– Set up a team that will help facilitate the expedited implementation of telemedicine services and be able to make decisions quickly to ensure launch as soon as possible.
– Check with your malpractice insurance carrier to ensure your policy covers providing care via telemedicine.
– Familiarize yourself with payment and policy guidelines specific to various telemedicine services.
Vendor evaluation, selection & contracting
– Check with your existing EHR vendor to see if there is telehealth functionality that can be turned on.
– Reach out to your state medical association/society for guidance on vendor evaluation, selection and contracting.
– Introducing new technology into practice quickly can be challenging, but a few things to keep in mind as you navigate a speedy implementation:
♦ Ensure HIPAA-compliance.
• During the COVID-19 emergency, physicians and practices can leverage technologies such as FaceTime, Skype, Zoom, etc. This will help speed up the implementation process. OCR guidance emphasized that physicians are encouraged, but not required, to notify patients of the potential security risks of using these services and to seek additional privacy protections by entering into Business Associate Agreements (BAAs) as able.*
♦ Make sure you understand who has access to and owns any data generated during a patient visit
♦ Get clear on the pricing structure (i.e. is there a monthly flat rate for using the technology or is it per call or per visit?)
♦ Recognizing that many physicians and care teams are working remote, the AMA and American Hospital Association created guidance to help you ensure your personal and home devices are secure.
* Given the special circumstances of the COVID-19 pandemic, the federal government has announced that the Office for Civil Rights (OCR) will exercise its enforcement discretion and will not impose penalties on physicians using telehealth in the event of noncompliance with regulatory requirements under the Health Insurance Portability and Accountability Act (HIPAA) in connection with the good faith provision of telehealth during the COVID-19 national public health emergency.
– Leverage resources available at the American Telemedicine Association to identify possible vendors to work with. Some are actively supporting quick and effective use of telehealth services. Additionally, ATA, in collaboration with the Consumer Technology Association, created a Digital Health Directory to support identification of various digital health technologies including telemedicine.
Workflow & patient care
– Determine protocols for if/when a telehealth visit is appropriate up front and train clinicians, care team members and schedulers. Consider a short survey or set of questions that patients can either answer electronically or over the phone when your patients are scheduling to properly triage.
♦ If you know your payer mix, consider reaching out to the payer with the highest percent of your patient population to discuss telehealth coverage, even if temporarily due to current events.
– Determine when telehealth visits will be available on the schedule (i.e. throughout the day intermixed with in-person visits or for a set block of time specifically devoted to virtual visits).
– Set up space in your practice to accommodate telehealth visits. This can be an exam room or other quiet office space to have clear communication with patients. If multiple members of the care team will be helping to facilitate telehealth visits, ensure they know where to support the set-up of the technology and communicate with patients virtually.
– Ensure you are still properly documenting these visits – preferably in your existing EHR as you normally would with an in-person visit. This will keep the patient’s medical record together, allow for consistent procedures for ordering testing, medications, etc. and support billing for telehealth visits.
♦ Ensure you receive advanced consent from patients for telemedicine interactions. This should be documented in the patient’s record. Check to see if your technology vendor can support this electronically.
– Let your patients know the practice is now offering telehealth services when they call the office. Have your office staff help support pro-active patient outreach. Additionally, post announcements on your website, patient portals and other patient-facing communications.
♦ Have a plan for supporting patients on how to access telehealth visits based on your practice’s technology and workflow to keep the clinic flow moving and avoid disruptions to care.
– Download the workflow tools and resources.
♦ Telehealth workflow best practice (PDF), ensuring your workflow addresses the entire life cycle
♦ Key considerations when designing a telehealth workflow (PDF), key questions and criteria for designing a workflow
♦ Telehealth workflow example (PDF), sample flow for scheduling, check-in, visit, and post-visit
♦ Telehealth etiquette checklist (PDF), tips on conducting a successful telehealth visit
♦ Patient take-home prep sheet (PDF), patient education on telehealth, how it works and how to prepare/what to expect from your appointment