TABLE 4.
Policy/regulatory standards | Authors experience | COVID‐19 impact | |
---|---|---|---|
Technology |
CMS TRC a |
Institution telehealth administrative team chose | Same |
Equipment |
CMS TRC |
Laptops, Tablets | Laptops, tablets, smart phones; The provider's platform and therefore patient encounter is HIPAA compliant regardless of what device the patient uses to enter the telemedicine platform. |
Security |
CMS TRC |
HIPAA compliant platform, documentation in EMR, authentication and identification to ensure telemedicine confidentiality. Originating site confirms patient identification | HIPAA compliant platform, virtual waiting room of the professional license requires distant provider ‘accepts’ only identified patients into session, documentation in EMR, authentication and identification to ensure telemedicine confidentiality. |
Providers eligible to offer telehealth services |
CMS State Medicaid guidance b |
All members of our team MD/DO/NP/RD/PhD |
Same |
Provider settings | Distant Site | Distant site‐team | Same |
Patient settings | Originating Site (healthcare facility as outlined by CMS/State policies) | Originating site: Primary care healthcare office | Patient's home |
Who needs to be present | AAP consent/assent guidelines 24 | Patient and family members with guardian and patients consent/assent. |
Same practice Ask who is present in the home; ask permission to speak freely |
Health condition characteristics | CMS and State Medicare: Provider assesses if can address health condition using this modality | Obesity and related comorbidities. In‐person visit scheduled if concerns arise using virtual visit | Same |
Scheduling |
Institutional policy Clinic protocol |
Our clinic schedules across the multi‐disciplinary team | Same |
Registration |
Institutional policy Clinic protocol |
Registered by our clinic (Distant Site) | Registered by our clinic (Distant Site) |
Consent for non‐in‐person visit |
CMS State Medicaid Institutional policy |
Pre‐COVID: obtained written consent to treat. Inform care by telemedicine voluntary | Per institution leadership/legal team verbal consent replicates written consent during the pandemic |
Check in and out | N/A | Via our clinic (distant) | Via our clinic (distant) |
Credentialing |
CMS Board of Regulations for Providers Institution credentialing policies |
Full credentialing of distant site provider by originating site Medical Staff Office if distant site provider will be seeing patients in‐person at the originating site | Provider already credentialed by distant site (their home institution); no further credentialing necessary as the originating site is now the patient's home. |
Documentation |
CMS Institution documentation policies |
Document that visit occurred via telemedicine | Document if visit occurred via telemedicine, telephonic, or both |
Coding and Billing |
CMS Institutional policies |
See Table 3 | See Table 3 |
Facility fee |
CMS Institutional policies |
See Table 3 originating site Q3014 |
No Facility Fee when home is originating site |
Professional fee |
CMS Institutional policies |
See Table 3 Distant Site: Professional Fee with GT or 95 modifier |
Same |
Abbreviations: CMS, Centers for Medicare and Medicaid Services; HIPAA, Health Insurance Portability and Accountability Act; TRC, National Consortium of Telehealth Resource Centers.
Restricted to HIPAA‐approved under CMS/TRC regulations.
Eligible providers vary by state Medicaid policy. Rapidly changing.