Fairfax- Falls Church Community Board Services agrees and supports the comments to date below:

1. Opioid Treatment Services/Medication Assisted Treatment- Page 26:

The foundation of the Preferred OBOT model is to provide the medical and behavioral health services within the same location, have in-person interactions with the member and provide the high-touch care coordination to support the member in their recovery. DMAS recognizes that there may be situations that telehealth is necessary to engage the member in treatment and recovery. Thus Preferred OBOT services may be provided via telehealth based on the individualized needs of the member and must have supporting documentation of why the in-person interactions are not meeting the member’s specific needs. The primary means of services delivery shall be in-person for the Preferred OBOT model with the exception of telehealth for specific member circumstances (such as transportation issues, childcare, employment, co-morbidities, distance, etc.) that impede their access to treatment. Providers delivering services using telemedicine shall use the modifiers GT (interactive audio and video telecommunications system) or GQ (asynchronous telecommunications system).

• Comments/feedback: Please allow and consider the use of the 95 modifier, as opposed to changing the modifier to GT and GQ,  which are both Medicaid specific. The proposed change will be detrimental to servicing agencies who currently use the 95 modifier if it is changed to GT and GQ.