Q: Will Optum hold Cerner training (online?) in order to onboard and allow billing and Cerner access for new staff hired?
A: Classroom-based Cerner and SanWITS trainings will be suspended until further notice. Paper charting is an acceptable method of documentation for services during this period.
A self-paced, virtual training model consisting of resource packets plus practice exercises will be available in the near future. Please contact firstname.lastname@example.org. This includes virtual Doctor’s Homepage training to ensure physicians have electronic health record access. If you need additional staff trained for billing purposes, please contact email@example.com to discuss further.
Q: How can Cerner Community Behavioral Health (CCBH) be accessed from a personal computer?
A: The steps to access CCBH from a personal computer are below:
Step One: Ensure you have been granted access via BHS and have the appropriate Username, Password, and Staff Number.
(BHS MIS Help Desk Number: 619-584-5090 )
Step Two: Log on to CCBH at: https://cosdca.cernerworks.com/Citrix/PRODWeb/
Enter Username and Password. Select Log On.
Step Three: Click the down arrow next to the Username on the upper right side of the Cerner pane.
Select Download Citrix Receiver and follow the prompts. Select Yes to allow the download onto the computer.
Step Four: Double-click the CCBH Live icon. Right-click the .ICA file at the bottom left of the screen after the Live icon is selected. Select Open file. (Note: this will only need to be completed after the initial Citrix download.)
Step Five: Enter the Staff ID and Password. Select OK.
COVID-19 Costs and General Revenue Loss
Q: Overall, our agency would like to know what kind of support the County can offer us (for programs that have County contracts): Will we get financial support if we close our programs? Can we allow short term closures? Can we allow phone services? Can staff work from home?
A: At this point it is not recommended to close programs. Services can be provided via telephone and/or telehealth, as needed. The location of services via telephone and/or telehealth is not restricted. Contractors should continue to chart, track, and document services for billing purposes. Please refer to 3-23-20 – Guidance for County Staff and Contractors Regarding Telehealth, 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices, and 3-17-20 – COVID-19 Guidance and Best Practices.
Q: Will cost reimbursement contracts still be able to pay staff if the program closes or an individual staff member is quarantined?
A: The County is currently exploring funding options and encourages providers to track all COVID-19 expenses for documentation purposes. Additional details are available in 3-20-20 – COVID-19 Financial Practices and Contract Management Guidance.
Q: Is the county putting a process in place to help contracted programs with COVID-19 related revenue loss?
A: The County is currently exploring funding options and encourages providers to track all COVID-19 expenses for documentation purposes. General processes for providers on tracking COVID-19-related activities is available in 3-20-20 – COVID-19 Financial Practices and Contract Management Guidance. The County will continue to provide information to providers as additional State and federal guidance becomes available.
Q: Will there be additional funding to assist those receiving housing support who pay a share of the cost of their housing through employment which is temporarily impacted due to COVID-19?
A: The County will be considering available options to support housing for those impacted by the COVID-19 emergency, contingent upon State and federal guidance. Guidance is forthcoming in future communications.
Q: What sort of guidance is available from Quality Improvement Unit on how to document and apply for COVID billing?
A: Please document as much as possible, and use existing codes as much as possible. Information around that topic is also available in 3-20-20 – COVID-19 Financial Practices and Contract Management Guidance and 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices. Otherwise, programs are advised to continue as normal with documentation of service, and standard code protocol.
Q: There was a suggestion to track activities/services that would normally not qualify as billable during this time. How should we track “never-billable” activities? For example, leaving a message for clients to offer support, check in on their needs, or schedule appointments. Can programs track those under “non-billable” (815) so that we can track the minutes spent?
At this time BHS is asking providers to continue to code all services as you do now (billable vs. non-billable, etc.) unless otherwise notified. Continue data entry, coding and billing as you typically would. Productivity standards are suspended during this time. Leaving messages and scheduling appointments continue to be considered "never billable" activities. However, please note that Mental Health program productivity standards will be waived during this time.
COVID-19 Testing and Transportation
Q: Where can clients be tested for COVID-19?
A: For patients that do not need emergency or hospital attention, programs are advised to have the patient CALL their primary doctor to determine if testing is recommended.
Q: What transportation options are available for patients we would like to direct to testing or healthcare but lack transportation?
A: The County recognizes that some HHSA contractors will need to provide transportation to clients in the course of their service delivery. Please see the 3-23-2020 – COVID-19 Guidance for HHSA Contractors Providing Transportation to Clients.
Q: Are clubhouses advised to shut down at this time per the County’s Public Health Order ?
A: Clubhouses can remain open as long as they comply with all current recommendations from public health orders and guidance issued. Any consideration for a shift in clubhouse staff resources or clubhouse closures should be discussed with the appropriate COR on a case-by-case basis.
Clubhouse-specific guidance is also forthcoming (See current guidance on congregate settings here: 3-13-20 – COVID-19 Response for Residential Facilities with Vulnerable Populations).
Q: In anticipation of staff shortages, can we combine clients from different levels of care in housing, group therapy, and dining areas?
A: During this time, it is acceptable to cohort clients by appropriate physical space in treatment, even if in different levels of care. The focus should be on keeping adequate distancing between clients. See guidance for care in long-term care settings for developing alternative clinical service delivery in residential settings: 3-13-20 – COVID-19 Response for Residential Facilities with Vulnerable Populations.
Q: Can outpatient programs cancel group therapy?
A: Outpatient programs have discretion to cancel group therapy. However, the County is recommending continued engagement with all clients via telehealth and/or telephone, as much as possible. Please see refer to 3-23-20 – Guidance for County Staff and Contractors Regarding Telehealth, 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices, and 3-17-20 – COVID-19 Guidance and Best Practices.
Q: Can we cancel psychiatry appointments if client is stable and medication refills can suffice?
A: Programs are encouraged to triage client needs and telehealth and/or telephonic services are being recommended when possible. The County is recommending continued engagement with all clients via telehealth and/or telephone. Please see refer to 3-23-20 – Guidance for County Staff and Contractors Regarding Telehealth and 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices.
Q: What if a patient refuses to go for medical evaluation?
A: Clients have the right to refuse. Providers can educate clients about the need to see a health care provider, but the decision rests with the individual. If the patient has active symptoms, attempt to arrange telephone and telehealth for ongoing behavioral health services.
Q: Is a SUD provider allowed to consult with another provider without written consent?
A: In making use of alternative means, such as telehealth, in providing needed services during the current declared public health emergency, providers may not be able to obtain written client consent for disclosure of substance use disorder records. The prohibitions on use and disclosure of patient identifying information (PII) under 42 CFR Part 2 would not apply in these situations to the extent that, as determined by the provider, a medical emergency exists. Under the medical emergency exception, providers make their own determinations whether a bona fide medical emergency exists for purposes of providing needed treatment services to clients. In circumstances in which client written consent is not obtained due to the medical emergency exceptions, the provider should document the reason for the disclosure, and make their best attempt to obtain and document client written consent as soon as is practicable. Additionally, if a client is able to provide verbal consent, notation of the verbal consent in the chart will be acceptable for the duration of the COVID-19 response.
Q: Will the County allow Drug Medi-Cal clients to extend their stays in residential settings due to concerns about COVID-19 exposure when transitioning into sober living facilities or other settings?
A: Access for new clients in residential settings is critical. Medical necessity standards still apply even with concerns over COVID-19. Please see guidance 3-13-20 – COVID-19 Response for Residential Facilities with Vulnerable Populations.
Q: Can contracted services related to discharge planning support halt due to impacted staffing and/or limitations on access to hospital emergency rooms and community settings?
A: BHS contractors must continue to seek to perform in accordance with their contract’s terms and remain operational to ensure essential services continue to vulnerable populations. Contractors encountering issues with maintaining continuity of operations should contact their Contracting Officer’s Representative (COR) immediately.
The County recommends that contractors that provide discharge planning support in acute and long term settings continue services via telephone and telehealth if visitation has been restricted by facilities. Additionally, please see 3-19-20 – Information for BHS Providers: Quality Improvement and Best Practices, and 3-20-20 – COVID-19 Financial Practices and Contract Management Guidance for detailed information on changes in contract monitoring and tracking COVID-19-related activities and expenses.
Q: How is BHS prioritizing which services are essential vs. non-essential and what might non-essential service delivery look like?
A: Direct client services are generally considered essential services to ensure the continuity of care. Personnel who provide those direct services, or who are required to ensure those services continue to be provided (i.e., scheduling, billing, information technology) are also generally considered essential. The State of California has delineated Essential Critical Infrastructure. Additionally, contractors may refer to the Organizational Providers Operations Handbook (OPOH), under Provider Contracting section J4, or the Substance Use Disorder Provider Operations Handbook (SUDPOH) on page E:12.
Q: Will Smartphones and wi-fi access be provided for clients who don’t have access?
A: Please communicate specific needs to your COR so any gaps in access can be identified and addressed.
Q: What we should do at a contracted mental health clinic if someone comes in with flu-like symptoms (i.e. fever, shortness of breath, cough, chills, etc.) but also report feeling suicidal? If a client is in a psychiatric emergency (i.e. acutely suicidal) and with some respiratory symptoms, how do we proceed?
A: This all starts with how the various programs are screening patients (e.g. screening questions, temperature, etc.) for acute medical symptoms. Management of the person who screens positive will preempt all else, including behavioral health assessment (assuming the person is not eminently violent). Management should include immediate masking and separation. Given that the patient has acute medical symptoms, a physician should be contacted for medical guidance. Guidance for medical care should take precedent. If the physician does NOT recommend further medical evaluation, the patient should be screened for high risk behavioral health needs. Those who are tested and medically stable, but cannot be isolated at home while results are pending may be eligible for temporary lodging. Staff should call 858-715-2350 from 7AM to 7PM. A negative high risk behavioral screen should result in the patient being sent home with a mask and instructions to social distance, follow medical physician instructions and to call primary healthcare provider for further instruction. If the patient then reveals suicidality, police/PERT will need to be called and given instruction regarding potential contagion risk. The patient will need to be kept isolated. Police/PERT are developing their own policies around this possibility and will react accordingly. For the gray zone between routine and emergency behavioral health needs programs will not want (and really can’t be asked) to do much else with a patient who is screening positive.
Q: What are the best methods to proceed with street outreach? The R-HOM (Regional Homeless Outreach Workers Meeting) would like to inquire, especially given the importance around continued services to the homeless population.
A: Until further notice, please operate business as usual, but with compassionate precautions that comply with state and local public health orders. Programs are encouraged to reach out to their CORs.
For more information, please see 3-17-20 – COVID-19 Guidance and Best Practices.
Q: What is the recommended plan of operations for Recovery Residences (RR)? Are there any exceptions to exceeding the maximum allocation per resident during this state of emergency. It may be difficult for some RR clients to secure employment and pay a percentage of their share at this time. Also, has there been any consideration given to housing support? To help offset those who are unemployed, with food, basic toiletries and more?
A: Substance Use Outpatient programs should continue to link eligible clients to Recovery Residences. Programs should consult on a case by case basis with their COR for approval of extensions during this emergency. Please document and track approved extensions so these extensions can be reconciled.
Additionally, please use available community resources for food and basic toiletries, as appropriate.
Q: What are staffing and pay expectations during the crisis?
A: The County continues to monitor evolving federal and State guidance regarding funding developments and will provide updates as more information is received. Contractors should track their actions and costs directly associated with COVID-19 in case this information is requested in the future, although at this time there is no known mechanism for reimbursement. Contractors should review internal benefit plans, policies and procedures, as well as their County contracts and scopes of work, to identify possible alternative delivery of service options to continue to meet the needs of the populations served and to support staff who may need to stay home during this time.
The federal Office of Civil Rights (OCR) has issued a notice regarding the flexibility for the use of video communication in delivering health care services to clients. Please review your organization's operations and types of services provided, and as applicable and helpful as an alternative mode of delivery, incorporate this guidance received from our federal government. The HHSA Compliance Office has created a centralized page to provide links to current guidance on delivery of services during this time, which includes a link to the OCR notice discussed above.
Q: Can a SUD Residential program upload a chart and send to our staff who is working from home?
A: Legal Entities should continue to use a secure network when uploading personal health information.
Q: Are providers to use a secured network to upload files to communicate with Quality Assurance contacts on the County side if working remotely?
A: County BHS Quality Management record review activities have been suspended until further notice. However, Legal Entities should continue to use a secure network when uploading personal health information.
Telehealth and Mitigation for Physical Distancing
Q: What is the difference between Telehealth and Telephonic services?
A: Telehealth is any non-public facing platform for communicating with clients that includes a video component, while telephonic is client-related communication via telephone that does not include a video component.
Q: Do providers have approval to shift away from face-to-face services and utilize telephonic and telehealth services?
A: Both telephonic and telehealth services are being recommended for both mental health and SUD programs at this time. Please refer to BHS provider communications: 3-23-20 – Guidance for County Staff and Contractors Regarding Telehealth, 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices and 3-17-20 – COVID-19 Guidance and Best Practices.
While we encourage the use of telephone and/or telehealth services, there may be individual clinical scenarios that warrant in-person interactions, so comprehensive cancellation of in-person services is not recommended at this time.
Q: Can Opioid Treatment Program (OTP) providers provide telehealth services?
A: OTPs are permitted to use telehealth in the provision of services. Services that may be provided by telehealth include physician evaluation and management, counseling, and case management. OTP provider personnel are not permitted to expand their scope of practice. If the prescribing practitioner has previously conducted an in-person medical evaluation of the patient, the practitioner may prescribe a controlled substance after communicating with the patient via telehealth. During the Federal state of emergency, the Drug Enforcement Administration has waived the Ryan-Haight Act to allow an initial buprenorphine prescription and all follow up care to be provided by telehealth, without an in-person medical evaluation (however, a telephone assessment is not sufficient). Telehealth service documentation and the patient’s verbal or written consent for the telehealth visit should be documented in the patient record.
Q: Can we utilize telepsychiatry for prescribers who are unable to come into the office?
A: Yes, telehealth is recommended at this time and recent expansion of HIPAA restrictions have been published and are referenced in 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices.
Additional telehealth guidance is available in 3-23-20 – Guidance for County Staff and Contractors Regarding Telehealth.
Q: Can Assertive Community Treatment (ACT) staff conduct services telephonically for clients who are not in psychiatric distress?
A: Programs are encouraged to triage client needs and telehealth and/or telephonic services are being recommended when possible. Please refer to 3-23-20 – Guidance for County Staff and Contractors Regarding Telehealth, and 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices.
Q: Can we cancel groups to ensure social distancing guidelines are adhered to?
A: Outpatient programs have discretion to cancel group therapy. However, the County is recommending continued engagement with all clients via telehealth and/or telephone. Please refer to 3-23-20 – Guidance for County Staff and Contractors Regarding Telehealth and 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices.
Q: Can ACT morning meetings be conducted via telephone or video?
A: Yes, teleworking is acceptable for ACT morning meetings. Please refer to 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices.
Q: Can screenings be conducted by phone?
A: Yes, screenings can be conducted via telehealth and/or telephone. Please refer to 3-23-20 – Guidance for County Staff and Contractors Regarding Telehealth, 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices, and 3-17-20 – COVID-19 Guidance and Best Practices.
Q: Do Substance Use Disorder (SUD) providers need written client consent to provide services by telehealth or by telephone?
A: During the current declared public health emergency, Medi-Cal providers are making use of alternative means of service delivery, such as telehealth, when clinically appropriate based on the individual needs of the client, including inability to present for treatment services in person, or to limit potential exposure to infection. When unable to obtain written consent, the provider should obtain and document the client’s verbal consent for use of telehealth or services provided by telephone. The provider should inform the client, before providing telehealth services, of the potential risk of unintended disclosure when using telehealth technology.
Q: Can SUD providers utilize telehealth from a non-DMC certified site?
A: The location of services via telehealth is not restricted. Clients may receive services via telehealth in their home, and providers may deliver services via telehealth from anywhere in the community, outside a clinic or other provider site. Please refer to 3-23-20 – Guidance for County Staff and Contractors Regarding Telehealth, and 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices.
Q: Can clients choose individual treatment in lieu of group therapy?
A: Outpatient programs have discretion to cancel groups, however, the County is recommending continued engagement with all clients via telehealth and/or telephone. Ongoing clinical assessment should inform continued care. Please see DHCS and CDC guidance on group settings and 3-23-2020 – Guidance for County Contractors Regarding Telehealth.
Q: We are looking into offering our treatment groups via telehealth and want to confirm how to properly track participant attendance since a sign-in sheet will not be available. Are we able to hand write the participants name and indicate verbal consent was given due to COVID-19 in lieu of a signature?
A: Yes, if the provider conducts a group counseling service through telehealth, the provider should obtain and document client verbal consent for conducting the service via telehealth. The provider should document that the clients were informed of the potential risk of unintended disclosure when providing services via telehealth, and that the client then gave verbal consent. Each client’s full printed name should be documented on the group sign-in sheet. In place of the client’s signature, the provider may document “[name of client] verbal consent given” followed by the date and the initials of the Counselor or LPHA who obtained the client’s consent. The progress note for the group service should indicate that the client’s signature could not be obtained and the reason, such as, “Unable to obtain client signature, as service was provided by telehealth due to COVID-19 public health precautions”.
Q: Can the required face-to-face consultation between the SUD Counselor and the LPHA on the ASAM Level of Care (LOC) Recommendation Assessment take place by video instead of in-person?
A: Yes, video conferencing is permitted for the face-to-face consultation between the SUD Counselor and the LPHA. It should be clearly documented that the consultation took place via video rather than in person. Consultation between the SUD Counselor and the LPHA on the ASAM LOC cannot be conducted by telephone, however.
Q: We are in the planning process for our annual landlord recruitment luncheon coming up in April. With the recent warnings on COVID-19, how would you like us to proceed? Should we be providing waivers to attendees or stop the event altogether with recent rules around social distancing etc.?
A: As the landlord recruitment event in this particular scenario is a contractual requirement, it should proceed using a WebEx option, or other virtual solution. Contracted activities must be done in compliance with local and state guidelines related to COVID-19. Programs are encouraged to reach out to their CORs in the event contracted operations shift. Additionally, please track direct COVID-19 related expenses as outlined in 3-20-2020 – BHS Provider Notice – COVID Financial Practices.
Q: Can SUD providers use services such as Telemed Drug Testing Solution?
A: The ASAM website offers guidance on COVID-19 Adjusting Drug Testing Protocols. It highlights that the goal is to balance the utility of having the data from a urine drug test against the risk of COVID-19 virus exposure to patients, laboratory staff, and clinic staff/providers. Guidance includes a recommendation for treatment providers to explore options for drug testing at a distance such as using oral fluid-based tests and/or home breathalyzer tests monitored via telehealth.
Q: Should we be screening clients over the phone if they have traveled within the month?
A: Regardless of recent travel, during this current declared public health emergency providers are encouraged to make use of alternative means of service delivery, such as telehealth, when clinically appropriate based on the individual needs of the client, including inability to present for treatment services in person, or to limit potential exposure to infection. When unable to obtain written consent, the provider should obtain and document the client’s verbal consent for use of telehealth or services provided by telephone. The provider should also inform the client, before providing telehealth services, of the potential risk of unintended disclosure when using telehealth technology.
Additional guidance can be found in 3-26-20 – QM Memo – Telehealth Resources during the COVID-19 Public Health Emergency and 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices.
Page last updated: 4/8/20