Knoxville Area Psychological Association

Tennessee Emergency Orders for Licensed Psychologists During the COVID-19 Crisis.

April 25, 2020 2:30 PM | D. Malcolm Spica (Administrator)

State emergency orders relevant to licensed psychologists during the COVID-19 public health crisis (From

Existing state telehealth coverage mandate?
YES for commercial health plans and Medicaid managed care plans; includes reimbursement parity: 
Tenn. Code Ann. §56-7-1002

Emergency state action on coverage of telehealth services?
Executive Order No. 20-20 dated 3/26/20 temporarily waives Tenn. Code Ann. § 63-1-155(a)(1) allowing any TN licensed health care provide to deliver services using telehealth.

Executive Order No. 20-15 dated 3/19/20 encourages insurers to cover telehealth services irrespective of a provider’s network status. See Section 38.

Emergency state action on telehealth reimbursement parity?
CMS Section 1135 Medicaid Waiver approved 3/31/20 allows for reimbursement of payable claims by out of state licensed providers not enrolled in the state Medicaid program subject to certain conditions for the duration of the public health emergency.**

Emergency state action to include audio-only phone?
Executive Order No. 20-15 dated 3/19/20 encourages providers to follow recent CMS guidance regarding the use of equipment and everyday communications technologies that may be used for the provision of telemedicine services. See Section 38.

TennCare Provider Memo dated 3/25/20 temporarily allows for audio-only phones to deliver behavioral health care services during the public health emergency.

Emergency changes in originating sites requirements?
Executive Order No. 20-15 dated 3/19/20 encourages insurers to cover telehealth services irrespective of originating site. See Section 38.

Emergency licensure waiver?
Executive Order No. 20-15 dated 3/19/20 temporarily waiving licensing requirements for out-of-state licensed health care professionals to provide telehealth services. See subsection 38.

Executive Order No. 20-24 dated 4/3/20 temporarily allows unlicensed individuals with mental health training (at masters or doctoral level) individuals to provide telemental health services under the supervision of a licensed psychologist or other licensed mental health provider.

This temporary practice authorization is valid through 5/18/20.

There is an online application for non-licensed behavioral health provider.

Supervised Trainee Telehealth Services – Telesupervision and Medicaid Reimbursement
Trainees are not eligible to perform telehealth services under Medicaid as they are not licensed (and Tennessee’s section 1135 waiver requires all providers to be licensed).

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