What do I need ?
- Internet - Your internet connection is the needed pathway to perform services. Think of it as the fuel that carries the flame. In order to deliver and maintain your connection, you will need to have adequate internet speed and bandwidth. You can perform a speed test through going online and selecting a speed test link. The suggested minimum amount of speed is 15MBps download and 5Mbps upload capability. One option is SpeedTest or going to your usual internet browser and entering, internet speed test, which should offer several tools for testing your speed. Or you may prefer to contact your communications network through their designated link to perform the speed test (Frontier, Comcast, AT&T, etc.) Your speed and bandwidth needed will depend on how many users or devices will be sharing your network.
- Hardware – These are your devices that you will be using to perform your telecommunications of telehealth services such as a desktop, laptop, tablet or even a smartphone, as well as, peripherals such as patient monitoring devices. Also, other hardware customized for telehealth are known as carts. These are portable systems that include a monitor, camera and keyboard which allow for live images and the ability to store and forward if needed. Compatibility is also an important factor with this because certain technologies must speak the same language in order to communicate well and efficiently. Also consider that although most hardware devices come with a microphone and camera, there are some that do not and you may need integrate a separate external microphone and camera, or to ensure higher quality sound and pictures, you may need to upgrade your equipment to include higher resolution monitors and headsets or earbuds.
- Software - In order for your hardware of choice to provide telehealth services, you may find it preferable to select a software program that provides telehealth platforms. There are various telemedicine software companies that offer these services.(e.g, Zoom, Doxy.me, Teladoc, Evisit) NORCAL does not endorse any particular vendor and the choice should be made based on your needs and comfort with the software that you choose. When considering one, it is important to choose one that promotes your responsibility to be HIPAA compliant, whenever possible. Although there are HIPAA waiver provisions during the COVID19 state of emergency, HIPAA still plays an active role in safeguarding healthcare information security measures. There are platforms that are not HIPAA compliant, which have been addressed as acceptable during this specific pandemic period. See The Office of Civil Rights (OCR) Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency for further guidance on use of these options, and remember, you will need to watch for any change in the relaxation of this enforcement once the pandemic period has been deemed to have ended.
- If your physicians, providers and staff will be working from home, consideration also needs to be given to the equipment and security available for telecommuting/remote work. The American Medical Association (AMA) and the American Hospital Association (AHA) have teamed up to provide a white paper entitled Working from home during the COVID-19 pandemic . Additional resources for transitioning to remote work may be found on our page Telecommuting Guide for Healthcare Organizations.
Who needs to be trained and/or notified of Your use of telehealth services ?
- Your patients
- Your providers
- Your staff
- Your IT service vendor if IT is not an employed staff member
- Your medical malpractice insurance provider (agent/underwriter)
Yes, if a business or entity performs functions on behalf of a covered entity where access to PHI is involved, then a BAA is recommended. While there has been relaxation of some aspects of HIPAA, many elements still apply. Refer to NORCAL Group’s Telemedicine: Risk Management Recommendations for guidance and resources associated with HIPAA enforcement during the COVID-19 pandemic.
Does HIPAA still apply and do I still need a business associate agreement?
How do I document my exam?
- Telehealth exams performed should follow the same guidelines of the standard of care and documentation should be equally as thorough with the recommendation of adding obtained consent for both the exam and billing for the exam. See NORCAL Group’s RESOURCE BUNDLE FOR COVID-19 PANDEMIC Communications and Telemedicine for risk management recommendations regarding documentation and consent, including sample forms.
- If your hardware and software devices consist of carts that allow you store the exam and then forward, be sure to perform the exam under same standard of care and combine additional documentation efforts in the EHR such as medications that were prescribed or any additional care that has been provided to the patient.
How do I bill for these exams?
- It is advisable to become familiar with state guidelines and the current state of emergency provision waivers.
- Contact your payors to understand how to bill for these services appropriately and to understand their reimbursement policies, including CPT codes and modifiers used.
- Refer to NORCAL Group’s Financial Operations for links to various sources addressing requirements for reimbursement and associated waivers for performing telemedicine services.
What happens if the equipment provided to staff is damaged, lost, stolen or misused?
- Establish policies and procedures with use of equipment to encompass training, responsibilities, HIPAA guidelines, proper and improper use parameters and penalties for misuse. Consider the use of an acknowledgement form for staff to sign to attest to their receipt of equipment, training and compliance of the policies and procedures.
- Consider liability coverage for risks associated with personnel, equipment and HIPAA/Cyber security violations.
- AMA Quick Guide to Telemedicine in Practice
- AMA Telehealth Implementation Playbook
- AAFP: Using Telehealth to Care for Patients During the COVID-19 Pandemic
Additional Resources Vendors Offering Free or Reduced Cost Platforms
These documents and links are provided for your convenience and reference only, and the provision of these materials does not mean NORCAL Group is affiliated or associated with these organizations.
- NORCAL Group: Telecommuting Guide for Healthcare Organizations
- Working from home during the COVID-19 pandemic