Growing reliance on telehealth services has led many Accrediting Organizations (AOs) to offer specialized accreditation in telehealth programs.
Having an accredited telehealth program can be a strong mark of excellence for a behavioral healthcare provider. It can reassure potential service recipients about the quality of services offered and establish a competitive edge in the market.
Polls tell us that increasing numbers of patients and clients consider telehealth services when evaluating providers. With advantages like access to care outside of normal office hours, continuity of care, and a reduced travel burden on the care recipient, quality telehealth programs are highly desirable.
Growing consumer demand makes telehealth accreditation appealing to payers as well.
Telehealth compliance considerations
If your organization is considering telehealth accreditation, you’ll want to make certain to identify and address any staffing, billing, or technology concerns that may impact the quality of your telehealth services.
- Does your technology platform integrate with the EHR? Is it easy for service recipients to use? What kind of orientation do you provide to them?
- Has your staff received adequate telehealth training?
- Do clinicians understand documentation requirements?
Do your billers fully understand telehealth billing and reimbursement timeframes and requirements? I’ve previously written about the seven riskiest billing practices generally associated with fraud and abuse in telehealth. Read my report here.
Telehealth licensure can get tricky
Licensure considerations for telehealth are also important—and can be somewhat challenging, as regulations vary widely from state to state.
Health professionals must meet the licensure requirements of the state where they are located as well as requirements for the state where the service recipient is located if those locations differ. Generally, this means providers have met examination requirements and passed background checks for both states. However, there are many exceptions in which arrangements are made between states. This often happens between states sharing a common border. Sometimes multiple states work together in licensure compacts to streamline the licensing process for providers, allowing out-of-state providers to practice telehealth.
Make certain your organization fully understands the requirements for your state and any other states in which it practices telehealth and has completed all registration requirements. States may have different continuing education requirements, and annual fees may be required.
The AO will look closely at these telehealth areas
When evaluating your telehealth organization’s telehealth program for accreditation, AO surveyors most likely will look carefully at:
- Your Emergency Plan. What will happen if an emergency situation interferes with normal telehealth operations? Make certain you have a documented plan to minimize patient impact in an emergency situation. The plan needs to address systems and processes and needs to be tested at least every other year.
- A full risk assessment by an objective reviewer. Can you show that data storage, gathering, and transfer processes have been assessed for risks and vulnerabilities by an impartial body?
- Equipment. Bandwidth, quality of connection, and how well your telehealth equipment works are all important to the quality of the telehealth encounter.
- Credentialing. Are credentials up to date? And, just as important, are credentialing files in order? Policies and personnel files should clearly reflect credentialing requirements and current status.
- Patient consent. Expect the AO to check a random sample of your patient or client records for consent documentation, including consent for consultation of care via a virtual encounter.
- Training. Technology proficiency training is an important component of a telehealth program. Does your organization provide training to all providers involved in the delivery of telehealth services?
- Performance indicators. The AO will audit patient or client files to evaluate how well your organization documents encounters, including diagnosis, procedures, treatment, etc. Documentation needs to clearly identify the type of telehealth encounter that occurred. Was it audio only? Audio-visual?
- Documentation. The AO will audit patient or client files to evaluate how well your organization documents encounters, including diagnosis, procedures, treatment, etc. Documentation needs to clearly identify the type of telehealth encounter that occurred. Was it audio only? Audio-visual?
- Performance indicators. The AO will audit patient or client files to evaluate how well your organization documents encounters, including diagnosis, procedures, treatment, etc. Documentation needs to clearly identify the type of telehealth encounter that occurred. Was it audio only? Audio-visual?
Telehealth and privacy
Even if your organization does not opt for a specific telehealth accreditation, your telehealth program will be scrutinized to ensure it meets all privacy and security requirements. For example, AO surveyors will examine privacy and security practices to ensure compliance with Health Insurance Portability and Accountability Act (HIPAA) regulations.
Providers of substance use disorder (SUD) services will also have to meet the new 42 CFR Part 2 regulations I have previously written about. (If you missed those posts, you can read them here.)
Start with a full compliance assessment.
A full compliance assessment is an excellent first step on your journey to telehealth accreditation. A qualified and objective firm like SimiTree can identify potential privacy, security, and safety vulnerabilities.
The assessment will also identify issues with telehealth policies and processes that need to be strengthened, streamlined, and secured for full risk management. Key areas evaluated include regulatory and business requirements, professional oversight, quality and patient safety, and clinical workflows.
Here are a few other ways our experienced compliance experts can help your organization with its telehealth compliance:
- Our HIPAA Privacy Assessment can help providers serving patients through everyday communications technologies ensure that all standards of the HIPAA Privacy and Security Rules are met.
- New to Medicare billing? Our knowledgeable consultants can help with Medicare enrollment for behavioral healthcare practitioners and set in place effective billing controls to avoid improper practices. Our billing compliance experts can insulate your organization against audit scrutiny.
- Maintain compliance with accurate documentation and billing practices. Our certified healthcare compliance experts can review clinical documentation to identify areas of risk and provide the training needed to help your organization mitigate risk.
Reach out to us today, and let’s work together to shore up your organization’s records confidentiality, meet HIPAA privacy and security requirements, and align your compliance program with the OIG's most recent compliance guidance issued in November 2023.
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Have a compliance question?
SimiTree’s certified healthcare experts can help! Our team consists of former auditors and surveyors from various healthcare settings. We have the know-how and experience to help your organization mitigate risk. Reach out to us today with all your compliance needs.
J’non Griffin serves as Senior Vice President for the Compliance as well as Coding divisions at SimiTree. With a healthcare career that spans three decades, she has a track record of helping many provider types implement effective compliance programs. She has worked with organizations nationwide to develop compliant emergency preparedness and operation plans, implement fully compliant plans of care, and meet regulatory demands. As an AHIMA ambassador, Griffin was instrumental in preparing the coding community for the launch of ICD-10.