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COVID-19 Outbreak: Telemedicine Expanded for ABA Services

Monday, March 30, 2020

In response to the COVID-19 pandemic, the Defense Health Agency (DHA) is expanding telemedicine options allowed under TRICARE’s Autism Care Demonstration. In addition to outcome measures, applied behavior analysis (ABA) supervisors and assistant behavior analysts may now provide parent/caregiver guidance via telehealth. This exception is in place during the emergency period of March 31–May 31, 2020. Providers must comply with telemedicine guidelines outlined in TRICARE Policy Manual, Chapter 7, Section 22.1. 

Below is an overview of the updated policy. For more information visit our Benefits A–Z and find additional FAQs at www.health.mil/autism

  • Telehealth for 97156 (parent/caregiver guidance). TRICARE is permitting Current Procedural Terminology (CPT®) code 97156 for synchronous (two-way audio and video) telehealth delivery, when performed by ABA supervisors (BCBA-Ds, LBAs, BCBAs) or assistant behavior analysts (BCaBAs, QASPs) and billed with the GT modifier and place of service 02. (Behavior technicians cannot render 97156 services.) HNFS will perform audits to ensure compliance with these guidelines. All session note and medical documentation requirements remain in effect. Services billed under 97151, 97153 and 97155 remain prohibited for delivery via telehealth, per TRICARE Operations Manual, Chapter 18, Section 4. Services under 97156 can still be rendered in person (see next bullet for same-day exception)

  • Same-day telehealth and direct care. TRICARE will not reimburse for direct services (97153, 97155, 97156) rendered on the same day as 97156 services via telehealth. Additionally, if you are no longer providing direct services under 97153, you cannot continue to bill for program modifications (97155). Program modifications are only permitted for direct therapy.

  • Claims requirements. Claims for 97156 rendered via telehealth must include the GT modifier and place of service 02. This service is unlimited during this emergency period. 

  • Initial assessments. ABA providers who have been approved for an initial assessment (97151) but are unable to meet with beneficiaries in person can perform these via indirect methods (not telehealth). Any program modifications needed once direct visits start can be completed via the in-person 97155 CPT code. Similarly, although reassessments (97151) cannot be completed via telehealth, you may complete these indirectly for beneficiaries whose authorizations are expiring. ABA supervisors may need to estimate progress from the last direct visit if services have been suspended or are only via telehealth. ABA supervisors should continue to complete reassessments and update treatment plans on the normal timeline. 

  • Authorizations. During the emergency period, units for 97156 are unlimited; however, there must be an approved authorization on file for 97156 for claims to pay. No changes are required for existing authorizations. All other requirements for reauthorization (referrals, PDD-BI, treatment plans) are still mandatory, without exception. Do not let authorizations lapse! Continue to submit reauthorization requests 30 days prior to current authorizations expiring, even if care is not being rendered. We are unable to issue retroactive authorizations for ABA services, including 97156 via telehealth.

Find the latest information on the COVID-19 outbreak at www.cdc.gov/COVID19 and additional provider resources specific to TRICARE on our Coronvirus web page. Subscribe for ongoing ABA updates at www.health.mil.



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