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CT DPH Issues Orders Suspending Licensure Requirements for Certain Providers

May 19, 2020

On May 15, 2020, the Connecticut Department of Public Health (“DPH”) Acting Commissioner Deidre Gifford issued two orders permitting the temporary suspension of the requirements for licensure, certification, or registration for certain health care providers, such that out-of-state providers can provide temporary assistance in the state.

First, Acting Commissioner Gifford extended, for an additional sixty days (from May 23, 2020 to July 22, 2020), a DPH order that was previously issued on March 23, 2020.  Specifically, DPH extended “the temporary suspension of the requirements for licensure, certification or registration, pursuant to chapters 368d (Emergency Medical Services), 370 (Medicine and Surgery), 376 (Physical Therapists), 378 (Nursing), 378a (Nurse’s Aides), 381a (Respiratory Care Practitioners), 383 (Psychologists), 383a (Marital and Family Therapists), 383b (Clinical Social Workers and Master Social Workers), 383c (Professional Counselors), 384d (Emergency Medical Services Personnel), and 400j (Pharmacy).”  The purpose of this suspension is to allow persons licensed, certified, or registered in other states to provide temporary assistance in Connecticut, subject to the same conditions and restrictions set forth in the initial DPH order issued on March 23, 2020.

Second, Acting Commissioner Gifford issued an order suspending, for a period of sixty days, “the requirements for licensure, certification or registration, pursuant to chapters 376a (occupational therapist), 376b (alcohol and drug counselor), 376c (radiographer, radiologic technologist, radiologist assistant and nuclear medicine technologist), 379 (dentist), 379a (dental hygienist), 382a (behavior analyst), 383d (genetic counselor), 383f (music therapist), 383g (art therapist), 384b (dietician-nutritionist), 385 (Embalmers and Funeral Directors), and 399 (speech and language pathologist),” such that providers licensed, certified, or registered in other states may provide temporary assistance in Connecticut.  Such out-of-state providers are subject to the following conditions:

  1. They are not permitted “to provide services beyond the scope allowed in the chapter of the Connecticut General Statutes specified that pertains to such provider's profession”;
  2. They must have and maintain such malpractice or other liability insurance that would be required if they were licensed in Connecticut for the entire period of assistance in Connecticut;
  3. Any Connecticut business or medical entity that engages with any such out-of-state provider must verify the credentials of such provider in the state in which he or she is licensed, certified, or registered to ensure the provider is in good standing and must confirm that the provider has the required insurance coverage;
  4.  Any such out-of-state provider who is enrolled in Medicaid or a fully-insured commercial plan must accept the Medicaid or in-network reimbursement as payment in full for his or her services; and
  5. Any such out-of-state provider who provides medical services to a patient in Connecticut who is not a Medicaid beneficiary or covered by a fully-insured commercial plan must determine, prior to engaging in such services: (i) whether a patient is covered by a health plan other than Medicaid or a fully insured commercial plan; and (ii) whether such plan provides coverage for such services.  If the provider determines that the patient’s services are covered under such health plan, the provider is prohibited from billing a patient for additional charges beyond the reimbursement received under such health plan.  If the provider determines that payment is not available under such health plan or determines that the patient is uninsured, the provider must accept the amount that Medicare reimburses for such service as payment in full, “provided that if such provider determines that the patient is uninsured or otherwise unable to pay for such services, such provider shall offer financial assistance if such provider is otherwise required to provide financial assistance under state or federal law.”

If you have any questions regarding these changes, please do not hesitate to contact any member of the Health Law Practice Group at Shipman & Goodwin LLP.

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