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Telehealth is here to stay, but that doesn’t mean the rules will all be staying the same, reports Holly Hester, Senior Director, Strategic Client Partnerships for Net Health and Yolunda Dockett (LinkedIn), Chief Compliance Officer at Anne Arundel Dermatology.
While the Public Health Emergency is set to end on May 11, 2023, the Consolidated Appropriations Act of 2023 extended many telehealth flexibilities through the end of December 2024. These include the ability to provide telehealth to patients in their homes, in both rural and urban settings, and the ability of physical and occupational therapists, along with speech pathologists, to provide telehealth.
Yet, there are inconsistencies, with some CPT codes used by rehab therapists set to expire at the end of 2023. Plus, some are being continued only for 151 days after the end of the emergency.
One other change to expect centers on privacy requirements. While many platforms have been used to provide telehealth, soon only HIPAA-compliant platforms will be allowed. It’s a change that makes the provision of care less flexible and perhaps less friendly.
Regardless, if your organization has not yet done a risk assessment about telehealth, now is the time. Leverage the relationships established in rolling out the service and then look collaboratively at the risks and start thinking about remediation techniques.
Some other things to consider:
- Understanding how to decide if a patient has the physical and mental capacity for telehealth
- Business and operational risks
- Privacy considerations, on both the provider and patient sides
- Reimbursement and billing
- Documentation requirements.
It’s a lot of work, but it helps to ensure that telehealth can be delivered in a complaint manner.
Finally, don’t miss learning more at their session “Incorporating Telehealth into Your Compliance Workplan” at the 2023 HCCA Compliance Institute.