NC Medicaid Telemedicine Updates for COVID-19

March 31, 2020Alerts

Between March 20 and March 30, 2020, North Carolina Medicaid issued five Special Bulletins that temporarily modify its Telemedicine and Telepsychiatry Clinical Coverage Policy to permit the delivery of remote care for Medicaid recipients on a more widespread and convenient basis. 

The policies announced in the Special Bulletins will remain in effect for the duration of the state of emergency in North Carolina or until rescinded, whichever is earlier. These temporary policies may be modified as the state of emergency continues. Each Special Bulletin contains detailed information regarding revisions to billing and coding requirements, including place of service, CPT codes, and modifiers.

Special Bulletin #9 contains the most significant changes. It permits billing starting on March 23, 2020, for dates of service on or after March 10, 2020.

Key Changes

  • Telemedicine and telepsychiatry services can be conducted via any HIPAA-compliant, secure technology with audio and video capabilities, including smartphones, tablets and computers. This is consistent with the guidance from the Office of Civil Rights for the US Department of Health and Human Services.
  • Virtual Patient Communications, which are defined to include audio-only communications, secure messaging using virtual patient portals, and store and forward technology, can be used in addition to two-way real-time interactive audio and video.
  • Patients can now receive telemedicine services from their homes.
  • There are no restrictions on where the telemedicine provider must be located as long as patient privacy is protected.
  • There are no requirements related to referring providers.
  • The list of eligible telemedicine and telepsychiatry providers now includes clinical pharmacists, licensed clinical social workers (LCSWs), licensed clinical mental health counselors (LMHC), licensed marriage and family therapists (LMFTs), licensed clinical addiction specialists (LCASs), and licensed psychological associates (LPAs).
  • Neither prior authorization nor an initial in-person examination prior to receiving telemedicine or telepsychiatry services is required.
  • Special Bulletin #19 adds the following associate level providers to the list of eligible telepsychiatry providers:  licensed clinical social worker associate (LCSW-A), licensed clinical mental health counselor associate (LCMHC-A), licensed marriage and family therapist associate (LMFT-A), and licensed clinical addiction specialist associate (LCAS-A).
  • Special Bulletin #28 is an addendum to Special Bulletin #9 and adds telephone management and assessment codes for Federally Qualified Health Centers and Rural Health Centers for services provided by licensed psychologists, LCASs, LCMHCs, LPAs, LCSWs, and LMFTs. It also clarifies that certain psychiatric diagnostic evaluation and management codes can only be billed by licensed psychiatric prescribing providers (physicians, physician assistants and nurse practitioners).

Special Bulletin #20 focuses on enhancing behavioral health services and avoiding interruptions in service that could lead to increased anxiety or exacerbation of symptoms. It permits billing starting on March 30, 2020, for dates of service on or after March 10, 2020.

The following protocol is established for community-based behavioral health services, including Intensive In-home Services, Multisystemic Therapy, Mobile Crisis Management, Assertive Community Treatment (ACT), Community Support Team (CST) and Peer Supports Services (PSS).

  • The beneficiary should be screened by phone or in-person from 6 feet away for symptoms of or exposure to COVID-19 in the past 14 days according to the CDC guidelines. If the screen is negative, an in-person visit is appropriate.
  • If the beneficiary screens positive, the appointment may proceed using HIPAA compliant two-way real–time interactive audio and video technology. If the technology available is not HIPAA compliant, the appointment can proceed as long as the beneficiary (or legal guardian) consents and the consent is documented. If video is not available, the appointment can proceed by telephone based on Special Bulletin #9, discussed above.
  • As with in-person visits, telemedicine visits must be clinically necessary.
  • Documentation of the visit must include the type of communication used and why, the duration of the communication, and informed consent by the beneficiary or legal guardian.
  • Telemedicine visits can be provided by any treating staff within their scope and with appropriate supervision.

Special Bulletin #21 focuses on outpatient specialized therapies and dental services. It permits billing starting on March 30, 2020, for dates of service on or after March 10, 2020.

Key Changes


  • Physical therapists, occupational therapists, speech-language therapists, and audiologists may provide certain evaluation and management services to new or established patients using two-way real-time interactive audio and video. Audio-only communications do not quality as teletherapy.
  • Therapists must consider a client’s behavioral, physical, and cognitive abilities to participate as well as the patient’s safety in determining whether to use teletherapy.
  • Therapy services provided via teletherapy must be consistent with licensing and other professional standards.
  • Prior authorization requirements still apply when using teletherapy, but teletherapy can be provided under existing prior authorizations.


  • The use of teledentistry services should be limited to triage or evaluation of beneficiaries with urgent or emergent oral health problems consistent with the American Dental Association, CDC, and CMS recommendations to postpone elective or routine care until further notice.
  • Only dentists can provide a service that will be reported as a teledentistry service.
  • The documentation of the teledentistry service must include the date, time, duration, and reasons for the teledentistry encounter as well as the technology used, diagnosis and treatment recommendations.
  • Prior approval limitations have been removed and are not required for any of the teledentistry services listed in the Special Bulletin.