Medicaid Bulletin: Hurricane Dorian Emergency Response Provider Provisions
TO: All Providers
SUBJECT: Hurricane Dorian Emergency Response Provider Provisions
The purpose of this bulletin is to describe state and federal efforts to ensure continued access to care during the emergency response to Hurricane Dorian and the impact these efforts will have on Healthy Connections Medicaid beneficiaries and providers.
The South Carolina Department of Health and Human Services (SCDHHS) is committed to ensuring reimbursement for services rendered by qualified providers, in good faith, during this emergency response period. Accordingly, SCDHHS implemented several emergency response provisions, which include:
- Allowing beneficiaries to replace certain prescription drugs and medical equipment lost during the emergency in excess of customary limitations;
- Authorizing reimbursement for medical care from in-state, out-of-network providers; and,
- Relaxing prior authorization requirements for certain medically necessary and time-sensitive services.
In addition to these actions, on Sept. 2, 2019, the United States Secretary of Health and Human Services (USHHS), Alex Azar, declared a public health emergency for the state of South Carolina. This declaration under the Public Health Service Act and Social Security Act is retroactive to Aug. 31, 2019, and authorized the waiver of certain administrative requirements relevant to beneficiaries and providers participating in Medicare, Medicaid and the Children’s Health Insurance Program (CHIP). With this authority, SCDHHS is implementing the following additional flexibilities:
- Reimbursement for medically necessary and time-sensitive services rendered during the emergency response period by qualified providers currently not enrolled with or otherwise preapproved by SCDHHS.
- Reimbursement for services provided by individuals not certified or licensed in the state of South Carolina, if the rendering provider holds an equivalent license in another state and is not specifically prohibited from practicing in the state of South Carolina.
- Suspension of civil sanctions under 1877(g) of the Social Security Act, relating to prohibited physician referral, only to ensure the timely provision of necessary services during the emergency response.
Providers should note that their obligations under state and federal licensing and certification requirements not specifically addressed by the 1135 waiver authority remain unchanged. At this time South Carolina has activated limited Emergency Management Assistance Compact (EMAC) agreements with several states. Providers interested in assisting with medical care through an EMAC request should contact their state emergency management agency. All other out-of-state providers intending to provide
care in South Carolina during the emergency response period should contact the South Carolina Department of Labor, Licensing and Regulation (SC LLR) at www.llr.sc.gov or (803) 896-4300 for guidance on state reciprocity and emergency licensure.
Further, SCDHHS is not waiving determination and certification of medical necessity for services requiring such a determination, only their review and prior authorization.
SCDHHS intends to issue future detailed guidance regarding the process for enrollment and reimbursement of providers not currently participating in the South Carolina Medicaid program who render services to South Carolina Medicaid beneficiaries during the emergency response period. In addition to SCDHHS actions, providers should be aware that Secretary Azar’s 1135 waiver applies to the state of Georgia, including its Medicaid program. South Carolina providers rendering services for displaced Georgia Medicaid recipients should contact the Georgia Department of Community Health at: https://medicaid.georgia.gov/contact-georgia-medicaid. Providers with questions about this bulletin should call the Provider Service Center at (888) 289-0709.
Thank you for your continued support of the South Carolina Healthy Connections Medicaid program.
Joshua D. Baker