Emergency Rules Filed

The Ohio Department of Mental Health and Addiction Services (MHAS) and The Ohio Department of Medicaid (ODM) have filed emergency rules expanding services and relaxing restrictions for the provision of services through telehealth, including telephone only services effective 3/9/2020.

For MHAS certified organizations, all eligible providers of community behavioral health services are eligible to provide services via telehealth, which now includes the use of non-secure methods and telephone (audio only).  Below is our recommendation on how to understand the emergency filed rule structure: 

How to interpret the emergency filed rules:   

  1. First, read the emergency filed MHAS rule OAC 5122-29-31 expanding the definition and scope of interactive videoconferencing in its entirety.   
  2. Then, read ODM Rule OAC 5160-1-21 (C)(5), which states, "Entities who provide services certified by the Ohio Department of Mental Health and Addiction Services (OhioMHAS) are subject only to paragraph (C) of this rule. Requirements for these entities are covered in Chapter 5160-27 of the Administrative Code with the following modifications and suspensions."  
  3. Next, read the rest of ODM Rule OAC 5160-1-21 (C).  
  4. Then, for more detailed explanation, please read the: March 20, 2020 BH MITS Bits on Emergency Rules Expand Access to Telehealth Services and the ODM FAQ.
  5. Review the ODM Telehealth billing codes for provider type 84s and 95s available HERE.

For questions related to changes to OhioMHAS interactive videoconferencing policy as well as questions related to clinical and technical implementation of telehealth, please email [email protected].

Questions about the Medicaid coverage, billing, and reimbursement under the new policy can be submitted to [email protected].


Billing:  It is very important for providers to continue to use the existing billing guidance. Providers should NOT add the GT modifier to services that are being added as new telehealth services under the emergency rules or use POS 02 for Medicaid claims.  Providers do need to use the GT modifier for the services that already require it for telehealth/interactive video conferencing.

ODM is working with the MCOs to create a single, unified approach for billing and coding changes - that will be tested - and a timeline for those changes will be announced.  Further, providers will NOT be required to resubmit these claims in the future once IT systems are updated to capture telehealth as the "method" of service delivery.