Thinking About Providing Telehealth? Here's Our Top 10 'To-Do' List
The COVID-19 pandemic has caused patients and providers, as well as state and federal governments, to consider the use of telehealth on a wider scale, including in physical therapy.
It's a complicated topic that deserves your time — not just because of the immediate need for change to help respond to the current health crisis, but because the expansion of telehealth to physical therapy has been long sought by many in the profession, and it is one of APTA's central advocacy targets.
APTA offers extensive resources on telehealth on its telehealth webpage, and we're adding information frequently as the on-the-ground realities continue to develop. You should review those resources before making a decision about whether telehealth is the right approach for you — or if it's even possible.
Arm yourself with as much information as possible—and follow these 10 telehealth "to-dos."
1. Know what's allowed and what's not.
Regardless of the payer or policy, if you provide and bill for telehealth services, you must do it legally and ethically. That means adhering to state and federal guidelines and paying particular attention to the laws and regulations in your state of licensure.
Understand that not all states allow telehealth by PTs or PTAs and that even among those that do, there are variations in what exactly is permitted. It doesn't matter what a commercial payer may allow, or even what CMS permits: If your state says telehealth is outside your scope of practice, you can't use it to provide services.
Carefully review your state licensure law and regulations, but remember that in many states, the law is silent on telehealth and physical therapy. If that's the case in your state, contact your state's licensing board to find out if there are limitations or restrictions. For more information, check out APTA's state practice act resources, and information from the Federation of State Board of Physical Therapy. And remember that state-mandated health orders and state emergency orders can also change what is and isn't permitted.
2. Train your staff.
Solid staff training is key to an effective telehealth program that best responds to the COVID-19 pandemic. APTA offers several resources to help you ensure that your staff is as prepared as possible for providing telehealth in this crisis. Check out these two APTA Learning Center webinars: Implementing Telehealth in Your Practice , recorded on March 26, and Digital Telehealth Practice – Connect for Best Practice, Healthcare, and Compliance, to be recorded on April 2, with a live online Q&A on April 7.
3. Educate your patients on their privacy and rights.
You need to properly educate patients about the use of telehealth, which includes their rights while being cared for under this modality. Patients need to be aware of your obligation to protect their privacy and gain their consent. For more information about informed consent, check out the Center for Connected Health Policy resources.
4. Take privacy seriously — and understand how it's affected by technology.
You need to understand the technology of telehealth, and the extensive regulation in place to protect patient privacy and security of health information, including HIPAA requirements. Also check out the additional resources listed at the end of this blog.
5. Document, document, document (just like always).
Keep in mind the documentation needed to have a proper compliant telehealth program. For more information, view APTA's Defensible Documentation resources.
6. When it comes to payment, assume nothing.
Your practice can involve multiple payers, with differing policies, including those related to telehealth. This means you'll face a patchwork of approaches.
You should command a sound understanding of variations in telehealth reimbursement, be it through Medicare, Medicaid, other federal health payers, or commercial payers. Verify with individual payers what is and isn't permitted, what CPT codes will be reimbursed, the required modifiers, and more. Confirm with each payer whether the originating and distant site can be a private home or office, if services must be real-time or can be asynchronous, and any other limitations to your use of telehealth. This APTA article offers guidance on what questions to ask your payer(s).
Also find out if your state has parity laws that require insurers to pay the same amount for telehealth services as they would for an in-person visit. For more information, check out APTA's Telehealth billing and coding resources.
7. Make sure your malpractice insurance covers telehealth.
You should check your malpractice insurance and update it if it doesn’t cover practice using telehealth. For more information, see APTA's Risk Management resources as well as the resources listed at the end of this blog.
8. Understand that your ethical responsibilities don't change when delivering services via telehealth.
It's simple: You are held to the ethical standards of your profession while practicing telehealth. Here are some resources you should review regarding ethics in telehealth. Also, check out a free APTA Learning Center webinar that discusses what you need to know to ensure compliance with regulations established by HIPAA and the APTA Code of Ethics when using telehealth and mobile health technology. Also worth a look: this blog post highlighting ethics, best practice, and law considerations for practicing telehealth.
9. Stay connected with your peers in telehealth.
Telehealth is part of APTA's Frontiers in Rehabilitation, Science, and Technology (FiRST) Council. FiRST grew out of identification of high-priority areas to advance science and innovation that our profession needs to understand and incorporate into our practice, education, and research. FiRST is intended to serve as a community for interested stakeholders, and is a great way to learn from those who've been leading the way.
Remember that most of the opportunities for telehealth at the moment are temporary, in response to the COVID-19 pandemic. And as of this writing, even though CMS now has the (again, temporary) authority to include PTs among the providers who can engage in telehealth, it hasn't moved in that direction. That’s why it's so important to continually advocate for payment and coverage policies that ensure patients have access to the rehabilitative care they need. Learn more about how you can engage in federal advocacy today and watch for advocacy opportunities on the state level.
More Telehealth Resources for PTs and PTAs
HIPAA: Business associate agreements
Health IT and telehealth
HPSO: Telemedicine: Risk Management Issues, Strategies, and Resources
APTA: Considerations for Practice Opportunities and Professional Development
HHS Security Risk Assessment Tool
HPA Tech SIG: SIG's homepage.