decisionhealth Newsletters, Coder Pink Sheets - 2020 Issue 5 (May)
Compliance: 7 answers to emergency telehealth expansion compliance questions (online only)
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Article Overview
This article explains the compliance issues practices faced when rapidly expanding telehealth during the COVID-19 public health emergency. It discusses federal guidance from HHS agencies, HIPAA enforcement discretion, state licensure concerns, payer reimbursement considerations, and questions around cost-sharing waivers. The piece is aimed at practices, compliance staff, and clinicians trying to understand how emergency telehealth policies affected operations and billing.
Why This Topic Matters
Providers moving quickly into telehealth needed to balance access to care with privacy, licensure, reimbursement, and fraud-and-abuse compliance requirements. The article helps readers understand the major federal and operational issues that shaped emergency telehealth implementation.
Article Sections
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Emergency telehealth compliance overview
Introduces the compliance context for rapid telehealth expansion during the COVID-19 emergency and the federal agencies involved.
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Common risks for practices new to telehealth
Covers general operational and privacy concerns that can arise when a practice quickly begins providing telehealth services.
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Smartphone-based telehealth precautions
Addresses considerations associated with using mobile devices for remote patient communication.
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Risk comparison for practices already using virtual services
Discusses how existing telehealth workflows and infrastructure affect a practice’s exposure and preparation.
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OCR enforcement discretion
Explains the federal privacy enforcement posture during the emergency and what that meant in general terms.
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Non-HIPAA compliant platforms and related risks
Reviews the broader risks associated with unsecured telehealth platforms and potential reporting implications.
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Scope of the telehealth enforcement notice
Clarifies the general scope of the federal telehealth discretion described in the article.
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Copay waiver flexibility
Summarizes the discussion of temporary flexibility around cost-sharing waivers and related compliance concerns.
What You Will Learn
- The main compliance risks associated with emergency telehealth expansion
- How federal privacy enforcement discretion affected telehealth operations during the COVID-19 emergency
- Why state licensure and payer rules still mattered for telehealth programs
- What operational issues practices needed to consider when using unsecured technology
- How cost-sharing waivers were discussed in relation to federal healthcare programs
Who Should Read This
- Physician practices
- Compliance officers
- Billing and reimbursement staff
- Healthcare administrators
- Telehealth program managers
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