Telehealth Policies and Procedures
Definitions
1. Telehealth, Telebehavioral Health, Telemental Health and Telemedicine: These terms are used interchangeably at Solutions Counseling and Assessment. All terms describe the use of digital technologies to deliver substance abuse services by connecting multiple users who are physically located in separate locations. Treatment information is exchanged from one site to another via electronic communications to improve a client’s health status.
2. Distant Site: This is the location where the client is located at the time of service delivery. For all telehealth visits/sessions, the client may be located anywhere in a private area as long as they are in the state of Tennessee.
3. Originating Site: This is the location where the licensed provider is located at the time of service delivery. This could be an office location or another site that has been pre-approved. The requirements for this site will be that:
the provider can attest to maintaining confidentiality and the privacy of the client as well as the security of client’s PHI.
The location is in the state of Tennessee
Procedures for Substance Abuse Service Delivery
1. Telehealth will be delivered through Zoom, which is HIPPA compliant. Use of any other platform for service delivery is strictly prohibited.
2. Clients will need to be informed of all the telehealth procedures the provider will utilize, including those in this policy. Verbal informed consent must be obtained prior to any telehealth service delivery.
a. Clients may be asked to show a government-issued ID at the first telehealth session to verify identity
3. Originating Site: Telehealth sessions for substance abuse services will be conducted in a private, confidential manner. Providers will be expected to ensure that at their site:
a. Internet connectivity is through a secured network, not an “open” network such as those found in coffee-shops, libraries, etc.
b. Sessions cannot be overheard by others such as family members, guests, colleagues, or others
c. The session is conducted in a quiet setting
d. The backdrop of the provider’s image will show a professional setting, free
from clutter in the background, and have adequate lighting to ensure the provider’s image is broadcast clearly to the client
e. Provider telepresence includes the following: leaning forward towards the camera, not leaning back in the chair, and to look into the camera not down or at other things in the room.
4. Distant Site: The client will be informed at the initial contact of the provider’s expectations regarding where the client is physically located during sessions. Lighting at the distant site should be assessed during the initial session to allow for full access to client facial expressions and body language. These locations are considered unsupervised settings and have an increased risk of confidentiality being breached. To minimize this risk:
a. At the initial visit, screening, or intake, the client will agree to conducting sessions in a reasonably private and quiet setting;
b. The client will understand the difference between secure versus open networks if using wireless capabilities; alternatively, the provider may assess the network security by asking the client certain questions
5. Safety Protocols:
a. Safety Plans: Each provider is expected to review a plan for safety with their telehealth clients at the initial session and briefly at the outset of every session. Each session must contain a brief review of the safety plan and be documented. Items to include are:
i. Physical location of the client during the telehealth session;
ii. Client Privacy: Reasonable assurance that the client is in a private setting. If necessary, you may conduct a room check with a 360-degree view with the camera on the client-side;
iii. Access to firearms, risk assessment;
iv. Potential for domestic violence, risk assessment;
v. City and nearest hospital to client location, emergency contact if applicable;
vi. Code word to stop the session;
vii. Access to drugs/alcohol, risk assessment;
viii. Suicidal/Homicidal risk assessment, as necessary.
6. Emergency Procedures:
a. De-escalation procedures: The provider will be trained through CE hours in de-escalation procedures;
b. Medical emergencies: The provider will be trained through CE hours in medical emergency procedures
c. Mandated reporting such as for vulnerable adults and child abuse and neglect: providers have the same mandate for telehealth as they do for in-person settings
d. Aggressive or threatening behaviors: providers will attempt to de-escalate the client. If another person is involved on the client-side, the provider will notify the client’s local police department or sheriff's office.
e. Physically intoxicated individuals who demonstrate signs of withdrawal: if medically necessary, the provider may need to call 9-1-1 and send emergency personnel to the client location.
f. Uncooperative Clients during an emergency: If clients become uncooperative during emergencies, the provider may need to contact the local authorities.
7. Actively Suicidal/Homicidal Clients: If a client expresses suicidal or homicidal ideation or intent during a telehealth session, the provider will assess the severity of the situation and determine next steps. If the assessment determines that an intervention is necessary:
a. The provider will keep the client online, in a live, two-way interactive video
b. The provider will concurrently notify the local authorities, mobile crisis, and/or 9-1-1 (if deemed appropriate) and provide client location
c. The provider will remain with the client in a live, two-way interactive video until appropriate professionals arrive to care for the client.
d. In the event of a group member having a crisis, the provider will have all other group members leave the session and points a and b will still apply.
8. If the technology fails during the session, the provider will call the client to explain the problem. Depending on the situation, the session may need to be rescheduled:
a. If the technology failure happens in the first half of the session and it is on the provider end, the provider may reschedule the client session and issue a refund if necessary.
b. If the session is more than 50% completed when the technology fails and it is on the provider end, the provider may finish the session via telephone, or reschedule the remaining time at a later date.
c. If the technology failure happens at any time during the session and it is on the client end, the provider may attempt to reschedule, but no refunds will be given and appropriate client fees may apply.
9. Clients who are deemed not conducting themselves in a respectful manner, breaking rules, or, otherwise, not conducive to recovery will be kicked out of their respective session and a refund will not be given.
10. At any time, the provider may determine that telehealth services are not benefiting the client, that the client is not a good candidate for telehealth or circumstances have arisen where a referral to face-to-face service delivery is warranted. The provider will make this recommendation verbally to the client, put it in writing in the client’s electronic file, and provide arrangements or referrals upon request of the client.
Procedures with the Originating Site
1. Telehealth sessions are limited to those who are clients of Solutions Counseling and Assessment.
2. Telehealth sessions will be conducted at an originating site that is set up to provide secure telehealth service delivery.
3. Telehealth will be delivered through Zoom, which is HIPPA compliant. Use of any other platform for service delivery is strictly prohibited.
4. Clients will schedule themselves for specific services through the software installed on the originating site’s website.
a. Clients will be sent an email to confirm their telehealth appointments
b. All other ongoing telehealth sessions will work in the same manner
5. Emergency Procedures: All Emergency policies and procedures for the originating site will be followed. These include, but are not limited to:
a. De-escalation procedures
b. Medical emergencies
c. Mandated reporting such as for vulnerable adults and child abuse and neglect,
d. Aggressive or threatening behaviors, and
e. Physically intoxicated individuals who demonstrate signs of withdrawal.
7. Actively Suicidal/Homicidal Clients: If a client expresses suicidal or homicidal ideation or intent during a telehealth session, the provider will assess the severity of the situation and determine next steps. If the assessment determines that an intervention is necessary:
a. The provider will keep the client online, in a live, two-way interactive video
b. The provider will concurrently notify the local authorities, mobile crisis, and/or 9-1-1 (if deemed appropriate) and provide client location
c. The provider will remain with the client in a live, two-way interactive video until appropriate professionals arrive to care for the client.
d. In the event of a group member having a crisis, the provider will have all other group members leave the session and points a and b will still apply.
8. If the technology fails during the session, the provider will attempt to call the client to explain the problem. The provider will then inform the client of the problem and assist the client in next steps.
9. Clients who are deemed not conducting themselves in a respectful manner, breaking rules, or, otherwise, not conducive to recovery will be kicked out of their respective session and a refund will not be given.
10. At any time, the provider may determine that telehealth services are not benefiting the client, that the client is not a good candidate for telehealth, or circumstances have arisen where a referral to face-to-face service delivery is warranted. The provider will make this recommendation verbally to the client, put it in writing in the client’s electronic file, and provide referrals upon request of the client.
Payment and Refund Policies and Procedures
1. Payments in full are required at the time of service and will be transacted through safe and secure online payment software within the website of the originating site.
2.Clients are not required to pay in advance of the scheduled service and are not encouraged to in case clients fail to show up for their scheduled appointments.
3. Appointments that are already paid for in advance by the client (or another party) to which the client fails to attend generally will not be refunded. The provider reserves the right to review these instances on a case-by-case basis.
4. If the technology fails during the session, the provider will call the client to explain the problem. Depending on the situation, the session may need to be rescheduled:
a. If the technology failure happens in the first half of the session and it is on the provider end, the provider may reschedule the client session and issue a refund if necessary. A refund will be made through the same software used to make the payment. Please see the originating site’s website’s payment system’s policies and procedures page
b. If the session is more than 50% completed when the technology fails and it is on the provider end, the provider may finish the session via telephone, or reschedule the remaining time at a later date and no refund will be necessary.
c. If the technology failure happens at any time during the session and it is on the client’s end, the provider may attempt to reschedule, but no refunds will be given and appropriate client fees may apply.
5. Clients who are deemed not conducting themselves in a respectful manner, breaking rules, or, otherwise, not conducive to recovery will be kicked out of their respective session and a refund will not be given.
6. At any time, the provider may determine that telehealth services are not benefiting the client, that the client is not a good candidate for telehealth, or circumstances have arisen where a referral to face-to-face service delivery is warranted. The provider will make this recommendation verbally to the client, put it in writing in the client’s electronic file, and provide referrals upon request of the client. Clients will not be refunded for services already obtained.
Zoom Delivery
Zoom does have a mobile feature that may be used on smartphones, tablets, laptops, and iPads. If the provider chooses to use one of these devices, the device must have the following security features installed and operational on them:
1. Password protected, preferably two-factor authentication is to be used
2. Device has had updates and security patches installed at least once/month
3. Software updates are conducted quarterly
4. Please refer to Zoom’s Device Management Policy and Procedure in the HIPAA Policy and Procedures Manual
5. All HIPAA Administrative, Technical and Security Standards are met and followed