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Telehealth


The Addiction Technology Transfer Center (ATTC) Network, the Center for Excellence on Protected Health Information (CoE-PHI), the National Consortium of Telehealth Resource Centers, and the Center for the Application of Substance Abuse Technologies (CASAT) at the University of Nevada - Reno (UNR) facilitated this national online discussion and resource sharing opportunity for substance use disorder (SUD) treatment providers and peer support specialists faced with transitioning their services to the use of telephone and videoconferencing methods in response to COVID-19 social distancing guidelines.


Download complete FAQ document for the full list of recommendations and frequently asked questions from the series.

Tools to Get Started

Telehealth uses computers, phones, and internet-supported mobile devices to deliver healthcare services, including mental health and substance use disorder treatment and recovery. Many healthcare organizations are starting this process in response to COVID-19 with a focus on better understanding where telehealth and services delivered virtually will integrate into their sustained services post COVID-19. If you or your clinic/center are still familiarizing yourself with the concept of telehealth and looking for resources and support during COVID-19, four great resource and technical assistance (TA) places to start include:
 


KEY RESOURCE: SAMHSA’s 2015 TIP 60: Using Technology-Based Therapeutic Tools in Behavioral Health Services offers a comprehensive overview of implementing and sustaining technology-assisted care and shares templates of forms.


Find funding to support telehealth: On April 2, the FCC established a $200 million COVID-19 Telehealth Program to help health care providers provide connected care services to patients at their homes or mobile locations in response to the pandemic. Congress appropriated the funds as part of the CARES Act. The program provides immediate support to eligible health care providers responding to the pandemic by fully funding their telecommunications services, information services, and devices necessary to provide critical connected care services. To learn more about eligibility and to submit an application, visit fcc.gov/covid19telehealth.

Recommended Resource: MATRC have a list of have a list of free/low cost platforms under the “About HIPAA, Telehealth technology, and Vendors” tab on their resource page.
Recommended Resource: Verizon Wireless COVID-19 FAQs
Recommended Resource: FCC Keep Americans Connected lists all the government and private company programs that are working to keep America connected.
Recommended Resource: Telehealth Use in Rural Healthcare


Billing questions are certain to arise! A recommended place to start is to review your patient profiles by payer mix, identify the majority group, and then begin with the rules for that group before moving on to the next. An initial task is to organize your billing and reimbursement around your virtual clinic flow and outline the flow of services, professionals reimbursed for those services, codes available for telehealth and how to integrate those CPT codes into your electronic health records (EHR), and note any changes from telehealth policy pre-COVID-19. 

Example: Caravan Health: Virtual Care and Care Management Services (services, codes, who can bill, and details).

Recommended Resource: CMS: Medicare Telemedicine Fact Sheet
Recommended Resource: CMS Telemedicine Toolkit
Recommended Resource: Center for Connected Health Policy Quick Glance State Telehealth Actions in Response to COVID-19 and COVID-19 related state actions
Recommended Webinar: Medicare Coverage and Payment of Virtual Services


Download complete FAQ document for the full list of recommendations and frequently asked questions from the series.


Additional Resources:

NSI Strategies Telehealth Quick Start Toolkit: Overview of the items needed to get telehealth up and running immediately.

American Medical Association (AMA) Telehealth implementation Playbook: Comprehensive resource to accelerate the adoption and scale of digital health solutions.

Telemedicine: Getting Started, Regulations and Privacy IssuesWebinar discussing reimbursement, changes in and incorporation of telemedicine into OUD treatment practice.

Where to Begin… The Mountain Plains ATTC Webinar on Essential Tips for Using Videoconferencing to Deliver SUD Treatment and Recovery ServicesA comprehensive list of tips and tools to get you started down the path of implementing telehealth in your practice.

Telehealth Learning and Consultation (TLC) Tuesday'sA one-hour webinar from Mid-America ATTC, MHTTC, and the Mountain Plains MHTTC.

Mountain Plains ATTC: A list of resources for treatment providers and peer support specialists on online and telephone support groups.

Association of Recovery in Higher EducationProviding Telehealth Recovery Support During COVID-19.

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Telehealth Best Practices

Recommended ResourceNational Council for Behavioral Health's Guidance for Behavioral Health Residential Facilities


How can Intensive Outpatient programs (IOPs) operate using telehealth?
IOPs can include a lot of group services across the week depending on the ASAM Level of Care and groups need to be smaller (around 10 people). If your IOP usually has 20 people per group, then offering two smaller sessions (at least initially) is the best approach. Panelists recommended using a co-facilitator so one person can lead the group and the other can monitor the chat and other needs. ASAM guidelines for IOP differ based on Level of Care so a mixture of individual and group sessions will ensure you meet the hourly requirements and parameters.

Examples: Virginia: SMART IOPCrestview Recovery Telehealth IOP.


Technology Based Clinical Supervision (TBCS):
TBCS is being done using telehealth and the National Frontier and Rural ATTC (NFAR ATTC) have created resources around this to provide substance use disorder and other behavioral health professional licensing and certification boards with guidelines and associated rationale for policies regarding the implementation of TBCS. All supervision, whether live or audio and video recordings, shall be done in a confidential manner in accordance with the ACA Code of Ethics and any state or federal guidance. Recording sessions is discouraged unless there are strong privacy protections in place and even then, the panelists recommended limiting any information disclosed during activities such as case studies.


Download complete FAQ document for the full list of recommendations and frequently asked questions from the series.


Additional Resources:

Advancing Clinicians' Videoconferencing Skills: An Audio-Consultation Series. The Mountain Plains ATTC introduces a new product to train behavioral health professionals on the use of videoconferencing to deliver clinical services.

Best Practices for Telehealth During COVID-19 Public Health Emergency: The National Council for Behavioral Health has put together an overview of best practices for behavioral health providers new to or just starting out with providing telehealth services.

Providers Clinical Support System FAQs: Tips for primary care providers for treating opioid use disorder via telehealth.

Mid-Atlantic Telehealth Resource Center (MATRC) Vendor Selection Toolkit: Insights of experienced telehealth experts to help you identify the steps you should undertake to select the most suitable technologies for your telehealth services.

National Frontier and Rural Telehealth Education Center: Telehealth Capacity Assessment Tool designed to help organizations assess their readiness to adopt telehealth technologies.

Mid-Atlantic Telehealth Resource Center: A curated list of FAQs, best practices and instructions for getting started in telehealth, including a list of free/low cost platforms.

Best Practices in Videoconferencing-Based Telemental Health (April 2018): A consolidated update of the previous American Psychiatric Association and American Telemedicine Association official documents and resources in telemental health to provide a single guide on best practices in clinical videoconferencing in mental health.

Technology Based Clinical Supervision National Association of Social Workers: A collection of resources and information from the NASW for social workers responding in their role to COVID-19.

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Federal & State Guidance for Practices

Policies around telehealth are rapidly changing and knowing where to find and learn about updated federal and state policies is critical.


Federal
At the federal level, SAMHSA’s COVID-19 Guidance and Resources and HHS telehealth and COVID-19 resource page outlines the most recent updates. These include changes around HIPAA flexibility, telehealth waivers for the Centers for Medicaid and Medicare Services (CMS), and details around cost-sharing for patients in federal healthcare programs. TA and resource centers such as CoE-PHI and the National Consortium of Telehealth Resource Centers offer webinars and brief guides to help understand these policies and guidelines.

Recommended Resource: CoE-PHI: Understanding the New SAMHSA/OCR Guidance for Telehealth SUD and MH Services
Recommended Resource: Telehealth for the Treatment of Serious Mental Illness and Substance Use Disorders
Recommended ResourceState-by-state guide to the rules/laws about telehealth services across state lines
Recommended Resource: Waiving State Licensing Restrictions for Telehealth Helps Combat COVID-19
Recommended ResourceAlliance for Connected Care: State Telehealth Expansion by Governor’s Orders


State
In addition to changing federal guidelines, providers need to ensure they comply with all state requirements, especially around privacy and consent to treat. COVID-19 has further created a situation where patients may have received treatment in one state and then moved to a different state for quarantining. This is especially relevant to those working with college students who have left campus and returned home. While CMS announced a waiver allowing telehealth across state lines, permissibility to practice telehealth across state lines may vary depending on your state. Two other key areas include the duty to warn and child abuse reporting mandates.

Recommended Resource: The American Psychological Association (APA) Telehealth Guidance by State
Comprehensive Resource: State Telehealth laws and Reimbursement Policies


Download complete FAQ document for the full list of recommendations and frequently asked questions from the series.


Additional Resources:

Medicaid State Plan Fee-for-Service Payments for Services Delivered Via Telehealth: A document intended to assist states in understanding policy options for paying Medicaid providers that use telehealth technology to deliver services. 

Medicare Telemedicine Health Care Provider Fact Sheet: Guidance from the Centers for Medicare & Medicaid Services (CMS) on expanded access to telehealth services for Medicare beneficiaries.

The US Department of Health and Human Services: A collection of FAQs around telehealth and being HIPAA compliant during the COVID-19 public health emergency.

The University of Texas at Austin Counseling and Mental Health Center: A starting place for mental health professionals looking for information on state-by-state rules/laws about telehealth services across state lines. 

Telehealth Guidance by State: The American Psychological Association (APA)

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HIPPA, Forms & PHI

Technical assistance (TA) provided by the Center of Excellence for Protected Health Information (CoE-PHI) aims to support implementation of relevant federal confidentiality and privacy laws for providing mental health and substance use disorder services to clients in practice.
Request TA from CoE-PHI

So how do we select a HIPAA-compliant platform?
We like to use the phrase HIPAA secure rather than HIPAA compliant to reinforce that it is the user that makes the platform HIPAA compliant rather than the platform itself. Generally speaking, the difference between HIPAA secure platforms (such as Adobe Connect, Cisco WebEx, Zoom Pro, and GoToMeeting) and currently allowed non-secure platforms (such as Apple FaceTime, Facebook Messenger video chats, WhatsApp, Google Hangout, Zoom, and/or Skype) comes down to the privacy of information (how it is shared) and the security of information (how it is protected). HIPAA secure platforms make a commitment to record and handle any session information or metadata in a way that complies with HIPAA and gives you the ability to audit. We should reinforce that any “public-facing” platform (such as TikTok, Facebook Live, Twitch, or public chatrooms), which are designed to be open to the public are not covered by the Notification of Enforcement Discretion regarding COVID-19.

How do I stay compliant if I am operating across state lines?
The variation in state guidelines around how patients can consent to treatment means reviewing the state guidelines for every state you are operating in (based on where you and your patients are located). Part 2 is a federal law and is generally the most protective privacy law, but state guidelines should still be reviewed for cases where the state imposes stricter guidelines around privacy.

Recommended Resource: State-by-state guide to the rules/laws about telehealth services across state lines
Recommended Resource: Waiving State Licensing Restrictions for Telehealth Helps Combat COVID-19
Recommended Resource: Alliance for Connected Care: State Telehealth Expansion by Governor’s Orders


Download complete FAQ document for the full list of recommentations and frequently asked questions from the series.


Additional Resources:

NASW Informed Consent Form: Telemental Health Informed Consent Form.

Center for the Application of Substance Abuse Technologies (CASAT): at the University of Nevada - Reno (UNR) facilitated eight national online discussion and resource sharing opportunities for substance use disorder (SUD) treatment providers and peer support specialists faced with transitioning their services to the use of telephone and videoconferencing methods in response to COVID-19 social distancing guidelines.

Understanding the New SAMHSA/OCR Guidance for Telehealth SUD and MH Services: This presentation describes how the privacy laws apply to telehealth and reviews the OCR/SAMHSA guidance related to the COVID-19 pandemic.

Office of Civil Rights (OCR) guidance: on enforcement of discretion for telehealth remote communications during the COVID-19 nationwide public health emergency. 

National Consortium of Telehealth Resource Centers: HIPAA and Telehealth Infographic, A Stepwise Guide to Compliance.

The University of Maryland School of Social Work Institute for Innovation and Implementation: An infosheet on HIPAA-compliant technology during COVID-19.

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Additional COVID-19 Resources:

Federal Communications Commission: A link to information and application for the COVID-19 Telehealth Program, established to offer funding to help health care providers provide connected care services to patients at their homes or mobile locations.

National Center on Domestic Violence, Trauma & Mental Health: Supporting Survivors’ Access to Substance Use Disorder and Mental Health Services during the COVID-19 emergency.

Center of Excellence for Integrated Health Solutions: COVID-19 Office Hour Session – Opportunities for Peer Support Workers, Supervisors, and Programs.

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