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UPDATED: Texas Health Steps Medical Checkups: Guidance for Remote Delivery During COVID-19

Date: 04/26/23

Effective with the end of the federal Public Health Emergency (PHE) on May 11, 2023, HHSC will end the temporary flexibility below.

Texas Health and Human Services (HHS) has provided updated guidance regarding Texas Health Steps (THSteps) medical checkups during the period of COVID-19 social distancing. During this time, HHS is allowing remote delivery of certain components of medical checkups for children over 24 months of age (starting after the “24 month” checkup). This guidance is effective from May 7, 2020 through the end of the PHE, on May 11, 2023.*

Texas Health Steps Medical Checkups

THSteps medical checkups require federally-mandated components, including:

  • Comprehensive health and developmental history, including physical and mental health and development.
  • Comprehensive unclothed physical examination.
  • Immunizations appropriate for age and health history.
  • Laboratory tests appropriate to age and risk, including lead toxicity screening.
  • Health education, including anticipatory guidance.

Because some of these requirements (like immunizations and physical exams) require an in-person visit, providers must follow-up with their patients to ensure completion of any components within six months of the telemedicine visit. Telemedicine or telephone-only delivery of THSteps checkups for children birth through 24 months of age (i.e. from the first newborn checkup through the “24 month” checkup) is not permitted.

Providers should use their clinical judgement as to what components of the checkup may be appropriate for telemedicine (audio + visual) or telephone only delivery. Audio + visual delivery is preferred over telephone-only. Physicians (MD and DO), nurse practitioners, physician assistants and registered nurses may perform remote delivery of these services. Non-physician provider supervision and delegation rules/regulations still apply.

Billing Codes for Texas Health Steps Medical Checkups

Providers should bill using the appropriate THSteps checkup codes for the initial visit as is currently required. Providers may also bill for “add-on” codes (e.g. developmental screening, mental health screening, etc.) as they normally would. Modifier 95 must be included on the claim form to indicate remote delivery. Providers will need to append the 95 modifier in the last position and ensure the THSteps modifiers continue to be primary to not cause claim issues.

Provider documentation should include the components that were not completed during the initial checkup, using COVID-19 as the reason for an incomplete checkup. When the patient is brought into the office within the 6-month timeframe to complete the outstanding components of the visit, providers should bill the THSteps follow-up visit code (99211). Reimbursement will be identical to current rates for THSteps checkup codes.

Providers must also document the reason a THSteps checkup was not able to be completed. Acceptable reasons for which the 6-month timeframe to complete the checkup might not be met include, but are not limited to, the following:

  • Child moves (from one service delivery area into another).
  • Child switches primary care providers.
  • Child changes product service lines (e.g. from STAR to STAR Kids).
  • Child switches Managed Care Organizations (MCOs).
  • Child moves out of state.
  • Child dies.
  • Child loses eligibility.
  • It is still not safe in six months to conduct an in-person visit.

Providers may also bill an acute care E/M code at the time of the initial telemedicine checkup or at the “6-month” follow-up visit. Modifier 25 must be submitted with the acute care E/M procedure code to signify the distinct service rendered. Providers must bill the acute care visit on a separate claim without benefit code EP1.

This guidance applies to both new and established patients and is applicable for members in both managed care and fee-for-service Medicaid.


3-Day Medical Exam

The 3-Day medical exam required by statute for children entering Department of Family and Protective Services (DFPS) conservatorship, telemedicine or telephone-only delivery will not be permitted, regardless of age, with one notable exception:

  • If a youth requires quarantine or isolation at the time of removal due to COVID-19 exposure or because the youth is known to be infected, remote delivery is allowed. Telemedicine, telehealth, or telephone-only will be allowed in this circumstance to avoid the risk of transmission in a health care setting, and audio + visual delivery is preferred, although telephone-only delivery will be permitted when audio + visual is not possible. Documentation should detail the circumstances which necessitated remote delivery. Providers should include modifier 95 when submitting a claim. Providers will need to append the 95 modifier in the last position and ensure the THSteps modifiers continue to be primary to not cause claim issues.


Additional Information and Resources

As a reminder, a patient’s home is not excluded as a THSteps site of service for medical checkups.

Providers are encouraged to explore different ways of ensuring children over two years of age receive age-appropriate vaccines in a timely manner. For recommended strategies, including curbside/drive-through immunization clinics, please visit the American Academy of Pediatrics (AAP) website.

Additionally, to help navigate telemedicine and telehealth reimbursement please reference Superior’s Telemedicine Quick Reference Chart (PDF).

For the latest updates on telehealth and telemedicine services during COVID-19 and Superior news, please reference the information posted on the Foster Care Texas Coronavirus Updates webpage, under Provider Billing Guidance for COVID-19 and Latest News sections.

*Please note: Previously, the end date for this guidance was April 30, 2020, then extended to May 31, June 30, July 31, October 23, November 30, December 30, 2020, January 31, February 28, March 31, April 30, May 31, June 30, July 31, August 31, September 30, 2021, December 31, 2021, January 31, April 30 and June 30, 2022. This notice is extended until the end of the PHE.