Prior to COVID-19 telehealth was not widely used. Practitioners who wanted to practice using telehealth, (or telepractice, the term that Speech-language pathologists use) were dealing with several barriers, including licensing, reimbursement, and privacy/confidentiality issues. While many of these barriers are slowly becoming easier to tackle, there are still many things that should be considered when managing telehealth implementation projects, and moving your practice into the virtual space.
All health practitioners must be licensed in the state that they practice. In the case of telehealth, that includes both the state where they are located and the state where the patient is located. Currently there is no nationwide or international licensing. However, there are interstate compacts which allow for ease of application. This does not exclude applicants of CEU’s (continuing education units), fingerprinting, or other requirements for a particular state. It is best policy to check the licensing compact for each practitioner type.
In 2019, there was no interstate compact in effect for speech-language pathologists, but it was in the process of being drafted. As a result of COVID-19, licensing laws are being revised. ASHA (American Speech and Hearing Association) provides information on the updates to COVID-19 regulations for Speech-Pathologists and Audiologists through this resource: https://www.asha.org/about/coronavirus-updates/.
Reimbursement of insurance providers is a sticky situation in terms of telepractice and depends on the population serviced. When focused on the geriatric population for example, it is appropriate to focus on reimbursement. Medicare, the primary insurance agency of this population, did not allow for reimbursement of any telehealth service prior to 2020. Part of this issue was regarding recognized telehealth providers. At the time, speech-language pathologists and audiologists were not recognized.
However, COVID-19 has allowed for Medicare part-B recipients to receive telehealth services. In planning a telehealth implementation project, include research with the practice’s affiliated association, and insurance (Medicare, Medicaid, and commercial insurance). Center of Connected Health Policy and Centers for Medicaid and Medicare Services (CMS) are great resources to learn about current regulations. As many of these regulations have been lifted to deal with COVID-19, it is unclear as to how long it will be in effect and is best to check these resources on a daily or semi-daily basis.
Privacy and Confidentiality
This barrier relates to PHI (Public Health Information) and keeping health records encrypted and private. Under normal conditions, such as prior to COVID-19, this included security, privacy, breach notifications. The privacy rule included a business agreement between the organization or private practice. In the security rule, it ensures that all data is encrypted with no identifiers. More information about these regulations can be found at the HIPAA Journal.
Prior to COVID-19, Skype, phone, or Zoom calls (unless they were using the HIPAA compliant version) were not allowed. Since then, regulations have been modified to allow for health practitioners to use telepractice with patients who can’t or are unwilling to have in-person visits. A critical piece of managing telehealth implementation projects will be to research the most up to date regulations in your area.
Ready to implement?
Each practice, state, and insurance is constantly going through changes as a result of COVID-19. Many practitioners are new to telehealth. Currently there are no state, national, or international training for practitioners of telehealth. There are some private universities that provide training. However, it is not consistent with every practice.
It is important to have a project manager that is patient and thorough as you navigate through this process. In addition, understand that laws and regulations are constantly changing. Use the sources above to stay abreast of new regulations, and contact CoApt Projects to connect with a experienced project manager that can help explore the options for your practice, by managing telehealth implementation projects with you.
Dr. Cybele Wu, EDD
A recent graduate of Nova Southeastern University’s EDD in Instructional Technology and Distance Education, Dr. Wu has gained expertise in various instructional design models, e-learning principles and applications, and instructional systems applications. She completed her dissertation, Utilization Efficacy Perceptions of Telepractice for Speech-Language Pathologists and University Faculty and Administrators, using a qualitative Delphi model. Though not a licensed Project Manager herself, Dr. Wu approached her dissertation much like a project that she needed to organize and manage, with different sections, participants, as well as the benefits and barriers.
Dr. Wu is interested in accessibility design, particularly in the healthcare sectors.