Table 1.
Guidelines for telehealth service bbefore and after the COVID-19 pandemic
| Topic | Relevant guidelines | General considerations | Reimbursement considerations | Documentation considerations | Changes due to the COVID-19 pandemic |
|---|---|---|---|---|---|
| Consent | Ethics Code; HIPAA | There may be added risks associated with confidentiality and privacy that need to be included in consent procedures | No specific considerations | Signed consent to treat via telehealth | No change, but may not ever be physically face-to-face with client so consent may need to be virtual |
| Privacy | Ethics Code; HIPAA | Transmission and storage of PHI must be encrypted and secure | No specific considerations | Notice of privacy rights signed and acknowledged by client annually | Temporarily no HIPAA violations will be prosecuted; unclear how long it will be suspended |
| Platform and equipment (Providers) | Ethics Code; HIPAA; insurance regulations | Platform must be HIPAA-compliant and accessible for clients | Requires interactive audiovisual sessions; phone, e-mail, or asynchronous video may not be eligible for reimbursement | Type of telehealth service provided | Alternative formats such as phone calls and text messages are currently permissible and reimbursable but must be documented |
| Client access | Ethics Code | Consider how platform and equipment needs influence clients’ access to services; may consider providing access to necessary equipment | No specific considerations | No specific considerations | Access may be easier because standard telephone services are temporarily permissible |
| Originating and distant sites | Insurance regulations | Location of the client can impact eligibility for services | Facility-to-facility required; may require that client reside in a “rural” area | Originating site location and distance from provider | Restrictions on originating site have been lifted by insurance companies (home-to-facility are permitted) |
| Licensure and state restrictions | State licensure laws; Ethics Code | Professionals must be licensed to practice in the originating site state (i.e., where the client is located during telehealth services) | State licensure could affect reimbursement | License for each state (including temporary); continuing education and other requirements for license renewal | Some states waive licensure requirements, others provide temporary licensure, and others require providers to apply for licensure; in some states, telehealth is only permitted with established patients |
| Credentials or privileges | Insurance regulations | May need telehealth credentials or privileges to practice | Credentialing necessary for reimbursement | Credential or privilege details | Credentialing guidelines have relaxed |
| Provider training | Ethics Code | Must be competent with telehealth delivery model | May be required to become credentialed | Specific training requirements completed | Many more providers qualify for telehealth, but still need to ensure proper training and competence |
| Outcomes | Ethics Code; insurance regulations | Must demonstrate that telehealth is as effective as in-clinic services | Needed for continued reimbursement and/or preauthorization | Relevant outcome measures throughout service | No change |
| Emergency procedures | Ethics Code | If there is an emergency with the client, providers must be able to contact authorities in the client’s district (dialing 911 will contact authorities in the provider’s district) | None | Client’s address; authority contact information for client’s district | No change |
| Provider wellness | Ethics Code | Providers should maintain self-care and be aware of “Zoom fatigue” | None | None | That most providers working are from home has blurred lines between work and home |
Note. Guidelines refer to legal, ethical, or professional documents that provide rules or regulations regarding these topics. Ethics Code = includes both the American Psychological Association and the Behavior Analyst Certification Board professional ethics codes; HIPAA = Health Insurance Portability and Accountability Act; PHI = protected health information. Reimbursement considerations are based on what most third-party payers (e.g., health insurance) will reimburse. There are exceptions to some of these guidelines across states and insurance companies.