03/17/2020

Telepsychiatry - How to Begin Delivering Services

If you are planning to implement telepsychiatry in your practice, you will need to ensure several tasks are completed - information from Victoria Kelly, MD, OPPA President.

• Both you and the patient are in Ohio. For details on how to obtain medical licenses in multiple states, consult the interstate medical license compact website, the federation of state medical boards website, or PSYPACT
• Obtain proper informed consent with a witness, including a discussion of risks, benefits, and alternatives to telehealth, and contingency plans for clinical emergencies and technical failures.
• Create a procedure for sending and receiving documents between the behavioral health provider and patient through a HIPAA compliant process (such as encrypted/password protected patient portal)
• Follow all state and federal laws, including laws related to telehealth, in-person examination requirements, prescribing, coverage limitations, privacy, documentation, and standards of care (which does not change just because the service is delivered via telehealth)
• Know your billing options and negotiate with insurers
• Have a signed Business Associate Agreement for HIPAA / HITECH compliance with your EMR or telehealth vendor / platform (if the equipment vendor stores any patient information). The 2 factors that must be in place for HIPAA compliance are end-to-end encryption (to ensure security) and a signed business associate agreement (to ensure privacy and compliance). Refer to OPPA’s Newsletter Insight Matters Volume 42, Number 2, the Fall 2017 Issue for more information about HIPAA & HITECH compliance in my Editor’s Note. (http://ohiopsychiatry.org/aws/OPPA/asset_manager/get_file/169411?ver=269)
• Notify your malpractice carrier, as they may or may not charge an additional fee, and consult an attorney for any legal issues and a risk consultant for risk management related questions
• If there are any additional questions, ask the State Medical Board of Ohio. As of October 2019, physicians wishing to provide health care via telemedicine to individuals located in Ohio may do so under their full Ohio license and no longer require a telemedicine certificate
• If you are planning to implement telepsychiatry in a hospital setting, you will have to deal with additional credentialing issues, which may lengthen the process.