Table 2.
Topic | Specific actions |
---|---|
Consent |
1. Verify that people providing consent are who they say they are (e.g., view their identification card). 2. Describe risks associated with confidentiality and privacy during consent. 3. Identify a HIPAA-compliant electronic signature service if first contact will be virtual. |
Privacy |
1. Identify a HIPAA-compliant method of transmitting PHI to and from the client. 2. Ensure consent includes a discussion of privacy risks and procedures. 3. Ensure that the family is in a private area and/or permits others in the area to hear possible PHI. |
Platform and equipment (Providers) |
1. Determine the requirements of insurance funders for telehealth services, which may require synchronous (live) audiovisual interaction. 2. Identify a HIPAA-compliant platform that meets requirements (may require a business associate agreement). 3. Obtain the necessary equipment based on the platform and insurance requirements for provider(s), which includes a secure (i.e., password-protected), Internet-enabled device with a webcam and microphone. 4. Obtain a headset for use in session to minimize privacy concerns and limit excess noise. |
Client access |
1. Verify that the client has an Internet-enable device with a webcam and microphone, and if necessary, consider providing access. 2. Provide instructions on how to download or access the platform. 3. Provide guidelines and feedback on how to set up a therapy space at home (e.g., proper lighting, minimal distractions, chair, table). |
Originating and distant sites |
1. Determine whether the client is eligible for reimbursement for telehealth. 2. If eligible, determine whether the client’s insurance company reimburses for facility-to-home telehealth. |
Licensure and state restrictions |
1. Document the originating site for each client. 2. For out-of-state clients, review state licensure requirements for the originating site and check whether existing clients can continue via telehealth. 3. Determine whether temporary or full licensure in the originating site state is needed to provide services. |
Credentials and privileges |
1. Follow insurance requirements for credentialing providers (may include a background check and update to liability insurance). 2. If part of a hospital or larger organization, check whether certain telehealth credentials or privileges are needed to practice. 3. Consider establishing a telehealth oversight committee to review and approve telehealth services in accordance with regulations. |
Provider training |
1. Develop provider training for telehealth service delivery. 2. Evaluate provider competence (see the Appendix for an example of a competency checklist). 3. Ensure providers can coach the client through telehealth setup. |
Outcomes |
1. Continue data collection of clinical (e.g., rates of problem behavior) and operational (e.g., cancellations, costs) outcomes in a manner that is comparable to in-clinic data collection. 2. Identify a HIPAA-compliant way to administer surveys, questionnaires, or other measures, as needed. |
Emergency procedures |
1. At the start of each telehealth session, document the client’s exact address. 2. Maintain an easily accessible list of authorities’ contact information in the client’s district that you can call in the event of an emergency. |
Provider wellness |
1. Frequently check in with employees regarding their wellness/mental health. 2. Incorporate opportunities for employees to connect and experience positive events (e.g., virtual happy hours, more frequent supervisory contact). 3. Be sensitive to employees’ schedules and competing demands (may require flexibility with scheduling clients and adequate breaks in between clients). 4. Encourage self-care activities. |
Documentation |
1. Incorporate necessary documentation for telehealth services into existing documentation procedures. 2. Ensure information such as the platform, service delivery method (e.g., synchronous video), originating site, and emergency procedures is easily accessible and properly reported to insurance. |
Note. HIPAA = Health Insurance Portability and Accountability Act; PHI = protected health information. These actions are based on ethical and legal guidelines and insurance regulations, as well as our experience in converting to telehealth.