Operational Guidance

Patient records and other related information are protected by Health Insurance Portability and Affordability Act (HIPAA) and its governing regulations as well as federal encryption and security requirements.

Please note: Due to COVID-19, the U.S. Department of Health and Human Services Office for Civil Rights (OCR) is exercising enforcement discretion and waiving penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communication technologies. Providers are responsible for providing telehealth services in accordance with OCR’s notice.

Technical Requirements for Telehealth Visits*

• Telehealth technology must comply with HIPAA and meet security and confidentiality requirements for electronic member information set by federal and state agencies.*
• Telehealth technology must enable interactive patient-provider exchanges by transmitting audio and video in real-time. These standards align with guidelines published by the American Medical Association and Federation of State Medical Boards.

Other Telehealth Technology Considerations

There are many options for telehealth technology that can increase patient ease of use and make telehealth more integrated into the provider visit process.

• A telehealth solution that’s compatible with a wide variety of internet browsers and devices will allow providers and their patients to conduct telehealth visits from the device of their choice, such as a smartphone, tablet or personal computer. 
• Telehealth systems that integrate with an EMR system enable ease of data collection and documentation during the visit and avoid duplicate documentation.
• Telehealth solutions that integrate with a scheduling system allow scheduling staff to seamlessly schedule appointments.
• Technology solutions that offer a method for verifying patient eligibility and collecting co-payment prior to the visit make the telehealth visit workflow more seamless for the office administrative staff.

Learn more about telehealth technical infrastructure.

*Unless otherwise noted by U.S. Department of Health and Human Services Office for Civil Rights during the national public health emergency.

The health care industry is continually discovering new uses for telehealth. Each provider practice will need to decide how telehealth will fit into their clinical model and how it can be used to meet patient needs. Some common examples include*:

• Chronic condition management:
  • Newly diagnosed diabetic education
  • Routine follow-up appointments
  • Medication management and education
• Behavioral health, including behavioral health visits offered by the primary care provider:
  • Attention-deficit/hyperactivity disorder check-ins
  • Symptom tracking and medication management
  • Screenings (e.g., PHQ-9)
• Surgical follow-up:
  • Wound assessment and management
  • Wound care education
  • Care coordination
• Same-day appointments for minor illnesses and injury (low-risk urgent care)
• Transitional care management services

*Coverage for clinical services may vary by plan. 

Thoughtful incorporation of telehealth visits into a practice’s schedule and scheduling operations is integral for a successful telehealth program. You should carefully review different approaches to scheduling telehealth visits as you choose the optimal option for your practice and patients. Three common scheduling approaches include:

1. Integrate visits seamlessly within the existing schedule.

Good fit for: Low volume of telehealth encounters

This option may work best for practices that have established operational support roles of the clinic staff that can "room" patients and perform parallel roles to an in-person visit.

2. Dedicate a portion of the workday.

Good fit for: Consistent volume of telehealth encounters

Early morning or late day visit time blocks can be dedicated to patients who can’t attend appointments during traditional office hours.

3. Dedicate one team to telehealth services

Good fit for: Large volume of telehealth encounters

Within this model, the telehealth team often offers same-day and one-time services to support the primary care provider team, think of this as virtual triaging.

Schedule Telehealth Requests by Phone/Triage Line

Preparing the practice's scheduling staff to identify visit requests that are appropriate for telehealth services can be a pivotal step to successful telehealth operations.

1. Provide scheduling staff an algorithm that filters on visit type and reason for visit. Or connect with your scheduling platform representative to identify telehealth scheduling solutions and capabilities.

Some examples that can be programmed into an algorithm:

• Follow-up visits to review the impacts of medications, discuss results of a visit to a specialty provider or to adjust care plans based on patient feedback.
• Requests for same-day appointments to address sub-acute symptoms like cough, congestion, sinus pain, headache, rash, etc.
• Conditions identified by practice specialty providers such as ADHD follow-up appointments, diabetic follow-ups with endocrinologists, evaluation of chronic skin conditions, etc.

2. Verify patient eligibility for telehealth services by reviewing their insurance coverage.

3. Offer telehealth appointment as an option to the patient. Assess the patient's comfort level with telehealth and their access to telehealth technology. Determine if the patient requires translation services.

4. Schedule the visit within the practice scheduling system and note that the appointment is a telehealth visit. 

5. Provide the patient with instructions to access the telehealth visit. Provide a web address to the practice website where telehealth instructions are available and email or text an appointment confirmation with the link to telehealth instructions.

Schedule as a Follow-Up to an In-Person Visit

Scheduling telehealth visits following an in-person visit could help improve follow-up compliance and improve patient experience.

• When care providers are completing their visit with a patient, they can recommend telehealth for a follow-up visit to the in-person visit.  At this time the provider would be able to address patient concerns about the care they can receive during a telehealth visit.
• During the checkout process, the clinic front desk staff can review and mention telehealth as an option for a follow-up visit. 
• Front desk staff can schedule the telehealth visit in the practice scheduling system and note that the appointment is a telehealth visit.
• Front desk staff can also provide the patient with instructions to access the telehealth visit. Provide the patient with printed instruction to access telehealth visits and email/text an appointment confirmation with link to telehealth instructions.

Online Scheduling

Available telehealth appointment slots can be made visible to patients on a practice website or patient portal, if available. Care providers can choose to release several of their appointment slots to telehealth and allow patients to schedule through applicable online platforms.