Telehealth and COVID-19: Guidance for Behavioral Health Providers

As COVID-19 puts increasing strain on the healthcare system, the CDC is strongly encouraging individuals with preexisting behavioral health conditions to closely monitor new or worsening symptoms and continue with their treatment. But with much of the country under quarantine orders, many patients in need of behavioral health services may not be leaving their homes to access care.

Fortunately, many services can be provided via telehealth, and behavioral health providers must quickly assess their existing capabilities to offer virtual care, troubleshoot any potential operational challenges, and provide guidance to their patients about how to continue to access services.

Confirm Telehealth Platform and Navigate Payer Guidelines

Providers should first review their existing virtual health infrastructure and confirm which services can be offered via digital means. For providers who had telehealth capabilities in place prior to the pandemic, the focus may center on operational challenges (discussed below). Providers who are new to telehealth must determine their options, which may vary based on payer guidelines.

Telehealth guidelines under Medicare have changed due to the US Department of Health and Human Services (HHS) reducing restrictions as a result of COVID-19 (Medicare Advantage plans have increased flexibilities related to telehealth, with payer discretion on service offerings). For commercial populations, providers will need to reach out to payers to determine telehealth policy updates and confirm that they will be reimbursed for delivering services through telehealth. This information can be accessed on a payer’s website or by contacting a payer representative. (ECG has summarized national commercial payer telehealth and COVID-19 coverage policies, but you should still reach out to your regional payer representatives as policies are being updated frequently.)

Regardless of the payer, make note of guidelines in the following key areas:

Technology Platforms: The approved platforms through which reimbursable telehealth services can be provided to Medicare beneficiaries have been expanded to include common video applications such as Skype and Apple FaceTime. Only some commercial payers have issued formal guidance on whether they intend to apply HHS’s guidelines for commercial and Medicare Advantage member benefits. Applying these guidelines would reduce restrictions that allow the use of nontraditional virtual care platforms to deliver reimbursable services during this emergency period.

Call payers and confirm telehealth platform requirements. Providers without a telehealth platform currently in place may find it difficult to get a commercial payer–compliant system set up quickly, especially if payers are unwilling to be flexible about the which platforms can be used to deliver reimbursable services. In this scenario, there are two options for providers to consider:

• Navigate a patient to an in-network provider that is already set up to provide telehealth services.
• Offer to provide services to a patient as self-pay, which can be delivered through the patient’s platform of choice.

Provider Attestation: Check whether providers’ attestation requirements for commercial member telehealth visits will be waived. The attestation process can be slow, and under the present circumstances, time is of the essence. Call your payer representative to confirm the status of provider attestation requirements.

Site of Service:Traditionally, Medicare telehealth services were only available to patients in certain rural geographies and had to be conducted from approved originating sites. Effective for services provided after March 6, the site-of-service requirements have been removed for Medicare beneficiaries through the remainder of the public health emergency, permitting telehealth services to be received from any healthcare facility or from home. As providers and patients stay home, monitor commercial payers’ changes to telehealth site-of-service requirements for commercial and Medicare Advantage members.

Billing: The services that can be provided to Medicare beneficiaries via telehealth have also been expanded to include behavioral health counseling. Billing for commercial payer and Medicare Advantage behavioral health counseling telehealth services has not changed as a result of COVID-19, and providers will need to continue to bill using the telehealth modifiers of GT/GQ.

Assess Operational Challenges Related to Telehealth

Once you have a telehealth platform up and running, challenges may emerge due to the transition to telehealth as the primary service delivery method. Key operational considerations relating to capacity, system coordination, and hardware must be taken into consideration.

Provider Training:Providers might need something of a crash course in providing services via telehealth. The patient-provider interaction through telehealth will be different than in person—adjusting webcams to eye level, paying attention to eye contact, determining the background of the video, and clarifying when to look at notes can help improve the patient experience. Sharing best practices for providing virtual services will lead to minimal distractions for the patient and allow for high-quality service delivery.

Confidentiality: Managing confidentiality while delivering services in a home environment may pose challenges for some providers. HHS encourages providers to notify patients that third-party applications (such as FaceTime or Skype) may have potential privacy risks and suggests that providers enable all available encryption and privacy modes.

Scheduling: Managing remote scheduling may pose new challenges for provider groups, as scheduling processes may need to be modified. Can an online platform be set up, or can scheduling be completed by staff remotely through existing systems? Establish a central line for scheduling appointments if staff are not working in the clinic. Setting up and outlining a scheduling process for patients and providers will ensure minimal disruptions to service delivery.

System Coordination: The transition to telehealth may require providers to coordinate and access electronic health records to appropriately document care, develop a process for following up on and refilling prescriptions, and ensure adequate support is available for technology issues.

Provider Shortages: The behavioral health workforce may experience initial challenges as some providers face delays in getting set up to deliver care via telehealth. Coordinating care with another in-network provider can allow for continuation of services during the transition period. Future considerations include potential provider shortages due to illness or other COVID-19 obligations. Develop a plan for shifting workloads and managing demand to ensure patients receive the behavioral health care they require.

Adequate Hardware: Some inpatient behavioral health services have an outpatient component that can be provided via telehealth if enough hardware is available to facilitate the services virtually. For example, in the delivery of inpatient or residential substance abuse disorder treatment services, the individual, group, or family therapy component could be provided via telehealth if therapists are unable to visit the facility in person. To successfully provide this virtual care, the facility must have enough hardware (e.g., phones/computers/iPads) for the patients to use that is coordinated with the therapist’s virtual platform.

Notify Patients and Stay Up to Date

CMS is actively encouraging providers to notify their patients that services are available via telehealth. Behavioral health providers can contact patients to let them know about the transition to telehealth and to relay relevant payer information regarding expanded telehealth benefits.

Meanwhile, it is important to note that commercial payer requirements are continually changing. As payers update their policies, it is necessary to stay up to date on the telehealth guidelines, tracking and monitoring payer policies to ensure your practice is in compliance.