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• Will Optum hold Cerner training (online?) in order to onboard and allow billing and Cerner access for new staff hired?

  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 sdu_sdtraining@optum.com. 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 sdu_sdtraining@optum.com to discuss further.

• How can Cerner Community Behavioral Health (CCBH) be accessed from a personal computer?

  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.

  For immediate access due to COVID-19 please contact: Stephanie.hansen@sdcounty.ca.gov or Dolores.madrid@sdcounty.ca.gov

  Please CC: Annlouise.conlow@sdcounty.ca.govand Christopher.guevara@sdcounty.ca.gov

  (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.

• Has there been any thought from Agency Contract Support or the Department of Purchasing and Contracting to halt Request For Proposal postings?

  During the COVID-19 response, the County of San Diego’s departments and offices will continue to examine circumstances and make decisions based on the best information available.  However, there is currently direction to move forward with Request for Proposals (RFPs), as appropriate and feasible given the evolving circumstances. Any changes to timelines and due dates for active (RFPs) will be posted to the BuyNet system as soon as possible to allow for adjustments in planned responses. Existing contractors may be contacted by their Contracting Officer’s Representative (COR) to discuss options for extension, as permitted under the contracting authority, if delays are anticipated for reprocurement of existing services.

• When will we hear about the CMS waiver? With outpatient groups being suspended for SUD Services, what will be the County’s role and expectation related to disallowances and unit production? | When will the QM or QI meetings continue? As this is likely going to be our new present state and normal for some time, will there be efforts to engage on Zoom and other electronic formats to assure quality readiness?

  For latest updates on the 1135 Waiver Request, please visit the DHCS COVID-19 webpage. Relevant sections include Federal Requests & Waivers​​ and 1135 Waiver Guidance.

  BHS is suspending the Fiscal Year 2019-20 DMC-billable unit production plan requirement.  Please refer to the BHS Provider Communication 3-20-20 – COVID-19 Financial Practices and Contract Management Guidance.

  QM meetings in March and April 2020 are cancelled. We have the capability for virtual meetings in the future and will continue to evaluate to determine appropriate scheduling.

• If we have a site visit scheduled for April, should we expect it is canceled for now, or should we wait for confirmation on that from our COR? | May the April Quarterly Status Report (QSR) due date be postponed by a minimum of 10 days during this public health emergency? And could this be a consideration for other upcoming cyclical reports as indicated?

  Aligned with the COVID-19 Q&A Document released by Agency Contract Support to all HHSA Providers on 03/23/2020, monitoring activities that are not related to COVID‐19 are on hold until further notice.

  However, please follow the existing reporting requirements as described in the Organizational Providers Operations Handbook (OPOH) or the Substance Use Disorder Provider Operations Handbook (SUDPOH) for critical incidents, serious incidents (SIR), or similar types of situations.

• My program is scheduled to have a Medi-Cal Recertification, are these still being conducted on site?

  No. During the COVID-19 crisis the California Department of Health Care Services (DHCS) is waiving the requirement of an on-site review. County QM will submit any required documents to DHCS. All recertifications that were cancelled during this time will be rescheduled as soon as possible after the crisis is ended. 

• For my upcoming Med-Cal Recertification do I need to submit a fire clearance?

  No. During the COVID-19 crisis DHCS is waiving the requirement of a fire clearance for recertification. Upon conclusion of the COVID-19 crisis, a completed fire clearance will need to be submitted upon notification. 

• What is the status of SUD EHR?

  The Substance Use Disorder (SUD) Electronic Health Record (EHR) build remains a priority and BHS is currently continuing the project at this time.  We are looking at virtual options for training to support the future roll out.  At this time, the intent is to start clinical documentation potentially in October 2020 with the outpatient programs being trained first and then the residential programs. The timelines are subject to change, however.

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• 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?

  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.

• Will cost reimbursement contracts still be able to pay staff if the program closes or an individual staff member is quarantined?

  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.  

• Is the county putting a process in place to help contracted programs with COVID-19 related revenue loss?

  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.

• 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?

  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.

• What sort of guidance is available from Quality Improvement Unit on how to document and apply for COVID billing?

  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.

• 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.

• For BHS programs with flex funds, may flex funds for youth be utilized for COVID-19 related expenses that were not explicitly part of the approved budget? Examples of COVID-19 related flex fund expenditures include: laundry soap, laundry coins for laundromat, etc.

  Contractors should not use flex funding to cover these types of costs and should instead use the correct budget line to invoice these costs. Contractors may exceed budget line items for COVID-19 expenses related to the delivery of BHS services, but must stay within their maximum contract budget. The standard practice of requiring an administrative adjustment request (AAR) and budget adjustments are not required.   As mentioned previously, to ensure contractors are able to delineate expenses in support of BHS services that are related to COVID-19 from costs for normal operations, contractors should establish a COVID-19 cost center. Please see 3-20-20 – COVID-19 Financial Practices and Contract Management Guidance for further details.

• Is the County anticipating any delays in reimbursements to contractors?

  There are no anticipated delays in the process of reimbursing providers for services. The BHS financial team is prepared to process invoice payments as scheduled. They are working proactively to identify any challenges and appreciate your patience as adaptations to this new environment are made.​​

• For cost reimbursement contracts, has the County discussed the possibility of fully funding the contracts for their current allocations through a 1/12th monthly invoicing process consistent with the policy adopted by the County of San Francisco?

  The County of San Diego continues to monitor evolving federal and State guidance regarding funding developments, along with different approaches that other entities are taking, and will provide updates and guidance as more information is received and analyzed.

  At this time, contractors will be required to invoice the County for normal and COVID-19-related costs in support of BHS services through the normal invoicing process. Billable services must be tracked and invoiced through the normal cost centers and should include staff time utilized in providing billable services via alternate service delivery methods such as telehealth or others.

  To ensure contractors are able to delineate expenses in support of BHS services that are related to COVID-19 from costs for normal operations, contractors should establish a COVID-19 cost center to capture the following:

  A. Salaries and Benefits (S&B), including non-billable time for employees providing COVID-19 support, such as administrative activities, planning, coordination and response related to COVID-19.

  ​B. Services & Supplies (S&S), including personal protective equipment (PPE), hand sanitizer, cleaning products, additional cleaning services, laptops, headsets, monitors, and other services, supplies and equipment in support of maintaining continuity of operations for services.

  Contractors may adjust line items but must stay within their maximum contract budget. Administrative adjustment requests (AARs) and budget adjustments related to COVID-19 are not required.

  At this time, the County will not cover expenses typically deemed non-allowable, such as: staff incentives, including meals, gift cards, hazard pay and others directly for contractor staff.

  The County is also waiving Mental Health and Drug Medi-Cal (DMC) – Organized Delivery System (ODS) unit production requirements for March and April, cancelling COR site visits, and suspending  in-depth invoice reviews (IIRs) and Agency Contract Support (ACS) contractor audits until further notice if contractor interaction is required.

  Please refer to the 3-20-20 – COVID-19 Financial Practices and Contract Management Guidance communication for more information.​

• For fixed price contracts, will BHS consider providing cost reimbursement payments instead, due to this COVID-19 pandemic?

  No, a fixed price contract cannot be managed as a cost reimbursement contract without a contract amendment.  Funding streams and deliverables also impact the payment structure and therefore a conversation with the COR is recommended. 

• Will BHS support contractors to offer hazard pay to their employees? If so, would this be documented in the COVID cost center? Do programs need to have policies in place to reflect hazard pay as an option?

  The County Health and Human Services Agency’s Agency Contract Support communicated to HHSA Contractors on 04/03/20 that the current regulations (5 U.S.C. 5545 and 5 CFR Part 550) provides for hazard pay differentials only when the exposure is directly connected with the performance of assigned duties. Potential, or incidental exposure is not considered as a qualifier for federal hazard pay differentials. The County continues to monitor this situation as potential relief for front line workers is considered by the federal government and will communicate any regulatory updates. Contractors are additionally reminded to review their internal policies as they relate to compensation and employee benefits.

• Can you specify if telehealth and telephone visits should be under COVID-19? Individual and group visits are typical services, as usual. Does alternate methods of care qualify under COVID-19?

  No, telehealth and telephone visits should not be classified under the COVID-19 cost center.  Delivery of SOW specified services via alternative methods, such as telehealth, shall continue to be invoiced under the normal service lines and cost centers.  Please refer to 05-05-20 – COVID-19 Invoicing Reporting Guidelines and guidance for further details. Any Specialty Mental Health and Substance Use Disorder service provided by telehealth and telephone should be coded by service type, per usual practice.  Continue to document and enter all specialty mental health and substance use services provided, indicating the contact type as telehealth or telephone. Telehealth is not a distinct service, but an allowable mechanism to provide clinical services. The standard of care is the same whether the patient is seen in-person, by telephone, or through telehealth.

• Stories in the news say people are receiving bills for COVID-19 related expenses due to their private insurance changes not catching-up. Do you anticipate Medi-Cal recipients to be billed as well? And who do we reach out if this happens to solve the issue?

  Medically necessary COVID-19 testing, testing-related services, and treatment are free with Medi-Cal. When the visit is to get screened, tested, or treated for COVID-19, services are covered for emergency room, urgent care, and provider office visits. If a Medi-Cal beneficiary receives a bill related to COVID-19 expenses, please refer them to their Medi-Cal Managed Care Plan to resolve the billing issue. 

• If a Drug Medi-Cal Organized Delivery Services (DMC-ODS) residential treatment provider continues to provide treatment services through telehealth and/or telephone to a residential client who has been temporarily relocated to a hotel for a 14-day COVID-related isolation period, can the provider continue billing during that period for residential treatment (bed days) for the client? Can the program be reimbursed for room and board as they are holding the bed for the client 10-14 days?

  Yes, medically necessary residential treatment can be provided on a case-by-case basis, dependent upon clinical considerations, to a client who is located off site, if the client is enrolled in the residential program, and the medical director of the residential program is in agreement. The residential provider must be able to document a minimum of one hour of clinical service per day and either 10 hours or 20 hours of combined clinical services and structured activities per week according to the residential level of care (ASAM Level 3.1 or 3.5, respectively).

  Providers will be reimbursed up to 14 days for bed-holds when a client is sent to a hotel due to COVID-19.  

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• Where can clients be tested for COVID-19?

  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.

• What transportation options are available for patients we would like to direct to testing or healthcare but lack transportation?

  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.

• We received information today from a client that there was a positive covid-19 test roughly 2 weeks ago at his current employer. We urged the client to call his health care provided and he was given a COVID-19 test today. The documentation stated that he was in good health, with stable vitals and is not showing any symptoms. It also stated that he is currently low risk at this time. The discharge paperwork did not recommend self-quarantine but we are having the client self-isolate in his own room and will put him on medical discharge. He will not be attending any activities pending his test results which stated it would take 2-3 days, or maybe longer. We want to make sure we protect the community pending any test results.

  As noted in DHCS Information Notice 20-009 providers are encouraged to take all appropriate and necessary measures to ensure beneficiaries can access all medically necessary services while minimizing community spread. Discharge of clients from medically necessary treatment is not recommended, and providers are encouraged to make use of alternative methods of service delivery as clinically appropriate, including telehealth and telephonic service delivery. Providers are encouraged to screen clients with potential COVID-19 exposure for symptoms, and to call a medical provider if the client becomes symptomatic. Within residential programs, clients with known or suspected COVID-19 should be housed in the same room for the duration of their stay in the facility (e.g., minimize room transfers) to the extent possible. As a measure to limit staff exposure and conserve personal protective equipment such as masks, programs could consider designating entire units within the facility, with dedicated staff, to care for known or suspected COVID-19 patients.

• Are OTP/NTP clinics are able to perform PCR or antibody testing on new clients or those suspected of having COVID-19, and if so, is this a billable service?

  DHCS has posted a guidance document on COVID-19 Emergency Services, allowing for providers to perform COVID-19-related emergency services including testing and treatment services. Per the guidance document, COVID-19 testing and related medically necessary treatment services have been deemed to be emergency services to treat an emergency medical condition. Accordingly, all enrolled Medi-Cal beneficiaries, regardless of their scope of coverage under Medi-Cal or documentation status, are entitled to all inpatient and outpatient services necessary for the testing and treatment of COVID-19 as certified by the attending physician or other appropriate provider and in the same manner as administered under Section 51056 of Title 22 of the California Code of Regulations. Providers who will be performing COVID-19 testing will need to submit billing through their own billing systems, as with other health coverage.

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• Are clubhouses advised to shut down at this time per the County’s Public Health Order?

  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).

• In anticipation of staff shortages, can we combine clients from different levels of care in housing, group therapy, and dining areas?

  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.

• Can outpatient programs cancel group therapy?

  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.

• Can we cancel psychiatry appointments if client is stable and medication refills can suffice?

  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.

• What if a patient refuses to go for medical evaluation?

  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.

• Is a SUD provider allowed to consult with another provider without written consent?

  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.

• 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?

  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.

• 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?

  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.

• How is BHS prioritizing which services are essential vs. non-essential and what might non-essential service delivery look like?

  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.

• Will Smartphones and Wi-Fi access be provided for clients who don’t have access?

  Please communicate specific needs to your COR so any gaps in access can be identified and addressed. 

• 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?

  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. 

• 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.

  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.

• 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?

  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. 

• Will timelines and requirements for Utilization Management (UM)/Utilization Review (UR) and Outcome Measures be waived due to the COVID-19 crisis?

  The Adult/Older Adult UR Committee activities may be suspended, until further notice. Providers must continue to evaluate service needs and make updates to the Client Plan and overall care as indicated. The mandated outcome measures (IMR, RMQ, MORS, LOCUS) must continue to be administered at intake and discharge. Programs will need to ensure that outcome measures are administered when clinically indicated beyond the intake and discharge, with attention given to the requirement that outcome tools be administered at a minimum every six months. 

  The Children, Youth & Family 14-Session UM Model is suspended, until further notice. Organizational providers must continue to evaluate service needs and make updates to the Client Plan and overall care as indicated, under guidance of clinical supervision and team meetings. The State-mandated outcome measures (PSC and CANS) must continue to be administered at intake and discharge. However, with the temporary suspension of UM, the clinical team will need to ensure that outcome measures are administered when clinically indicated beyond the intake and discharge, with attention given to the State mandate which requires that outcome tools be administered at a minimum every six months. Please refer to the 4-1-20 – CYF Memo – UM Temporary Revision Due to COVID-19 for further details.​

• With many of our families not working, can outpatient program hours be changed to 8AM-5PM, as opposed to having evening program hours available?

  Please consult directly with your COR. At this time the County is not changing hours for programs overall, but will consider doing so on case by case basis. ​Furthermore, for guidance on operational continuity please see ​3-20-20 – COVID-19 Financial Practices and Contract Management Guidance. 

• In the current environment, it is challenging for residential treatment programs to provide the usual Patient Education groups, and there is a need to replace them with other structured activities. What activities can residential treatment providers count as “Structured Activities”?

  Structured activities are defined in the Quick Guide to Residential Services under the SUDPOH Toolbox tab as any facilitated activities by provider staff or providers outside of the program. Providers have discretion in determining structured activities that are appropriate during the current public health emergency, keeping in mind the 6ft distancing protocols. 

• Our client is currently staying in a different state or country during the public health emergency. Can we continue to provide services?

  Yes, telephone and telehealth are strongly encouraged, and DHCS does not restrict the location of services during this time (DHCS Information Notice 20-009).

• Are there currently any beds available for clients placed in recovery substance abuse disorder treatment programs who would otherwise be homeless? This is related to availability of the SD Regional Task Force on the Homeless coordinated beds, but also directly links to the following question: is there a mandate for clients that are already in detoxification centers or long term treatment extending the time that clients can stay?

  The capacity for residential treatment beds under the current COVID-19 climate has been reduced to incorporate CDC physical distancing in congregate settings, but there is capacity available for clients that meet ASAM criteria for this level of care.  Clients can receive withdrawal management (WM) services as long as it is clinically indicated. Homeless clients can be subsequently linked to a residential program if ASAM criteria for residential treatment are met. If a client no longer needs a residential level of care, they can be linked to an intensive outpatient or outpatient program for continued treatment and Recovery Residence access. 

• Are outpatient programs still taking intakes and providing sober living beds?

  Yes, substance use disorder outpatient programs are open for intake. If a client is eligible for a Recovery Residence (RR), the program will work towards  connecting a  client to a RR as part of their treatment.  

• In our pay-for-performance contracts where clients have to attend in person in order to meet contractual obligations, what guidance can you provide during this time?

  Please refer to the County’s Department of Purchasing and Contracting letter to contractors dated March 18, 2020. BHS contractors must continue to perform in accordance with their contract’s terms and conditions, including remaining operational to ensure essential services continue. Contractors encountering issues with maintaining continuity of operations should contact their COR immediately. Additionally, contractors are encouraged to discuss options for telehealth as some programs and services may have interim waivers for in-person delivery.  Contractors must also continue to enter client data into the appropriate data systems, including CCBH and SanWITS, whenever applicable.

• If programs have difficulties attaining critical supplies, including food and toiletries, what can programs do to ensure inpatient programs, crisis homes, residential treatment programs (RTPs), will have sufficient food and toiletries (e.g., shampoo, toothpaste, deodorant) for their clients?

  To ensure food and toiletries remain sufficient for clients, Contractors may adjust line items in their budget but must stay within their maximum contract budget. Please refer to BHS Provider Communication 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices which serves as budget approval and as such administrative adjustment requests (AARs) and budget adjustments are not required.

• How can providers ensure their patients do not run out of medications?

  Medi-Cal allows patients to fill up to 100 days of non-controlled medications. Narcotic treatment programs can receive exemptions to provide take-home medications for patients who are sick or quarantined. Patients receiving buprenorphine products can currently receive 30-day supplies on Medi-Cal.

  Utilization limits on quantity, frequency, and duration of medications may be waived by means of an approved Treatment Authorization Request (TAR) if there is a documented medical necessity to do so. See DHCS pharmacy guidance.

  Some medications are anticipated to be in short supply due to supply-chain challenges. The FDA keeps a list of medications in short supply, including some medications for behavioral health conditions. Providers can prescribe 100-day supplies of all chronic medications, and patients may obtain early refills if 75% of the estimated duration of the supply dispensed has elapsed (other than certain medications with quantity/frequency limitations). Pharmacies are required to supply up to 72 hours of prescribed medications in an emergency and may provide the emergency supply without an approved TAR.

  Medi-Cal allows for, and reimburses, mail order pharmacy providers enrolled as pharmacy providers in the Medi-Cal program.

• At a recent Behavioral Health Services (BHS) All Provider Meeting via tele-town hall call, it was emphasized that recording services was very important during the pandemic. Can you give more information to clarify what was meant by this?

  “Recording services” in this context means documenting the provision of service. During the COVID-19 public health emergency, it is essential that providers document all services provided to clients. Providers also should clearly document any alterations in the usual approach to service delivery (for example, providing counseling groups by telehealth), as well as the reasons why required signatures may be late or missing from the client record during this time.

• If a client has not received any billable services in 30 days, we should discharge them from the program. Given the COVID-19 pandemic, we are struggling to reach our clients to provide services to them for several reasons, including, but not limited to, their not having a working phone, an appropriate place for sessions, or the desire to engage with providers at this time. Are we still expected to discharge clients if we cannot contact them and provide services beyond 30 days?

  Effective May 20, 2020, DMC-ODS providers are required to discharge clients when there is a lapse in treatment for more than 30 days, although clients can be readmitted as medically necessary. Clients should be reassessed for readmission when ready to resume treatment. If a client is subsequently reengaged in the program, please treat this as a readmission with all relevant documentation requirements. Please note that the two non-continuous residential stay limit still applies in DMC-ODS.

• Are clubhouses still open and providing services?

  ​Clubhouses are open and accepting new members. Programs may refer clients to a clubhouse by contacting the clubhouse by phone during regular operating hours.

• Will congregative care facilities for children, STRTPs, be considered for that second tier of priority for testing for new admissions and readmissions?  What will be the role of CWS in this process for CWS youth?

  Short-Term Residential Therapeutic Program (STRTP) providers should connect with the placing agency with questions related to testing of foster youth in congregate care settings.  

• I understand that crisis centers are keeping clients longer because of the COVID-19, however, we have one that is being asked to move out because time is up and that she does not meet criteria for an extension. Is that being encouraged?

  At this time authorization requirements for organizational providers have not been waived by the California Department of Health Care Services (DHCS) and are still required for certain mental health services, such as those provided by crisis residential programs.

• Is there an anticipated end-date to the Substance Abuse and Mental Health Services Administration (SAMSHA) / State Opioid Treatment Authority (SOTA) / Center for Substance Abuse Treatment (CSAT) / Drug Enforcement Agency (DEA) "blanket CSAT exception" for patient take-home medications due to COVID-19? We are renewing our blanket CSAT now to extend 90-days after expiration on 6/19/2020.

  According to the SOTA representative on 5/14/20, all blanket exceptions are still effective. The State will reach out to notify programs when they are no longer valid.

  An approved CSAT exception submitted through the CSAT Extranet is valid for the timeframe stated in the CSAT Extranet. This expiration date may vary as Opioid Treatment Providers (OTPs) request different timeframes.

  If the OTP submitted a letter of need in writing to the California Department of Health Care Services (DHCS) for a blanket exception, the blanket exception approval is still valid and in effect.  DHCS will provide guidance when these blanket exceptions are no longer valid. 

  An OTP that submitted their request via the CSAT Extranet and has an “expiration” date may submit a letter of need in writing to DHCS to obtain a written blanket exception approval.  For more information see COVID-19 NTP FAQ.

• How long should Mental Health (MH) programs keep clients open if they have still not been in contact with the family/the family has not returned calls/letters/emails since March when schools closed?

  All providers should have policies in place regarding missed appointments and types of contact to be used to re-engage clients, specific to the risk levels of clients served. Please follow the program's policies and procedures, and document rationale for decisions and contact attempts. 

  For Substance Use Disorder programs, specifically, there are still requirements in place to discharge any individual if they have had no contact for 30 days.

  Additional information can be found in the Organizational Provider Operations Handbook (OPOH) and Substance Use Disorder Provider Operations Handbook (SUDPOH). 

• How do I manage signature requirements during the emergency?

  If a signature cannot be obtained, for any reason, the reason for the missing signature should be documented in the client record.

  When the public health emergency ends, you are not required to “make up” missing or late signatures and will not ask for collection of signatures for clients starting and/or ending treatment during the emergency. However, the requirement for signatures would resume, and signatures would need to be obtained when they are due, on a “go-forward” basis. Signatures should not be backdated.

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• What are staffing and pay expectations during the crisis?

  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.

• Can a SUD Residential program upload a chart and send to our staff who is working from home?

  Legal Entities should continue to use a secure network when uploading personal health information. 

• Are providers to use a secured network to upload files to communicate with Quality Assurance contacts on the County side if working remotely?

  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. 

• Is the requirement that Substance Use Disorder (SUD) treatment programs maintain a minimum of 30% licensed staff waived during the COVID-19 public health emergency?

  Regulations require licensed and certified SUD programs to ensure that their counseling staff are appropriately registered and/or certified at all times by an approved certifying organization, or appropriately professionally licensed. During the current public health emergency, SUD programs must continue to meet the regulatory requirement that 30% of the staff providing SUD counseling are certified or professionally licensed.

• As a Board of Behavioral Sciences (BBS) Licensee if my license is set for renewal, what is the process during COVID-19? Will I be required to complete Continuing Education Units (CEUs) for licensure at a future time?

  Those licensees that are set to renew between March 31, 2020 and June 30, 2020 will not need to complete CEUs in order to obtain renewal. Log in to online Breeze (https://www.bbs.ca.gov/) and complete the renewal process.

  If your renewal falls during the waiver period (March 31, 2020 – June 30, 2020) you will be required to complete your 36 hours within six months (by September 30, 2020), unless the order is extended.

• As a Board of Behavioral Sciences (BBS) Registrant (associate marriage and family therapist, associate clinical social worker, and associate professional clinical counselor) if my registration expires, what is the process during COVID-19?

  Those registrants that are set to renew between March 31, 2020 and June 30, 2020 will not need to complete the required Law and Ethics Course in order to renew. You will have six months (by September 30, 2020) to complete the course.

• If I am required to take Continuing Education Units (CEUs) as part of a disciplinary action, does this waiver apply to me?

  No. You are still required to complete the CEUs by the due date.

• If I have a staff member that would like to restore a retired, inactive or cancelled license in order to help with the current State of Emergency, do they need to complete the required CEUs?

  The individual may do so without completing the normally required CEUs and fees, if it has been inactive for 5 years or less. This license will be valid for six months or when the current state of emergency ends, whichever is sooner. Visit the following link to restore a license: https://covid-19.dca.ca.gov/backtoactive

• If a registered Alcohol and/or Other Drug (AOD) Counselor working for our program is unable to obtain an AOD Counselor certification during the period of the COVID-19 public health emergency and it has been more than 5 years since the date of the Counselor’s AOD registration, do we need to remove that Counselor from providing services to clients or document the services provided by the Counselor as non-billable?

  The requirement to complete the process of AOD certification within five years has been suspended for the duration of the declared public health emergency. Substance Use Disorder (SUD) Counselors who have begun but not completed the AOD certification process with a certifying organization recognized by the California Department of Health Care Services (DHCS) can continue to provide billable services within the scope of practice for a SUD Counselor during the public health emergency.

• How do we get the Optum training for CCBH/Cerner for a new intern?

  Classroom based CCBH and SanWITS trainings have been suspended until further notice. A self-paced, virtual model consisting of resource packets, plus practice exercises, is available currently.  Additionally, a live one-hour video webinar has recently been implemented to provide an orientation to the self-paced training process. An American Sign Language interpreter would be needed during the live webinar and these sessions will not be recorded. Please contact sdu_sdtraining@optum.com for training information.  BHS is working to create video-based trainings in the future that would include closed captioning, but the timeline for availability is still to be determined. 

• Can a flat rate payment (prorated for part time staff) be issued to reimburse a portion of the costs for of home internet charges, upgrades needed for video conferencing, cell phone costs, electricity, and use of personal equipment and supplies for staff who are now working from home?

  There is no additional compensation provided to staff who are teleworking. 

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• What is the difference between Telehealth and Telephonic services?

  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.

• Do providers have approval to shift away from face-to-face services and utilize telephonic and telehealth services?

  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.

• Can Opioid Treatment Program (OTP) providers provide telehealth services?

  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. However, 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 or telephone, without an in-person medical evaluation. Telehealth service documentation and the patient’s verbal or written consent for the telehealth visit should be documented in the patient record.

  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. 

• Can we utilize telepsychiatry for prescribers who are unable to come into the office?

  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.

• Can Assertive Community Treatment (ACT) staff conduct services telephonically for clients who are not in psychiatric distress?

  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.

• Can we cancel groups to ensure social distancing guidelines are adhered to?

  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.

• Can ACT morning meetings be conducted via telephone or video?

  Yes, teleworking is acceptable for ACT morning meetings. Please refer to 3-19-20 – COVID-19 Quality Improvement Updates and Best Practices.

• Can screenings be conducted by phone?

  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. 

• Do Substance Use Disorder (SUD) providers need written client consent to provide services by telehealth or by telephone?

  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. 

• Can SUD providers utilize telehealth from a non-DMC certified site?

  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.

• Can clients choose individual treatment in lieu of group therapy?

  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 guidance for behavioral health programs regarding ensuring access to health and safety during the COVID-19 public emergency and 3-23-2020 – Guidance for County Contractors Regarding Telehealth.

• 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?

  The provider should document that the clients were informed of the potential risk of unintended disclosure when providing services via telehealth and agreed to participate. 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, but is not required to, document “[name of client], consent given in lieu of signature” followed by the date and the initials of the Counselor or LPHA who provided the group counseling service. 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”.

• 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.?

   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.

• Can SUD providers use services such as Telemed Drug Testing Solution?

  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.  

• Should we be screening clients over the phone if they have traveled within the month?

  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.

• With regards to Narcotics Treatment Programs, or Medication Assisted Treatment, for telephone and video services, what is the protocol and guidance for staff providing services at home? Does the counselor need to demonstrate that they have an area in their home to provide telephone and/or video services in privacy?

  Providers are required to follow relevant privacy procedures, document verbal consent when written consent is unattainable and work to follow guidelines to the best of their abilities.​ During this time there are greater flexibilities but providers should use locations where they can provide the greatest privacy protection possible. Please refer to 3-26-20 – QM Memo – Telehealth Resources during the COVID-19 Public Health Emergency for supplemental information. 

• In a residential facility, it can be impossible to fit the clients in a group counseling session in the same room while maintaining physical distancing. Can groups be conducted through telehealth for clients that are in residential treatment?

  Yes, use of telehealth services is encouraged during the current public health emergency to provide clients with medically necessary services while also minimizing potential exposure of clients and program staff to COVID-19. Any alterations in how services are provided related to COVID-19 precautions, including use of telehealth for counseling groups in the residential program, should be clearly documented in the progress notes in the client records.

• A component of QAR reviews and file compliance is to ensure that the Medical Director (MD) is reviewing files within 30 days of admit, and this is also a component of our contract. Are we still required to meet with our MD regularly so that he can review files? Or is it okay if we suspend that for now since our offices are currently closed and we have limited office access?

  The requirement for the physician in an outpatient program to review each beneficiary’s personal, medical, and substance use history within thirty (30) calendar days of admission is a Title 22 mandate. As such, the requirement cannot be suspended. However, the physician review may be conducted through examination of records (sent by secure email or other secure means), or by telephone or telehealth. The methodology used to conduct the physician review of the client’s personal, medical, and substance use history should be documented in the client’s record.  

• May telehealth and telephone be used to place and release involuntary holds on individuals (5150 evaluations and 5151 assessments) and are those services billable to Medi-Cal?

  WIC 5150 evaluations may be performed by authorized providers via telehealth as per WIC 5008(a). This may include releases from involuntary evaluation and treatment, as appropriate.  These services are billable to Medi-Cal regardless of whether they are provided in person or through telehealth as long as the individual has Medi-Cal coverage for the service and all Medi-Cal requirements are met. Assessments required by WIC 5151 are to be completed “in person” and, as such, shall not be provided using telehealth.

• I am still concerned about the dormitory setting. Is three feet enough social distancing space in the dorms? What if 32 beds in each dorm exist, when there is only to be small groups of 10 or less gathering?

  Please continue to review and follow CDC guidance. Additionally, our local Public Health Department has recommended further guidance that beds in sleeping areas for those not experiencing symptoms are at least 6 feet apart.  They also suggest that clients sleep head-to-toe. Since bunk beds typically cannot meet 6 ft vertical spacing, programs may wish to consider one client per bunk bed.

• Could the County clarify the bed space guidance at residential facilities, specifically around the use of bunk beds? Will a program be penalized for less bed days due to this guidance?

  Please continue to review and follow Center for Disease Control (CDC) guidance. Additionally, our local Public Health Department has recommended further guidance that beds in sleeping areas for those not experiencing symptoms are at least 6 feet apart.  They also suggest that clients sleep head-to-toe. Since bunk beds typically cannot meet 6 foot vertical spacing, programs may wish to consider one client per bunk bed.

  Programs should discuss the reduction in number of beds with their COR.

• What are the expectations for documentation of SUD services delivered by telephone or telehealth?

  SUD Providers should continue following current documentation requirements as outlined in the Substance Use Disorder Provider Operations Handbook (SUDPOH) on the Optum website. When providing services through telehealth or telephone, the provider also should document that clients were informed of the potential risk of unintended disclosure when providing services via telehealth.

• For a DMC-ODS program, can the required face-to-face consultation between the SUD Counselor and the Licensed Practitioner of the Healing Arts (LPHA) on the American Society of Addiction Medicine (ASAM) Level of Care (LOC) Recommendation assessment be conducted by telehealth or telephone?

  Yes, effective March 1, 2020 and for the duration of the COVID-19 public health emergency, the consultation between the certified SUD Counselor and LPHA/Medical Director on the ASAM LOC Recommendation assessment can be conducted by telehealth, telephone, or in person. It should be clearly documented in the client record if the consultation took place by telehealth or telephone rather than in person. For additional information on provision of telehealth and telephonic services, please see 3-23-2020 – Guidance for County Contractors Regarding Telehealth.

• 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?

  The provider should document that the clients were informed of the potential risk of unintended disclosure when providing services via telehealth and agreed to participate. 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, but is not required to, document “[name of client], consent given in lieu of signature” followed by the date and the initials of the Counselor or LPHA who provided the group counseling service. 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”.

• Are there any updated video telehealth platform recommendations based on what has been learned lately of security and hacking of video calls?

  Please refer to 3-26-20 – QM Memo – Telehealth Resources during the COVID-19 Public Health Emergency​​. If there are platforms that allow for passwords to increase technical safeguards, providers are encouraged to consider.  Please note that public facing applications such as Facebook Live, Twitch, TikTok, and similar video communication applicat​ions should not be used in the provision of telehealth. 

• Are verbal signatures and consents approved for outpatient children's mental health programs intake documents, consents, client plans, etc.?

  ​Yes, providers are directed to obtain verbal consent with detailed documentation when they are not able to obtain wet or electronic signatures. Additional information is available in 3-23-20 – Guidance for County Staff and Contractors Regarding Telehealth.

• How can we protect the confidentiality of our clients participating through telehealth in SUD treatment groups?

  While using alternate methods such as telehealth to deliver medically necessary services is encouraged during the current COVID-19 public health emergency, there are unique risks inherent in the use of telehealth technology, including the risk of inadvertent disclosure of confidential information. Prior to engaging in a telehealth treatment session, clients should be informed by the provider of this risk and of the efforts made by the provider to minimize the risk, such as using a non-public-facing telehealth platform. Whenever possible according to the telehealth product’s available features, the provider should manually turn off the participants’ ability to record sessions. Providers are advised to caution all clients participating in group counseling sessions conducted by telehealth that they are prohibited from allowing other people who are not enrolled in the group to watch or listen to the session and also are prohibited from recording or capturing still shots of the session. The provider also should inform the clients of the consequences for violating this expectation, which should be in line with violation of the program’s general rules around maintaining confidentiality. The provider is advised that breaches of privacy must be reported to the COR who will provide direction on next steps including reporting to the HHSA Compliance Office. ​

• Related to Mental Health - Can we have clarification to clinicians providing services when clients are residing in Mexico during stay at home order? The CMS waiver stated licensed providers, but does that include associates?

  DHCS does not restrict the location of services via telehealth.  An intern, trainee, or waivered licensed professional under the supervision of a Licensed Professional of the Healing Arts (LPHA) may perform specialty mental health assessments and subsequent services by telephone, telehealth, or in-person, under supervision of a licensed professional.

• What is the best way for a LPHA to complete the Continued Stay Review when we are working remotely and do not have access to client files to review prior to approval?

  The requirements for a continued stay review in an SUD outpatient treatment program continue to include determination that continued services are medically necessary and that all of the following have been considered: the client’s personal, medical, and substance use history; documentation of the client’s most recent physical examination; the client’s progress notes and treatment plan goals; the Licensed Professional of the Healing Arts (LPHA) or counselor’s recommendation; and the client’s prognosis. It is understood that for safety during the COVID-19 public health emergency, many staff members are teleworking. It is acceptable for the LPHA to receive information telephonically, by telehealth, or by secure email (according to the legal entity’s policies and procedures) from an on-site staff member to complete the review. Providers are advised to take the necessary precautions within the outpatient clinic to allow a staff member to safely enter the clinic as necessary to access clinical records.

• If providing a new medication or making a change to medications on the Medication Consent Form, how do I document client’s signature?

  Programs can allow for verbal consent (in lieu of written consent) for the consent form. This should be documented in a progress note.

• Can we send documents such as grievance acknowledgement letters and responses, Notices of Adverse Benefit Determination (NOABD) to the beneficiary via email?

  Yes, as long as the beneficiary consents to receive via email and this has been documented by the MH or SUD treatment provider. As a reminder, NOABD information provided to the beneficiary must be consistent with federal requirements on content, language, and format. For details on the NOABD forms developed by DHCS, please visit the Optum site.