Telehealth Policy and Procedures
for Choosing Connection Counseling, Inc.
Stella “Sahar” Jones, MA, LMFT
Policy
The telehealth policy at Choosing Connection Counseling, Inc. (hereafter referred to as “CCC”) is to provide telehealth as an option for health care service delivery to enhance access in ways that are convenient, safe, and equitable for our patients. All administrative, billing, communications, and clinical services to facilitate telehealth appointments are rendered by the owner and sole proprietor of CCC, Stella “Sahar” Jones, MA, LMFT (hereafter referred to as “the clinician”).
Terminology
Telehealth. For purposes of this policy and procedure, by telehealth we mean the discrete set of codes promulgated by the Centers of Medicare & Medicaid Services (CMS) that can either be provided in-person or by using an interactive audio and video telecommunications system that permits real-time communication between the clinician at the distant site and the beneficiary at the originating site.
Distant site. CCC is the distant site when we deliver telehealth services to patients who are at a different location, including their home.
Originating site. This is the site where the patient is and may be when:
We deliver telehealth services to a patient at a different location, including their home – either of which would be the originating site, or
A clinician/specialist delivers telehealth services to a patient at their clinic, making that clinic the originating site. CCC does not offer appointments at a physical location at this time.
Procedures Scheduling as Originating Site
When a patient is scheduled to receive telehealth services from CCC, the clinician will conduct all appointments from a private space, via web camera and microphone. To ensure HIPAA compliance, the clinician will confirm that the patient is also in a private space with access to a functioning web camera and microphone, either on a computer, tablet, or phone. The patient will be advised to begin preparing for the appointment 15 minutes prior to the appointment to set up and test the equipment. The clinician will be familiar with the platform used to conduct the appointment and will be able to support the patient with technical difficulties.
Prior to the visit, the clinician will ensure that:
The clinician has been e-faxed or otherwise provided with the medical records needed for the visit while adhering to the HIPAA Privacy rule governing “minimum necessary” when providing records/information.
The clinician is clear on their roles and responsibilities, especially around consent, documentation and payment.
A referral order has been entered so the clinician can close the loop and ensure that our ordering clinician has signed the referral notes/results.
The patient(s) have had their information entered into the EHR system SimplePractice, have had a clinical chart created, and have been sent and given sufficient time (at least 12 hours before the appointment time unless this timeframe is waived by the patient) to review and sign intake paperwork.
The patient(s) have been informed of all session fees prior to beginning services with the clinician, including any co-payments when using insurance, and provided with a Good Faith Estimate prior to beginning treatment. Patients will be informed that all fees will be processed through secure Stripe transaction via the EHR platform SimplePractice, and are due at time of service.
Scheduling as Distant Site
When a patient contacts CCC to schedule an appointment they will be offered a telehealth visit, or the option for referral to an in-person provider within the clinician’s professional network who offers similar services.
If the patient chooses to proceed with telehealth services with CCC, the clinician will administer a questionnaire to establish whether the reason for the visit and/or chief complaint is appropriate for telehealth services.
Once telehealth services with CCC have been approved as a mode of service for the client, the clinician will deliver the standard script indicating that the telehealth appointment is made, based on information provided in the questionnaire and that if conditions change the patient may need to be seen in person or seek urgent/emergent care.
The clinician will also provide additional scripting to ensure patients are clear on the expectations (i.e., must have a quiet place to participate in the telehealth visit, no multitasking) and the cost requirements, as patients are often surprised when the cost/reimbursement for a telehealth visit is the same as an in-person visit.
If the patient is a minor, the clinician will follow guidance from the Oregon Health Authority (OHA) covering when minors seek health care services.
The clinician will ask “Do you have a smartphone, tablet, or desktop computer with camera and internet?” If patients have one of the three, they are considered “video-capable” and will be offered a video appointment, rather than a phone appointment, unless they are unable to participate in video calling for medical/disability and/or safety reasons.
The clinician will note video capability in the patient’s chart. The patient will be sent appointment confirmation by email or text, depending on patient preference, with date/time of appointment, link for telehealth visit and instructions for connecting, and an offer for a “test” telehealth visit.
All telehealth appointments will be initiated and conducted using the EHR platform SimplePractice. All appointment reminders, session video links, and encrypted messages will be provided through SimplePractice.
In the event of a connection failure with SimplePractice, the clinician will offer to continue the session over Zoom. In the event of total failure of video capability, the clinician will offer to continue the session via phone call.
Unless otherwise specified, recommended by the clinician, or requested by the client, all standard individual and couple/family telehealth sessions will range between 53 - 60 minutes. Free initial telehealth consultations are 15 - 20 minutes.
Before Visit
Within three business days of the telehealth visit, the patient will receive an appointment reminder per their preferences – call, email, text or portal message.
The clinician will confirm that all intake paperwork has been completed and signed by the patient(s) prior to beginning services.
The clinician will review intake documents completed by the patient(s) and identify all current preventive and chronic gaps in care to discuss with patient during the initial assessment.
The clinician will identify any outstanding orders or referrals to discuss with the patient to determine the status – pending, need to cancel, waiting for referral notes/results, etc.
Day of Visit
The clinician will:
Clearly introduce themselves to the patient(s) and wear or otherwise display their first and last name and credentials.
Confirm the patient’s identity – name, date of birth, etc.
Conduct intake, including the portions usually performed by reception staff for in-person visits.
Advise the patient how to make their copay, when applicable.
Discuss back-up plan for if the audio or video fails or the technology otherwise is not working for the patient or the care team, including a number to call the patient or for the patient to call the clinic.
Confirm and document the patient’s physical location in case emergency or other services need to be called to assist the patient in the event of serious signs or symptoms.
Obtain consent for the telehealth visit, depending on patient’s primary insurance:
Medicare → Medicare requires beneficiary consent — verbal or written — for telehealth and other virtual services as well as notification of any applicable cost sharing, including potential deductible and coinsurance amounts. Consent must be documented in the patient’s medical record.
Medicaid → Medicaid requires beneficiary consent — verbal or written — for telehealth and other virtual services as well as notification of any applicable cost sharing, including potential deductible and coinsurance amounts. Consent must be documented in the patient’s medical record.
Commercial and other insurers → Varies by insurance provider. If no consent is noted, the clinician will obtain the state-required telehealth consent.
Take psychotherapy notes during the appointment to facilitate accurate and expedient clinical documentation of services.
Perform check-out with the patient at the conclusion of the visit as per the standard procedure for in-person visits, including asking the patient if they have any additional questions about their treatment plan and scheduling any follow-up or other visits.
Clinically document the appointment as per requirements for the given type of visit (e.g., evaluation and management/office visit) and documentation standards for insurance being billed.
Enter the appropriate billing code with modifiers, etc., depending on insurer.
After Visit
The clinician will:
Provide visit notes/summary to patient as requested by patient, per patient’s preference (text, email, portal, etc.)
Follow up on all orders/referrals, etc.
Ensure patient is clear on co-payment/deductible amounts and how to pay.
Send any relevant supplemental information/reference materials per patient’s preference (text, email, portal, etc.)
HIPAA Privacy
The patient(s) will be advised to use headset/ear buds to assure their privacy, and must identify for the clinician any other individuals that are present.
The clinician must be in a private space (e.g., exam room or office) or wear headset/ear buds. The clinician’s video screen, clinical documentation, and records of the patient’s protected health information (PHI) must not be viewable or accessible by any other individuals unless authorized by signed release of information with the client, and must be secured by at least two modes of encryption (i.e. door/file lock, computer password, EHR login) while not actively in use.
HIPAA Security
All efforts have been made to ensure the security of patient’s protected health information (PHI) through use of HIPAA-compliant devices and telehealth platforms for both the patient and clinical staff. The clinician has signed business associate agreements with all telehealth platform vendors or others that may create, receive, maintain or transmit electronic protected health information (ePHI) as part of CCC’s telehealth processes to ensure HIPAA compliancy. All other contingencies have been made; the clinician has reviewed our policies and procedures to ensure that we are HIPAA-compliant and have mitigated any risks, including updating the security risk analysis with any changes resulting from the use of telehealth.