[Transcript] Episode 533: “Telehealth Care Coordination Policy & Procedures” — What to Know

 

Evan Dumas 

You’re listening to Group Practice Tech, a podcast by Person Centered Tech, where we help mental health group practice owners ethically and effectively leverage tech to improve their practices. I’m your co-host, Evan Dumas.

 

Liath Dalton 

And I’m Liath Dalton, and we are Person Centered Tech.

 

Liath Dalton 

This episode is brought to you by Therapy Notes. Therapy Notes is a robust online practice management and electronic health record system to support you in growing your thriving practice. Therapy Notes is a complete practice management system with all the functionality you need to manage client records, meet with clients remotely, create rich documentation, schedule appointments and bill insurance all right at your fingertips. To get two free months of Therapy Notes as a new Therapy Notes user go to therapynotes.com and use promo code PCT.

 

Evan Dumas 

Hello and welcome to Episode 533: “Telehealth Care Coordination Policy & Procedures” – What to Know.

 

Liath Dalton 

Yes, what to know. And we know that discussion of policy and procedures is not necessarily everybody’s favorite topic or what feels most exciting and compelling, but we are talking about this today because we have been getting increasing reports and queries from clinicians and practice owners related to being asked to provide a quote “telehealth care coordination policy and procedures” to insurance companies as part of their credentialing and paneling process.

 

Liath Dalton 

So what the heck is supposed to be contained within that? Is that something you already have covered? Or just, how should you go about preparing to be in compliance with this? If it’s not a requirement you’ve been faced with directly yet, or if it’s one you have been faced with directly, what do you do and how can we help?

 

Evan Dumas 

Yeah.

 

Liath Dalton 

So before we get into the nitty gritty of it, I’ll also share that we have just been working to create specific, customizable templates and support resources related to this that we are going to be releasing next week, but in the meantime, wanted to talk about what exactly this policy and procedures is supposed to contain, and why we’re seeing this requirement coming up.

 

Liath Dalton 

So essentially, the requirement is coming up now because there has been a shift, understandably, in both insurer and regulator focus since telehealth has become, you know, mainstream through and post pandemic, and the insurers are wanting to ensure that clinicians and providers have a standardized and documented protocol for risk management, especially around emergencies and provider to provider coordination.

 

Liath Dalton 

I’d say as an aside that the you know, American Telemedicine Association, the ATA, who set a lot of telehealth standards and policy and the Center for Connected Health Policy had not previously explicitly addressed the care coordination with other providers as part of telehealth standards, right? So Evan, what was our discussion when we got the first query related to this?

 

Evan Dumas 

We were like, This is great. We have things that cover like 90% of it, because we’ve been telehealth focused since the start of PCT. But we’re like, oh, we are totally going to make this and help people, because, you know, people are still sort of falling into telehealth and not being formally trained or having documentation about how they do it.

 

Liath Dalton 

Exactly. And in terms of the policy itself, and when, going back to what Evan just said about the 90% or like 95% of it already are being covered in existent materials, that’s because our telehealth checklist includes addressing all of the previously existent standards around crisis response and local crisis response and emergency services for where the client is actually located at the time of session, and documenting the client location at time of session, crisis response, a safety plan, all of those pieces are really depthfully addressed in our trainings and materials. But this piece around coordinating care with other providers wasn’t explicitly addressed.

 

Evan Dumas 

No.

 

Liath Dalton 

So then we had this consideration of, well, do we just add in a section that explicitly addresses care coordination with other providers, or do we pull pieces from the existent materials and whatnot into a new policy? Well, the the end result of that consideration was to put everything in a dedicated policy that addresses just what the insurance companies are looking for. They don’t want to sift through all of the other policies and procedures and components that a clinician or a practice has in place for telehealth, in general, they’re just looking to check a box, and if they’re doing an audit or going through the, you know, paneling process with someone to be able to quickly identify whether or not these requirements are met.

 

Liath Dalton 

So yay. Yet another document. But it does really make sense, and in all reality, it is an area where you know, if you haven’t had a chance to think really intentionally about it, there could be gaps, or there could be areas where maybe you are going through a care coordination process with another provider and not ensuring that client info is fully secured throughout that whole coordination process, right? Okay, so what is the definition of this policy, Evan?

 

Evan Dumas 

Yeah, it’s a written practice policy that outlines how clinicians ensure continuity, safety and coordination of care when, you know, delivering services via telehealth.

 

Liath Dalton 

And what are the core elements that the insurance companies are looking to see addressed in this policy?

 

Evan Dumas 

Yeah. And so we’ve covered some of these. You know, I’ve hinted at them earlier, but they’re things like, you know, emergency crisis coordination, how you communicate with other providers, what those standards for secure communication are, how to do continuity of care, if you’re not unavailable, and how it connects to your sort of greater ensure expectations of HIPAA, privacy, security rules, ethics codes, things like that.

 

Liath Dalton 

Right. So that you know the pieces around emergency and crisis coordination should be fairly clear at this point in terms of what that entails for having a safety plan, knowing what the emergency and crisis response resources are that are local to a client, where they are physically located at the time of session, and how to directly contact those emergency services in the event that a crisis occurs during a telehealth session.

 

Liath Dalton 

But here’s where we have to give yet another aside, which is that clinicians actually following that practice and standard has resulted in lives being saved.

 

Evan Dumas 

Yeah.

 

Liath Dalton 

And we’ve had direct reports of that happening from folks in the PCT community. So this is something that is really important and needs to be addressed, and odds are you’ve already addressed it, but you want to include that in this policy and procedures. And then have, like Evan said, your a plan for continuity of care when you’re unavailable, whether that be a planned vacation or in the event that you are unexpectedly unavailable. And that can be something like, you know, the local crisis line and another provider, potentially ,who may be available to provide coverage in the event of an emergency.

 

Liath Dalton 

What I want everyone to really be thinking about here, though, is their processes for communication with other providers and those secure communication standards. Because what we’re wanting to see is that the secure communication standards the same as what you have in place for secure client communication should also be in place for communicating with other providers?

 

Evan Dumas 

Oh, definitely.

 

Liath Dalton 

And while maybe you’re thinking up, but that’s not something that’s specific to telehealth that’s addressed in our general policies and practices. Yes, exactly. So if you have that already written out, just pull that piece over. But need to be using HIPAA compliance compatible platforms for those communications, so meaning that you have a HIPAA Business Associate Agreement in place with the service provider and that communications with clients about any coordination of care with their other providers also needs to be contained within your compliance, compatible secure communication channels that if there has been a client request for non secure communication, or alternative communication, as it’s known under the HIPAA Privacy Rule, that is not something that then extends to how you communicate with other providers for care coordination, right? So it’s gotta, gotta be secure and compliance copacetic across the board.

 

Liath Dalton 

So what should you do to comply?

 

Evan Dumas 

Yeah, yeah. Well, it depends if you’re solo or group practice, but we’ll speak to that.

 

Liath Dalton 

Exactly. So Evan, if you’re a solo practitioner, what should the policy include?

 

Evan Dumas 

Yeah, you know you got your regular client, location to verification, emergency planning, things like that. Your communication standards, like, you know, your secure one and your alternative ones, if you know they consent to non secure communication. Also, provider to provider coordination protocols, because you may need to consult with your supervisor or with peers, and how do you handle that? And, you know, also your classic continuity of care, because if in case you’re unreachable, in case you’re on vacation, how does all of that handled? How are they making sure their things are safe and secure, and yeah, how you take care of it.

 

Liath Dalton 

Exactly. And then for group practice, it’s the same as what Evan just said, plus some additional pieces, because your coverage for someone in the event of being unavailable is going to be most likely other another clinician from within the group practice. So then what your policies and procedures need to address are how the internal handoffs and staff rules in emergencies are managed, and then specifically address what the centralized documentation and quality assurance processes are going to be.

 

Liath Dalton 

So that’s the like main takeaway, and I will say that one thing that really comes up when talking about coordination of care with other providers is that under HIPAA, you do, you are not required to have a release of information from a client in order to discuss treatment with Another no provider, no right, that is not a requirement. But Evan, what does our favorite HIPAA and teletherapy attorney always say about ROIs?

 

Evan Dumas 

Oh, better to have one and not need it than not have one and need it.

 

Liath Dalton 

Yes. So even though it’s not required for coordination of care, it is very beneficial for transparency and client trust to have that in place.

 

Liath Dalton 

So the PCT template for group and solo practices for this policy is that even though an ROI is not required for care coordination, that except in the event of an emergency where care coordination is happening due to the emergency, that efforts will be made to obtain an ROI, and that’s just providing consistency across what’s going to be in your general HIPAA policies and procedures anyway. And that’s something that’s protective for you, but also, and even more importantly, of the client relationship, in part because ROIs also specify what information may be disclosed and or what information they don’t want disclosed, and that’s something that clients should have, say, an autonomy over, if at all possible.

 

Liath Dalton 

So anyway, we hope that this little discussion has been helpful, and if you would like some direct support related to how to shape these policies, if it’s something you’re crafting on your own, that’s something we’ll gladly provide input on through our Office Hours direct support and consultation service that’s part of Practice Care Premium or the PCT customizable templates will be being released next week and available through the Telemental Health Certificate Program, materials, resources, or through the Group Practice Teletherapy Program, manual, informs, package. So stay tuned for those and take good care.

 

Evan Dumas 

Oh, yes.

 

Liath Dalton 

So I think that’s something that may be a little unique in how we’re approaching this, but in terms of whether or not an insurance company is requiring that, my understanding is they’re not requiring that, but they like to see that still still present, because that also is indicative of how you center client confidentiality and ethics adherence, and kind of going above and beyond the bare regulatory minimum, and always remembering that HIPAA is the floor, not the ceiling.

 

Evan Dumas 

Everybody, yeah, talk to you next week, everybody.

 

Liath Dalton 

This has been group practice tech. You can find us at personcenteredtech.com. For more podcast episodes, you can go to personcenteredtech.com/podcast or click podcast on the menu bar.