Provider COVID Update

Service Authorization Requests
In an effort to best serve our members, Alliance continues to explore ways to support our provider network by removing as many barriers as possible that could potentially interfere with the critical task of maintaining service capacity during this time of national crisis. To this end, effective Monday, March 23, 2020, for the next 30 days, Alliance will be waiving requirement for concurrent authorization of both Medicaid and state-funded enhanced community-based services as well as several of the Medicaid B-3 services. A list of services that will be exempt from concurrent review during the 30 day period can be found below. Concurrent authorization is defined as having an active service authorization for the same service with your agency at the time of this announcement. Although the authorization requirement is being waived for a 30 day period, members still must meet medical necessity/continued stay criteria to receive services. Prior authorization remains required for individuals new to enhanced and B-3 services.

Services Covered Under 30-day Concurrent Review Waiver:

  • Assertive Community Treatment Team (ACT): H0040
  • Assertive Community Treatment Team Step-Down: H0040TS
  • Community Support Team: H2015HT
  • Peer Support: H0038 (individual)
  • Individual Supports B3: T1019 U4
  • Supported Employment Individual Mental Health: H2023U4 HE
  • Opioid Treatment: H0020
  • Intensive In-Home: H2022
  • Supported Employment Individual (I/DD): H2023 U4
  • Intercept: H0036 U3 HK
  • Family-Centered Treatment (FCT): H2022 U3 HE
  • Multisystemic Therapy (MST): H2033 HE
  • Outpatient Therapy Plus (OPT Plus – child only): 90837 U3 HE
  • Respite – B3: H0045 U4 (Individual)
  • Community Guide (B3): T2041 U4

Special Instructions for B3DI
Guidance regarding B3DI Innovations Deinstitutionalization (B3), Innovations and Traumatic Brain Injury services will follow the temporary policy modifications as outline in Appendix K.

Member and Legally Responsible Person Signatures
At this time in recognition of the realities of current pandemic situation and based on guidance from the N.C. Department of Health and Human Services (DHHS) and the U.S. HHS Office for Civil Rights, to decrease unnecessary face to face contact, promote the use of virtual care where possible and address challenges related to obtaining member signature on person center plans, treatment plans and consent to treat forms Alliance is implementing the following:

  • Alliance will accept a qualified professional/para-professional or clinician signature in place of the member or legally responsible person’s (LRP) signature, along with a notation that the member/LRP gave consent for the provider representative to sign the document on his or her behalf.
  • Providers should document whether such consent was made via telephonic, email or other means. Any provider relying upon email consent should follow up via telephone communication with the member/LRP to secure verbal consent if possible. Providers should track consent received in this manner so they can implement a plan to obtain signatures of the member or LRP at a later time.
  • To verify you are speaking with the member/LRP, best practice is to ask for another identifier (besides name and date of birth), such as Social Security number or Medicaid number. Always obtain express consent for disclosure of any substance use information. Member/LRP consent or approval should be clearly documented in the service note.

Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency
Below is a summary of a notification released by the Office of Civil Rights at the US Department of Health and Human Services. You can access the full notification.

During the COVID-19 national emergency, which also constitutes a nationwide public health emergency, covered health care providers subject to the HIPAA Rules may seek to communicate with patients and provide telehealth services through remote communications technologies. Some of these technologies and the manner in which they are used by HIPAA covered health care providers, may not fully comply with the requirements of the HIPAA Rules.

The Office of Civil Rights (OCR) will exercise its enforcement discretion and will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules against covered health care providers in connection with the good faith provision of telehealth during the COVID-19 nationwide public health emergency. This notification is effective immediately.

OCR is exercising its enforcement discretion to not impose penalties for noncompliance with the HIPAA Rules in connection with the good faith provision of telehealth using such non-public facing audio or video communication products during the COVID-19 nationwide public health emergency. This exercise of discretion applies to telehealth provided for any reason, regardless of whether the telehealth service is related to the diagnosis and treatment of health conditions related to COVID-19.

Under this Notice, covered health care providers may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype, to provide telehealth without the risk that OCR might seek to impose a penalty for noncompliance with the HIPAA Rules related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency. Providers are encouraged to notify patients that these third-party applications potentially introduce privacy risks, and providers should enable all available encryption and privacy modes when using such applications.

Under this Notice, however, Facebook Live, Twitch, TikTok, and similar video communication applications are public-facing, and should not be used in the provision of telehealth by covered health care providers.

Covered health care providers that seek additional privacy protections for telehealth while using video communication products should provide such services through technology vendors that are HIPAA compliant and will enter into HIPAA business associate agreements (BAAs) in connection with the provision of their video communication products. The list below includes some vendors that represent that they provide HIPAA-compliant video communication products and that they will enter into a HIPAA BAA.

  • Skype for Business / Microsoft Teams
  • Updox
  • VSee
  • Zoom for Healthcare
  • Google G Suite Hangouts Meet

State Initiatives
As mentioned in previous updates the state is moving quickly to provide increased flexibility afforded to the LME/MCO system and providers to ensure both ongoing access to behavioral health services and the health and sustainability of the behavioral health care delivery system. A letter to the LME/MCO CEOs outlines both immediate steps and planned initiatives to achieve the above-stated goals. Alliance has already begun to exercise some of this newly afforded flexibility and will work rapidly with our provider network partners using available funding and flexibility to address barriers that impact the ability to deliver care during this very challenging time.

You can access a comprehensive listing of rule waivers to Appendix K that the State has submitted to CMS which are necessary to support members and providers under the Innovations and TBI waiver, including members receiving B3DI funding.

Useful Information
Access a CCNC summary of the NC Medicaid Outpatient Pharmacy Program’s flexibilities implemented to the Outpatient Pharmacy Policy as of March 13, 2020 in order to support recommendations for social distancing to prevent COVID-19 spread and to facilitate access to needed medications.

Please note: Gurley’s pharmacy will waive the $3.00 copay for Durham residents receiving state and county funded behavioral health services.

Please direct any questions or concerns to [email protected].

Alliance Health highly recommends that you monitor Provider News and our website daily at for any updates regarding provider services.  Alliance will update this information as we receive any updates from the State in regards to COVID-19.

Please continue to check our COVID-19 resources for providers. Alliance will continue to update this page with resources.

In the event that COVID -19 seriously impacts your ability to provide services to our members, please notify Alliance immediately by submitting the Temporary Disruption of Service Delivery form found on our website

Page last modified: March 22, 2020