available information to determine additional care and next steps for the patient’s recovery. The Health Information Exchange (HIE) or secure electronic means should be used to share documents. Facilities and providers are encouraged to contact Health Current to enroll in the HIE if they have not done so.
    21. (added 4/10/20) Question: Can a provider other than a physician order home health services for members during the COVID emergency?
    Answer: Yes, providers whose licensure enables them to practice independently in Arizona, who are not licensed physicians, are able to order home health services, provided they are able to assess and certify the medical necessity of such services within their scope of practice. For example, a Nurse Practitioner practicing independently in the state of Arizona may order home health services for a member within their care. The ordering provider must provide any necessary attestations, and adhere to any Prior Authorization requirements that are relevant for initiating and continuing home health care services to a member.
    22. (added 4/10/20) Question: What is the process for the second newborn screening?
    Answer: The AZ Dept. of Health Service Office of Newborn Screening advises that newborn screening guidelines have not changed due to COVID-19. Certain conditions are often identified on the second screen after a normal first screen, and if the second screen is not completed, these conditions can be missed or identified late, causing irreversible damage. To limit exposure of COVID-19 to newborns and families, providers are encouraged to collect the second screen during the first well check in-office instead of sending out to a lab. The Office of Newborn Screening can help providers who require supplies to collect in-office tests and provide a free FedEx account for timely transport of newborn screening samples. Contact nbseducation@azdhs.gov or (602) 364-0128 for more information.
    23. (updated 4/22/20) Question: Can fingerprint clearance card requirements be waived to help streamline the onboarding process for new employees of provider agencies in an effort to address workforce shortages?
    Answer: No. The provider agencies required to comply with Fingerprint Clearance Card requirements as specified in A.R.S. Title 41, Chapter 12, Article 3.1 must maintain compliance with the law during the COVID-19 state of emergency. If provider agencies are having challenges in finding open locations for professional fingerprinting services, they may want to consider a local police department or professional fingerprinting services that offer online or mobile service options.
  • RATES

  • 1. (updated 5/5/20) Question: What are the AHCCCS fee for service (FFS) rates for the COVID-19 testing codes?
    Answer: Effective February 4, 2020, the rate for code U0001 is $35.91 and the rate for code U0002 is $51.31. Effective March 1, 2020, the rate for code G2023 is $23.46 and the rate for code G2024 is $25.46. Effective March 13, 2020, the rate for code 87635 is $51.31. Effective March 18, 2020, the rates for codes U0003 and U0004 are $100.00.
    2. (updated 3/30/20) Question: Will AHCCCS provide financial assistance to providers to address revenue losses experienced as a result of the COVID-19 emergency?
    Answer:
    • AHCCCS recognizes that some providers may experience a reduction in the number of services they can provide during the emergency period as a result of members avoiding provider offices. AHCCCS is actively exploring opportunities to ensure provider sustainability to address this challenge.
      • One option that AHCCCS intends to implement is to make interim payments to Targeted Investment (TI) Program participants for Year 3 as soon as possible. Information has been emailed to TI participants regarding these interim payments.
      • AHCCCS is also evaluating potential flexibility the Centers for Medicare and Medicaid Services (CMS) may provide, which would allow AHCCCS and its Health Plans to make limited "retainer" payments to specific types of providers.These payments would be specifically related to reductions in utilization of services related to the COVID-19 emergency, such as missed appointments or decreased frequency of members receiving services. Such payments would be intended to help offset the reduction in revenue experienced by providers due to members staying home and avoiding care.
      • The Arizona Legislature has passed legislation stating that AHCCCS may authorize payments to specific types of providers to ensure that providers maintain capacity to continue to provide services during the state of emergency, however, no additional funding was appropriated for this purpose.
    • Any action AHCCCS takes will require CMS approval and upon approval AHCCCS will work swiftly to operationalize the dissemination of retainer/retention dollars.
    3. (updated 5/20/20) Question: Does AHCCCS have any update on retainer payments for providers?
    Answer: CMS has approved retainer (also referred to as retention) payments for HCBS providers of personal care services. As such, AHCCCS is making retention payments to providers serving members enrolled in the ALTCS Elderly and Physical Disabilities (EPD) program, including both Attendant Care and Personal Care services.

    At this time, CMS’ approval is limited to 30 days of retention payments for participating providers. Consecutive billing days are defined as follows:
      • If a service is provided on a daily basis 7 days a week, then 30 consecutive billing days is 30 calendar days.
      • If a service is provided 5 days a week, then 30 consecutive billing days corresponds to 6 weeks of services (5x6=30).
      • If a service is provided 3 days a week, then 30 consecutive billing days corresponds to 10 weeks of services (3x10=30).

    AHCCCS has established guidelines for provider qualifications to receive retention payments. Among those guidelines is a requirement that providers not lay off staff and maintain staff salary and wages at pre-COVID-19 levels. Please see the COVID-19 Retention Payment Guidelines.

    The Department of Economic Security, Division of Developmental Disabilities (DES/DDD) has established COVID-19 Value Based Payments for HCBS providers serving members enrolled in the ALTCS DD program. See more details here regarding this DES/DDD VBP initiative.

    AHCCCS is in frequent contact with CMS regarding its request for approval authority for retention payments for other provider types and services including but not limited to behavioral health providers. The FAQs will be updated as new information is received.
    4. (added 4/23/20) Question: How can EMS providers assist with reducing ambulance transports to, and non-emergency use of, hospital emergency rooms during this COVID-19 crisis?
    Answer: EMS providers are able to participate in a joint Arizona Department of Health Services (ADHS) and AHCCCS program called Treat and Refer. The Treat and Refer program addresses the situation when an individual calls 911, but whose illness or injury does not require ambulance transport to a hospital emergency department.

    In order to receive reimbursement for Treat and Refer services for AHCCCS members, EMS agencies must first submit an application to ADHS (click here for more information on the application process). Of note, ADHS revised the requirements for the Treat and Refer program in January 2020 in order to streamline the application process and increase participation. Once approved, ADHS will connect EMS providers to AHCCCS to complete the AHCCCS provider application process in order to receive reimbursement for Treat and Refer services. AHCCCS and ADHS will expedite application processing due to the COVID-19 emergency.

    AHCCCS is reimbursing Treat and Refer providers for A0998 Ambulance response and treatment, no transport, conducted in-person as well as via telemedicine (interactive audio and video communications). When conducting via telemedicine, the GT modifier must be used. Please refer to the AHCCCS Medical Coding webpage for additional information.

    In addition, during the COVID-19 public health emergency, EMS agencies can perform the clinical Treat and Refer activities, with the COVID-19 guidelines as approved by their administrative medical director, without submitting an application to ADHS for Treat and Refer recognition. However, under this pathway, these EMS agencies cannot bill AHCCCS for reimbursement.
    5. (added 4/22/20) Question: For providers who are paid by RBHAs under block payment arrangements, and who have a payable due now or during the COVID-19 emergency period to the RBHA for submitting encounters below the required threshold for block for periods prior to the COVID-19 emergency declaration, will AHCCCS provide any financial assistance for these payables?
    Answer: AHCCCS is directing the RBHAs to delay collection of payments owed by providers (that are due now or during the COVID-19 emergency period) due to the provider submitting encounters below required thresholds for all periods prior to the start of the emergency declaration on March 13, 2020. This delay shall be in place for three months after the end of the month in which the emergency period is officially ended. RBHA’s are allowed to inform block providers of their encounter shortfall/overage to block funding so that providers can appropriately record necessary accounting entries, i.e., payables/receivables. Providers that desire to pay for encounter shortfalls prior to the RBHAs collecting overpayments three months after the end of the month in which the emergency period is officially ended shall be allowed to make those payments.
    6. (added 4/22/20) Question: When the emergency period is over and the future reconciliation of block payments paid during the COVID-19 emergency finds that the provider has a payable, will AHCCCS provide any financial assistance for those payables?
    Answer: AHCCCS shall direct RBHAs to delay future collection of payments, no sooner than three months after the end of the month in which the emergency period is officially ended, for monies owed by providers for the period of under-reporting that occurs during the COVID-19 emergency period.

    AHCCCS does not intend to lower encounter thresholds. Providers are encouraged to continue to deliver medically necessary services to members using telehealth and telephone delivery, which are paid/valued at the same rate as face-to-face delivery, to the greatest extent possible.
    7. (added 4/22/20) Question: For providers who are paid by RBHAs under block payment arrangements, and who will not be able to meet encounter thresholds for the block during the period of the COVID-19 emergency declaration due to under-utilization of services, will AHCCCS reduce encounter threshold requirements if AHCCCS receives approval from CMS for behavioral health provider retention payments?
    Answer: Reducing encounter thresholds for under-utilization of services during the COVID-19 declaration period is essentially a form of retention payments. Providers paid under block payment arrangements should be treated the same as providers paid under fee for service arrangements who are also experiencing under-utilization of services relative to retention payments. That is, regardless of how the provider is paid by the RBHA (block or fee for service), many providers are seeing reduced appointments and thus reduced revenue.

    If AHCCCS receives CMS approval to implement retention payments for behavioral health providers, AHCCCS intends to implement retention payments for providers regardless of the manner in which they are paid (block or fee for service) in accordance with the provider/service requirements established by CMS.

    That said, all providers are encouraged to continue to deliver medically necessary services to members using telehealth and telephone delivery, which are paid/valued at the same rate as face-to-face delivery, to the greatest extent possible.
    8. (updated 4/27/20) Question: What has AHCCCS done to date to supply financial relief to providers impacted by the COVID-19 emergency?
    Answer: In addition to the federal relief that is being disseminated or will soon be disseminated directly to providers through the CARES Act* and another COVID funding package that is currently making its way through the legislative process**, AHCCCS has taken many actions to provide financial relief to Arizona Medicaid providers, including:
    • Offered $5.3 million in additional payments to Critical Access Hospitals (CAHs) using the temporary Federal Medical Assistance Percentage (FMAP) increase of 6.2% included in the Families First Coronavirus Response Act (FFCRA). The temporary increase allowed AHCCCS to recalculate supplemental payments to CAHs to reflect an increase of approximately 64%.
    • Accelerated $50 million in payments to hospitals which participated in the Graduate Medical Education (GME) program in 2019, including $2.5 million to trauma hospitals.
    • Made $6 million in additional payments to Nursing Facilities (NFs) using the temporary Federal Medical Assistance Percentage (FMAP) increase of 6.2% included in the FFCRA. The temporary increase allowed AHCCCS to recalculate supplemental payments that were made in February 2020 to reflect an increase of approximately 25% for participating NFs.
    • Advanced supplemental payments to three hard-hit NFs facilities by one month, allowing payments to be made in April rather than May 2020.
    • Initiated the provision of retention payments (payments aimed at covering the cost of revenue declines stemming from decreased utilization) to ALTCS providers who serve individuals who are elderly or have physical disabilities (ALTCS EPD) and offer attendant care and/or personal care services. AHCCCS has released operational guidelines to ALTCS EPD providers and Managed Care Organizations (MCOs), allowing for the initiation of such payments.
    • Accelerating $41.3 million in interim payments in early May to participants in the Targeted Investments (TI) Program. Payments are typically made sometime after the close of the contract year which ends on September 30.

    Additionally, AHCCCS has:
    • Asked for, and is awaiting, CMS approval to make retention payments to other provider types.
    • Applied for, and has been awarded, a $2.0 million SAMHSA grant to increase the mental health services infrastructure in response to the COVID-19 national emergency.
    • Requested CMS approval to make $270 million in interim payments to hospitals participating in the GME program in 2020.

    *CARES Act

    The CARES Act, signed March 27,established a $100 billion provider relief fund to reimburse health care providers for COVID-19 expenses and lost revenue. The first round of payments was released in mid-April, totaling $30 billion nationally. Over 6,000 Arizona providers and systems shared in more than $707 million in payments based on their 2019 Medicare Fee For Service payments.
    A second round of the remaining $70 billion in the provider relief fund from the CARES Act is anticipated to be targeted at:
    • Medicare facilities and providers
    • Hospitals in areas that have been particularly impacted by the COVID-19 outbreak
    • Treatment of the uninsured
    • Rural health clinics and hospitals
    • Indian Health Services facilities
    • Medicaid-predominant providers

    The Act also included $1.3 billion in supplemental funding for Federally Qualified Health Centers (FQHCs). Twenty-three Arizona FQHCs received a combined $25.8 million in supplemental payments.

    The CARES ACT stipulates that appropriated funds are not to be used to reimburse expenses or losses that have been or will be reimbursed from other sources.

    **Paycheck Protection Program and Health Care Enhancement Act (as of 04/22/2020)

    The new $475 billion package will focus on funding for:
    • The Small Business Administration’s Paycheck Protection Program, which exhausted the CARES Act’s appropriation last week
    • The Small Business Administration’s Emergency Impact Disaster Loan program
    • COVID-19 testing
    • Additional COVID-19 relief via the Public Health and Social Services Emergency Fund (this is in addition to the $100 billion appropriated in the CARES Act)

    The Federal Administration has not yet provided specific details about how and when the funds will be distributed.

    9. (Added 6/17/20) Question: On June 9, the U.S. Department of Health and Human Services (HHS) through the Health Resources and Services Administration (HRSA),announced distributions from the Provider Relief Fund to eligible Medicaid and CHIP providers. Does AHCCCS have details about how and when these provider relief funds will be distributed?
    Answer: The Provider Relief Fund monies, to be distributed to eligible Medicaid and CHIP providers, total approximately $15 billion nationwide. Providers will be eligible for payment if they:
    • Did not receive funds from HHS as part of the $50 billion General Distribution (of which $30 billion was distributed in April 2020), and
    • Billed Medicaid or CHIP programs for healthcare-related services from January 1 to May 31, 2020

    The payment to each provider will be at least 2 percent of reported gross revenue from patient care; the final amount each provider receives will be determined after the data is submitted through the CARES Act Provider Relief Fund Payment Attestation Portal, including information about the number of Medicaid patients providers serve. Providers must submit their data by July 20, 2020.

    HHS has published more information on the provider relief fund website including:

    Providers should not rely solely on information provided by AHCCCS. More information about eligibility and the application process is available at the CARES Act General Information webpage.
  • TELEHEALTH DELIVERY & BILLING

  • 1. (updated 4/9/20) Question: Are telehealth services covered by AHCCCS?
    Answer: Yes, AHCCCS covers all forms of telehealth services including asynchronous (store and forward), remote patient monitoring, teledentistry, and telemedicine (interactive audio and video).

  • As per AHCCCS Medical Policy Manual 320-I:
    • There are no AHCCCS restrictions for where the provider is located when providing services via telehealth.
      • In addition to utilizing current AHCCCS registered providers, Arizona was authorized by CMS on March 23rd to provisionally and temporarily enroll providers who are enrolled with another State Medicaid Agency or Medicare for the duration of the public health emergency.
  • For more information about telehealth services, please see this April 9, 2020 presentation, or visit the AHCCCS Medical Policy Manual 320-I Telehealth and the AHCCCS Telehealth Code Set.

    2. (added 4/1/20) Question: Question: Can all AHCCCS covered services be delivered via telehealth (including telephonic) and reimbursed by AHCCCS?
    Answer: All services that are clinically able to be furnished via telehealth modalities will be covered by AHCCCS throughout the course of the COVID-19 emergency. Ultimately, it is up to the treating provider to follow clinical best practices and use clinical judgement to determine what services can reasonably be provided via telehealth versus what services must be provided in-person. All scope of practice, coding, and documentation requirements still apply to services delivered via telehealth. For more detail about medical coding please see the Medical Coding Resources web page.
    3. (updated 3/31/20) Question: What codes can be used when services are provided telephonically?
    Answer: AHCCCS has established two telephonic code sets that are available for use:
    • Table I, AHCCCS Telephonic Code Set (Temporary) provides the lists of codes available on a temporary basis to be provided telephonically starting on dates of service March 17, 2020 until the end of the COVID-19 declared emergency.
      1. The UD modifier must be used when billing the applicable CPT or HCPCS code to designate telephonic service.
      2. The Place of Service (POS) is the originating site (ie, where the member is located at the time of the telephonic service delivery). POS home (12) is allowable for all temporary telephonic codes.
    • Table II, AHCCCS Telephonic Code Set (Permanent) are codes that have been available for use telephonically prior to the COVID-19 declared emergency and will continue to be available after the end of the emergency. There is no change to the coding standards for these codes. When providing these services telephonically, please continue to utilize POS 02 telehealth.

    Both code sets, along with additional medical coding information and guidance, are posted on the AHCCCS Medical Coding Resources web page.

    Respite is not available to be provided telephonically. For any AHCCCS coding related questions, please contact: CodingPolicyQuestions@azahcccs.gov. Telehealth services should otherwise continue to be billed in compliance with AMPM 320-I Telehealth.

    4. Question: Will all AHCCCS Health Plans and the AHCCCS Fee-For-Service Programs honor the use of the telehealth and/or telephonic services and service codes, as expanded by AHCCCS in response to COVID-19?
    Answer: Yes, regardless of whether a provider is specifically contracted to provide telehealth and/or telephonic services, AHCCCS Health Plans and AHCCCS Fee for Service Programs will reimburse for services.
    5. Question: For members who have been receiving behavioral health services through the AHCCCS Behavioral Health in Schools Initiative, can telephone and telehealth be leveraged to provide these services in the member’s home and/or community while school is closed?
    Answer: Yes, AHCCCS strongly encourages Behavioral Health Providers to continue to provide behavioral health services to children and their families in their home and community while schools are closed. Please see other telehealth FAQs for additional information on telehealth and telephonic service delivery.
    6. (updated 6/24/20)Question: Is there an AHCCCS Fee Schedule rate difference for services provided “in-person” versus services offered via telehealth and/or telephonically?
    Answer: The rates on the AHCCCS fee schedule for services offered via telehealth and/or telephonically are not lower than the published rates for "in-person" services.
    7. Question: Are AHCCCS health plans required to reimburse at the same rate for services provided “in-person” and services provided via telehealth and/or telephonically?
    Answer: Yes, effective March 18, 2020 until the end of the COVID-19 emergency declaration, AHCCCS health plans shall not discount rates for services provided via telehealth and telephonically as compared to contracted rates for "in-person" services.
    8. (added 3/19/20) Question: Can Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) offer services via telehealth?
    Answer: On March 18, 2020, CMS issued guidance for Medicaid programs confirming that FQHCs and RHCs can offer services via telehealth, including services via telephone. For more information on the services that can be offered via telehealth/telephone, please see other telehealth questions/answers in this FAQ document.
    9. (added 3/19/20) Question: What rate will AHCCCS pay an FQHC/RHC for services delivered via telehealth?
    Answer: In accordance with the March 18, 2020 guidance from CMS, for services offered via telehealth within the scope of the FQHC/RHC benefit, health plans and AHCCCS FFS programs will pay the established PPS rate. For services offered via telehealth that are not covered as part of the FQHC/RHC benefit, health plans will reimburse FQHCs/RHCs at contracted rates and AHCCCS FFS programs will reimburse FQHCs/RHCs consistent with the AHCCCS fee schedule.
    10. (added 3/26/20) Question: Are there any AHCCCS restrictions on the AHCCCS provider types that are permitted to provide services via telehealth (including telephonic) modalities?
    Answer: As per Governor Ducey’s Executive Order 2020-15 effective March 25, 2020 through the end of the COVID-19 declared emergency, telehealth services may be provided by any Arizona licensed healthcare provider type, including but not limited to, physicians, physicians assistants, advanced practice nurses, optometrists, psychologists, dentists, occupational therapists, physical therapists, pharmacists, behavioral health providers, chiropractors, athletic trainers, hearing aid dispensers, audiologists, and speech-language pathologists.
    11. (added 3/20/20) Question: Can telehealth and telephonic service delivery methods be leveraged to provide behavioral health services to children in DCS custody?
    Answer: Yes, telehealth and telephonic service delivery methods can be utilized when clinically appropriate to provide behavioral health services to children in DCS custody.
    12. (update 3/26/20) Question: Typically providers require in-person visits for controlled substance refills. Can these services be provided via telehealth or telephone during the COVID-19 emergency?
    Answer: AHCCCS has updated its telephonic and telehealth code sets to enable providers to be able to conduct visits remotely, including for controlled and non-controlled substance medication refills when clinically appropriate.
    13. (added 3/24/20) Question: During the COVID-19 emergency period, how do providers handle the informed consent requirements and treatment plan agreements/signatures and/or other documents that require a member or guardian's written consent, agreement and/or signature if they are providing services via telehealth or telephone?
    Answer: During the COVID-19 emergency, providers delivering services through telehealth and telephonic means can obtain verbal consent and verbal treatment plan agreements and document the Member's/Guardian's verbal consent and verbal agreement in the Electronic Medical Record (EMR). It will not be necessary to gather retroactive signatures once the COVID-19 emergency period ends provided the documentation is in the EMR.
    14. (updated 5/6/20) Question: Can LOCAL EDUCATION AGENCIES (LEAs) receive reimbursement for Medicaid-covered medical services provided to eligible students through telehealth and telephonic means during school closures due to COVID-19?
    Answer: AHCCCS, working in conjunction with the Arizona Department of Education and Public Consulting Group (AHCCCS’ third party administrator for the Medicaid School Based Claiming program), have updated their systems to allow LEAs to bill for telehealth services for the Medicaid in Schools program for Dates of Service (DOS) March 30, 2020 and later.
    15. (updated 5/6/20) Question: How does an IHS/638 Provider bill telehealth services?
    Answer: For specific billing instructions regarding telehealth and telephonic services, please see Chapter 8 -Individual Practitioner Services of the IHS-Tribal Provider Billing Manual. The Division of Fee-for-Service Management has not changed the way to bill for telehealth services but has expanded what services can be delivered via telehealth.
    16. (updated 5/6/20) Question: How does the “Four Walls” apply to IHS/638 free-standing clinics?
    Answer: In March 2020, AHCCCS requested flexibility from CMS to reimburse free-standing clinics at the All Inclusive Rate for telehealth and telephonic services during the COVID-19 emergency, even if neither the member nor the clinician was within the “Four Walls” but a clinic visit/facility defined service had been provided.

    Per CMS FAQs issued on January 18, 2017, they will not review claims for adherence to the “Four Walls” requirement until January 30, 2021 for free-standing IHS/638 clinics. See FAQ number 13 on the Medicaid.gov website.
    17. (updated 3/31/20) Question: Can physician interns and residents provide telehealth services to AHCCCS members?
    Answer: AHCCCS reimburses for telehealth services provided to our members by physician interns and residents. Billing parameters remain the same and additional information can be found in the FFS Provider Manual (page 40).
    18. (updated 4/7/20) Question: Can telehealth be utilized for initial appointments (i.e. when members that have not been seen face-to-face previously)?
    Answer: Yes, telehealth can be utilized for initial appointments when clinically appropriate. For Medication Assisted Treatment (MAT), SAMHSA guidance has indicated telehealth for initial appointments can only be used for buprenorphine products. Telehealth for initial appointments for methadone is unallowable. For more information see SAMHSA guidance, issued March 19, 2020, on the provision of methadone and buprenorphine for the treatment of Opioid Use Disorder during the COVID-19.
    19. (added 3/30/20) Question: Are behavioral health technicians (BHTs) permitted to provide services via telehealth modalities (including telephonically)?
    Answer: Yes, BHTs can utilize telehealth modalities to provide behavioral health services. AMPM 320-O Behavioral Health Assessments and Treatment/Service Planning and 310-B -TITLE XIX/XXI Behavioral Health Service Benefit outline requirements for service delivery by BHTs, including clinical oversight requirements.
    20. (added 3/31/20) Question: For the DDD population, can habilitation codes be added to the Temporary Telephonic Code List during the COVID-19 emergency?

    Answer: AHCCCS had added the following habilitation codes to the Temporary Telephonic Code List for the DDD population only: T2016, T2017, T2019, T2020 and T2021.

    All codes must still meet medical necessity, scope of practice and all coding, policy and documentation requirements. Refer to Table 1 AHCCCS Telephonic Temporary Codes on the Medical Coding Resources web page.

    21. (updated 4/1/20) Question: Is there Federal Guidance for utilizing widely available communications applications for providing telehealth services, such as FaceTime or Skype during the COVID-19 emergency?

    Answer: On March 17, 2020 the Office for Civil Rights (OCR) at the U.S Department of Health and Human Services (HHS) announced, effective immediately, that it will exercise its enforcement discretion and will waive potential penalties for HIPAA violations against health care providers that serve patients through everyday communications technologies during the COVID-19 nationwide public health emergency. More information can be found at HHS Office of Civil Rights and SAMHSA.

    22. (added 4/29/20) Question: Can primary care physicians and pediatricians outreach to their patients to provide preventive medicine counseling via telehealth (including telephonic) during the COVID-19 emergency?

    Answer: Yes, providers are encouraged to outreach to patients to ensure their care needs are being met during the emergency. Information on what billing codes can be used for preventive medicine counseling are listed on the Medical Coding Resource web page.

  • UNINSURED TESTING

  • 1. (added 5/5/20) Question: Can providers be reimbursed for COVID-19 testing for Arizonans who are uninsured?
    Answer: Yes. The Families First Coronavirus Response Act authorized federal reimbursement for COVID-19 testing and services for any uninsured individual. The US Department of Health and Human Services, Health Resources & Services Administration (HRSA), announced the COVID-19 Uninsured Program Portal. To learn more, read this AHCCCS News post.