Guidance for Direct to Patient Video Conferencing
We have created Guidance for Direct to Patient Video Conferencing for
Department faculty and staff in response to the current COVID-19 situation. We encourage you to familiarize yourself with the guidance (15-20 minutes).
NOTE: The COVID 19 situation continues to evolve quickly and we anticipate some of this guidance may change, especially around federal regulations and billings in the coming days.
- The current APA-ATA joint guidelines provides an overview of
key issues in administering and conducting telemedicine sessions.
- Articles that have some suggestions on managing patients with remote technologies include the following:
- Shore, J. H. (2020). Managing Virtual Hybrid Psychiatrist-Patient Relationships in a Digital World. JAMA psychiatry.
- Shore, J. H. (2013). Telepsychiatry: videoconferencing in the delivery of psychiatric care. American Journal of Psychiatry, 170(3), 256-262.
- An extremely helpful resource is the APA’s Telepsychiatry Toolkit providing brief overviews via 2-3 minute video on key topics in Telepsychiatry. https://www.psychiatry.org/psychiatrists/practice/telepsychiatry/toolkit
New Federal and State Guidelines
- Controlled substances prescriptions over telehealth no longer require in-person medical evaluation. https://www.deadiversion.usdoj.gov/coronavirus.html
- Medicare restrictions for telehealth lifted, in particular, patients outside of rural areas, and patients in their homes will be eligible for telehealth services, effective for services starting March 6, 2020. https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf
- The HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies. (non-HIPPA Secure, eg.
facetime, regular skype).
NOTE: Language above is “will exercise enforcement discretion,” which is very different than saying HIPPA does not apply. For the DOP we should FIRST use our HIPPA compliant platforms VIDYO and
ZOOM. If for some reason these will not work then consider going to a non-HIPPA compliant platform. ZOOM is functioning very well right now so we would be surprised if this is needed.
- Colorado’s Mental Health Boards are alerting the public that it is at the discretion of mental health providers to account for current circumstances and use their best judgment in choosing telehealth as a modality. Professionals licensed, registered
or certified in the state and treating clients within Colorado may conduct teletherapy sessions. Policy 30-1 recommends that the initial consultation be face to face. However, it is at the discretion of the mental health professional as to the
type of modality of treatment format that is appropriate for the client - especially in light of recent guidance given by the CDC and other public health organizations. https://content.govdelivery.com/accounts/CODORA/bulletins/281b51d
NOTE: It has always been at the discretion of the mental health professional as to the type of modality of treatment format that is appropriate for the client. So even before COVID, it was very unclear what “recommend”
meant and we were never able to get clarification out of boards on this. Clearly at this moment telehealth is encouraged.
- Throughout the COVID-19 state of emergency, Health First Colorado (Colorado’s Medicaid Program) is temporarily expanding its telemedicine policy to authorize the following, among others. Colorado Access, the Denver-area Regional Organization
for Medicaid, has resources on their website.
- Expanding the definition of telemedicine services to include telephone only and live chat modalities.
- Adding Pediatric Behavioral Therapy services to the list of eligible interactive audiovisual telemedicine services.
We should keep in mind that the above are all predicated on the Federal and State emergency declarations and presumably will expire when these end.
We have included some relatively brief videos to complement the materials that went out on Monday, March 16th focused on telehealth divided into administrative, technical and clinical considerations. https://www.youtube.com/playlist?list=PL0UFu3yA68AmCNO3l9TAgvL9GPMUenEZ3