Wild West of Waivers

Thank you for joining us for today’s legal/regulatory webinar related to the Covid-19 pandemic. This post contains links to the various resources that we discussed. Additional resources will be added after the event based on your questions

Disclosures
The webinar represents a partnership between Allina Health (David Frenz’s employer) and the Center for Practice Transformation. Please review Dr. Frenz’s disclosures, especially that bit about seeking counsel from experienced health lawyers like our panelists, Teresa Knoedler and Kit Friedemann


in partnership with

Questions to Ask Yourself

  1. Is the health care service permitted by law? (if yes, then go to #2)
  2. Is the health care service permitted by the patient’s health plan? (if yes, then go to #3)
  3. What is the claims submission process? For example, what CPT code and place of service code (Item Number 24B in the 1500 Health Insurance Claim Form) should be submitted for payment?


Introduction
High-level Explainer by Kit Friedemann, J.D.

Emergency Declarations
Federal
Minnesota
#StayHomeMN

HIPAA Enforcement
Office of Civil Rights resource page
Telehealth and Telemedicine Tool Kit

Medicare
Expansion of telehealth with 1135 waiver
CMS Interim Final Rule
MLN Booklet — Telehealth Services [requirements prior to Covid-19]
Medicare Coverage of Substance Abuse Services [prior to Covid-19]

Minnesota Department of Human Services
Waivers and modifications
MHCP Provider Manual

42 CFR Part 2
Substance Abuse and Mental Health Services Administration (SAMHSA)
Relationship to HIPAA enforcement discretion

Ryan Haight Act
Use of Telemedicine While Providing Medication Assisted Treatment (MAT)
Drug Enforcement Administration (DEA) Covid-19 Information Page

Author: doctorfrenz

I'm a physician specializing in addiction medicine