Below is some tele-health software shared with us by a variety of different organizations through various channels including NCB's Advisory Group and our listserv. Please check your state and local regulations and verify any information before moving forward with any tele-health platform. If you would like to share information with us to post, please email Ann Lundberg, NCB Logistics and Communications Coordinator, at firstname.lastname@example.org.
COVID 19 changes to telemedicine, this Medscape article has been shared by Eugene Augusterfer of HPRT. (Free registration is required to view the article.)
A note from Cynthia Grguric at International Psychology and Healing: APA has called on states to lift interstate laws for telemental health during COVID, read more on this at https://www.apa.org/news/press/releases/2020/03/mental-health-care-covid-19.
Links to FAQ and a paper from the California Association of Marriage and Family Therapists (CAMFT):
- Regulatory and Legal Considerations for Telehealthhttps://www.camft.org/Resources/Legal-Articles/Chronological-Article-List/regulatory-and-legal-considerations-for-telehealth
- Telehealth FAQs for Therapists during the COVID-19 Coronavirus Pandemic California Association of Marriage and Family Therapists (CAMFT) https://www.camft.org/Resources/Legal-Articles/Legal-Department-Staff-Articles/Telehealth-FAQS-for-Therapists-During-COVID-19
Notification of Enforcement Discretion for telehealth remote communications during the COVID-19 nationwide public health emergency from the HHS Office for Civil Rights in Action
https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html. Some of the links mentioned on the website include:
- OCR has published a bulletin advising covered entities of further flexibilities available to them as well as obligations that remain in effect under HIPAA as they respond to crises or emergencies at https://www.hhs.gov/sites/default/files/february-2020-hipaa-and-novel-coronavirus.pdf - PDF.
- Guidance on BAAs, including sample BAA provisions, is available at https://www.hhs.gov/hipaa/for-professionals/covered-entities/sample-business-associate-agreement-provisions/index.html.
- Additional information about HIPAA Security Rule safeguards is available at https://www.hhs.gov/hipaa/for-professionals/security/guidance/index.html.
- HealthIT.gov has technical assistance on telehealth at https://www.healthit.gov/telehealth.
Here is the latest on the relaxation of regulations related to telehealth. As you will see, the most relevant part reads: "A covered health care provider that wants to use audio or video communication technology to provide telehealth to patients during the COVID-19 nationwide public health emergency can use any non-public facing remote communication product that is available to communicate with patients". Lawyers with the American Telemedicine Association read this as phone communications are permitted and also fully billable, if appropriate. - From Eugene F. Augusterfer, Deputy Director and Director of Telemedicine, Harvard Program in Refugee Trauma
Below are two CMS Releases on COVID-19 and Telehealth
It appears that the waiver covers Medicare, which is a national program so all states are covered in the waiver. The second paper is on guidance for states, which administer Medicaid for individual states. Thus, each state has the right to set their own rules regarding telehealth, to include during this crisis. Each program needs to contact their individual state and check their states ruling on this issue. - From Eugene F. Augusterfer, Deputy Director and Director of Telemedicine, Harvard Program in Refugee Trauma
- Medicare: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet
- Medicaid: https://protect2.fireeye.com/url?k=777d6919-2b2860c9-777d5826-0cc47a6a52de-620bb70ae196e907&u=https://www.medicaid.gov/medicaid/benefits/downloads/medicaid-telehealth-services.pdf
If you have any regulations you think would be helpful to add please use the comment section below or contact Ann Lundberg at at email@example.com.