RCPA attended the Office of Mental Health and Substance Abuse Services (OMHSAS) telehealth webinar on Monday, January 29, alongside many provider members, regarding the Federal payment conditions related to the delivery of telehealth services and the requirement that the physicians or clinicians must present in the office, or that the client must be in the office during the telehealth session, to meet the guideline. It was explained that despite the standards outlined in the current OMHSAS Telebehavioral Health Bulletin, under the Federal “4 walls” statute, this is a required Federal Medicaid payment condition. These requirements cannot be waived.

The purpose of today’s call was twofold: explaining the “4 walls” requirements, and for providers to give vital feedback to OMHSAS on the impacts, challenges, and barriers to accessing services that this may create for consumers and families. This Medicaid standard remains in effect, and RCPA recommends provider members review their operating practices to ensure compliance.

During this time, RCPA will continue its efforts and work with OMHSAS, the HealthChoices partners, and stakeholders to ensure access to services via telehealth. You can review today’s OMHSAS telehealth webinar slide deck. We are also looking to obtain a recording of the webinar to share with our members.

If you have questions, please contact RCPA Policy Director Jim Sharp. The next RCPA Telehealth Operations Committee meeting is scheduled for Tuesday, February 27; however, we will be reviewing if we need to meet sooner based on current information.

Please share this information with your stakeholder networks.