Healthcare systems and individual hospitals can evaluate their very own metrics against industry data to evaluate cost and revenue implications of an investment in on-demand telepsychiatry.

(October 22, 2020) – Array has launched a customized capability using a value calculator to help hospitals and healthcare systems evaluate costs associated with their current process for managing behavioral health patient demand against savings and revenue opportunities.

The unique tool responds to a long-standing need for hospital administration to quantify the expected return on investment of behavioral health coverage via on-demand telepsychiatry. This new capability comes at a critical time as the industry faces unexpected operational and financial challenges. Many facilities are seeing a rise in demand for mental health services, while a simultaneous drop in ED visits in the wake of COVID-19 is presenting financial strain.

Array Behavioral Care Begins Offering Customized ROI Assessments to Help Healthcare Systems Measure Financial Impact of OnDemand Telepsychiatry

For hospitals and healthcare systems considering on-demand telepsychiatry to meet growing patient need for mental health services, implementing a financially sustainable and scalable program is essential:

  • 25% of all emergency department visits are due to behavioral health issues
  • 3X longer emergency department boarding times for mental health admissions vs. non-mental health admissions

On-demand telepsychiatry can have a positive financial ripple effect that extends well beyond emergency departments, including reduced reliance on scarce inpatient psychiatric resources, reduced inpatient psychiatric admissions, improved emergency department throughput and increased capacity for med-surg admissions. It allows healthcare systems to allocate resources to populations with heightened need and acuity to reduce strain on clinicians and improve operational metrics.

Array Behavioral Health Calculator

Array's value calculator uses proprietary logic based on more than two decades of experience implementing programs and delivering telepsychiatry services within hospitals and health systems. Customizable to organizations of all sizes, the tool uses validated data, clinical research and demonstrated outcomes to help organizations determine the financial impact of on-demand telepsychiatry applied to their specific use case. It takes into account actual direct and indirect costs using current behavioral health demand within the facility in order to quantify specific areas of cost savings and highlight untapped revenue opportunities.

Using key data on current behavioral resources and gaps, such as patient length of stay, bed capacity and existing clinical coverage, hospitals and health systems can:

  • Isolate specific metrics that impact overall cost of care to understand where and how telepsychiatry can drive savings
  • Compare actual data against industry benchmarks to evaluate the broader impact of telepsychiatry on operational, financial and clinical outcomes
  • Validate where and how on-demand telepsychiatry is appropriate in a variety of applications across the health system
  • Provide a clear, customized picture of potential ROI to aid in decision-making and the development of a justifiable business case

“We understand the key role on-demand telepsychiatry can play in helping hospitals deliver financially sustainable care, but it has typically been challenging for leadership to quantify its impact at a detailed level,” says David Cohn, Chief Growth Officer at Array. “Now, this capability allows us to collaborate with healthcare organizations and give them a fresh, detailed view of their current cost exposure and expected operational outcomes and financial returns from on-demand telepsychiatry programming.”

Request a Customized ROI Assessment Now

About Array

Array Behavioral Care is the leading and largest telepsychiatry service provider in the country with a mission to transform access to quality, timely behavioral health care. Array offers telepsychiatry solutions and services across the continuum of care from hospital to home with its OnDemand Care, Scheduled Care and AtHome Care divisions. For more than 20 years, Array has partnered with hundreds of hospitals and health systems, community healthcare organizations and payers of all sizes to expand access to care and improve outcomes for underserved individuals, facilities and communities. As an industry pioneer and established thought leader, Array has helped shape the field, define the standard of care and advocate for improved telepsychiatry-friendly regulations. To learn more, visit www.arraybc.com.

More clinicians are choosing to work in telehealth than ever before. As the industry matures and more competitors enter the market, clinicians have more options in where they chose to work.  What makes them choose one provider organization over another?  

Telepsychiatry is changing the way mental health services are being delivered. Telepsychiatry not only transforms access to care for patients, but it also offers clinicians unparalleled job flexibility and opportunities for growth.   

The clinician network at Array continues to grow rapidly as we regularly add new psychiatrists and other behavioral health professionals to our team. In the past 6 months, more than 200 clinicians and 18 supporting administrative members have joined our teamIn addition to these new hires, we have numerous existing clinicians who have been with our organization for many years.  

These new and seasoned clinicians alike share what initially attracted them to Array and why they chose to stay: 

Work-Life Balance 

Array prioritizes the well-being of clinicians and administrative team – the mental health of our patients starts with us. Aside from the flexibility that comes with working from home and choosing your own schedule, we’ve established a wellness committee and clinician engagement team who continuously promote healthy work-life practices and on-going education. 

Longtime Array clinician, Julie Lu, a psychiatric NP who has worked with us for several years explains why she enjoys working in telepsychiatry. 

“What I like most about practicing telepsychiatry is that it feels like I’ve found more time in the day; I no longer have to fight traffic during a long commute. That time is now better used talking to patients and my clinic staff. The technology has allowed me to reach across the distance and make connections with patients who might otherwise still be on a wait-list to be seen by a psychiatric provider.”  

Focus on Clinical Care 

Array has an unmatched internal technical and administrative infrastructure backing its clinicians. We offer around-the-clock clinical, operational and technical support designed to help clinicians with their delivery of care every step of the way. Clinicians enjoy support from a large responsive team so they can focus on what they do best – providing patient care.  

Array offers reliable support via admin staff, care navigation team and user-friendly systems. Thank you, Array for allowing me to put 100% of my energy into providing therapy.” - Kelly Wood, LCSW 

Being Part of a Team 

Collaboration is a cornerstone of our organization. Through collaboration, Array clinicians develop strong professional relationships with their partner site as well as with their telepsychiatry peers and administrative support staff. Clinicians are not providing care “on an island” by themselves; our clinicians can find reassurance in having systems in place that makes it easy to communicate with colleagues and collaborate with necessary personnel in order to deliver the highest-level care  

When community health clinics across the country had to close or temporarily suspend services during the coronavirus crisis, one of our partners, the Fauquier Free Clinic in rural Virginia, in collaboration with our clinician, Dr. Azpiri, was able to quickly convert from facility-based to home-based virtual care so their patients could continue to receive much-needed mental health services. 

“I am so grateful that patients have been so receptive to this new approach. They have been so welcoming and inviting and flexible, which is a big reason we’ve been able to pivot so quickly and successfully to in-home virtual care. Delivering care directly to patients in their homes gives me a glimpse inside their private worlds, without being overly intrusive. I can assess environmental cues such as the orderliness and cleanliness of their surroundings, appearance, food needs, etc. This allows me to really see how they are doing physically, emotionally and mentally and determine if additional support is needed.” – Alicia Azpiri, MD 

Expanding Organization 

Following the recent merger between InSight Telepsychiatry and Regroup Telehealth in December 2019, even more clinicians have inquired about clinical opportunities with our newly combined organization. The merger created a larger, more comprehensive nationwide team that allows us to grow more quickly and strategically. With a bigger footprint and opportunities in various settings across the continuum of care, we are able to offer clinicians different options for where and how they practice. Clinicians also benefit from, our collective partnerships, expertise, leadership and resources; together we are truly transforming access to care. 

Clinician Choice in Care Setting 

Array is the only telebehavioral health care organization that offers clinicians the flexibility to select among multiple models, serve multiple organizations and work with multiple patient populations. Clinicians have the opportunity to choose from a myriad of settings such as emergency departments, hospital medical/surgical floors, inpatient units, mobile crisis programs, crisis centers, residential programs, primary care clinics, community health centers,  tribal programs, correctional facilities or direct-to-consumer. Given the multitude of options available, we work with each clinician from the start to figure out the best care setting for them. We discuss their individual needs and preferences as well as the needs of the organization to ensure long-term success. We have found that uniquely matching our clinicians and partners and maintaining a strong line of communication has enhanced clinician satisfaction. 

“I have been a psychiatrist with Array for 2 years. It has been a phenomenal work experience. I enjoy rotating my days between an outpatient clinic, a correctional facility and a commercial insurance/home setting. It keeps my clinical work interesting and my skills sharp.” - Betsy O’Brien, MD  

Work for an Established Reputable Organization 

Array is the pioneering leader in telepsychiatry. For the past two decades, our mission has remained the same – to transform access to quality behavioral health care. Clinicians appreciate the stability and reassurance of working for an established and rapidly growing organization that has the technical, clinical and operational support to make them successful. Clinicians can engage with telepsychiatry peers, learn from behavioral health thought leaders and clinical experts.  

The collaboration between professionals, flexible hours, and ability to work with a company whose values and standards are in alignment with mine are some of the reasons why I continue to choose Array as an employer. I enjoy working in telehealth; it's a rewarding and humbling experience to be invited into a patient’s home once a week for online therapy and have the opportunity to observe and help them when their most vulnerable.” – Robert Cleveland, LCSW 

Array uses the Net Promoter Score (NPS) metric that assesses clinicians’ experience with our organization by asking them how likely they are to recommend us to a friend or colleague. The final aggregate NPS score can range from as low as –100 to as high as 100. With the most recent clinician NPS scores for the two organizations averaging 55, it’s clear that clinicians like working at Array.  We are committed to fostering the best clinician experience possible to ensure they can deliver the best in class care. 

What do you look for in a telebehavioral health employer? We’d love to hear from you. Visit this link to either share your ideas or to discuss the various telepsychiatry opportunities available at Array. 

This year has seen remarkable changes across every element of the healthcare landscape. From the unforeseen curve ball thrown at a vulnerable U.S. healthcare system to the rapid, necessary adoption of telehealth across all care settings, 2020 is nothing like we’ve dealt with before.

With all this change comes a need to be introspective and understand how we can prepare for the days, weeks, months and years ahead. Array maintains partnerships with hospitals and health systems across the nation under unique circumstances to ensure access to timely psychiatric assessments.

To help give us a clearer picture of what hospitals have experienced and may continue to endure related to mental health patients, Array SVP & Medical Director, Dr. Mark Alter, gives his thoughts on the current hospital-based telepsychiatry landscape.

How has the coronavirus impacted hospital behavioral health services/programs?

The earliest phase of COVID-19 (March and April) saw a significant dip in the utilization of hospital-based behavioral health services and programs. This was in large part due to patients trying to avoid physical spaces with high risks of infection. Then, we saw a spike in mental health visits in hospitals as community-based programs where individuals typically sought treatment temporarily closed or switched to telehealth-only appointments. These types of programs are often inaccessible to the most vulnerable populations such as those experiencing homelessness and require them to end up in the emergency department.

Now, as COVID impacts lives in numerous ways, the need for behavioral health care is still present and is in fact increasing. The National Alliance on Mental Illness estimated that by 2021, 1 in 3 Americans will have a mental health or substance use issue. As an organization that works with its partners to scale and adjust services to meet these challenges, we are expanding our work into non-traditional on-demand settings and developing models to improve our ability to provide our services in areas and communities most in need.

One thing that has changed is our operational process and on-demand platform used by our hospital partners to request an assessment. When an emergency department, inpatient psych unit or medical floor requests a patient evaluation, they may denote the patient in question has tested positive for COVID-19. Doing this allows for our telepsychiatry clinician to adjust their messaging and ensure the appropriate amount sensitivity around the subject. Additionally, this makes the telepsychiatry clinician aware that onsite staff may require more time preparing PPE before setting up the virtual encounter in the presence of the patient.

What does the future of behavioral health look like for hospitals?

Prior to this pandemic, the need for telepsychiatry was fueled by a limited, poorly dispersed number of quality behavioral health clinicians across the country as well as an increasing demand for services by patients in need of care. The nature of this virus complicated those already difficult challenges. Even with available care resources or a manageable demand, this virus halted many in-person encounters and has forced us to adopt virtual interaction. Whether newly implemented programs or refining and sustaining ongoing programs, healthcare professionals are realizing the efficacy of telebehavioral health encounters and we will likely see continued use of these solutions even when in-person assessments are possible.

Has there been an increase in mental/behavioral health presentations in emergency departments or changes in disposition decisions?

While stressors such as the duration of quarantine, inadequate supplies, lack of information, frustration, boredom and fear of infection exist, these have not necessarily meant an increase in mental health-related presentations in hospitals. In response to the pandemic, hospitals and health systems have had no choice but to reallocate their resources. Changes like the need to limit inpatient psych unit rooms to just one bed did decrease overall bed availability. This did not mean that behavioral health programs they had previously implemented shut down. Our telepsychiatry clinicians continue to constantly monitor the evolving circumstances of the partner facility, adjust their processes and consider the community resources that they can leverage when making dispositions.

Though behavioral health visit volume was down initially, we have seen a steady return to pre-first spike volumes of mental health-related visits across many of our hospital partners. This could be in part due to patients in crisis or in urgent need of care feeling more comfortable utilizing hospital resources now that many have managed to safely adapt their operations in response to the virus. Stepping inside a hospital may not pose an exorbitant amount of infection risk as it may have posed just a few months ago. 81% of hospital leaders stated in recent Array poll that they believe the volume of mental health-related visits will increase over the next 6 months.

Hospitals and health systems need to continue to examine their disposition processes and adjust according to the availability of other resources in their community. If resources like intensive outpatient programs (IOP) and primary care providers (PCP) close or offer limited access, telebehavioral health may be able to bridge those gaps in many instances.

It is vital to support the mental health of your team right now. Healthcare workers and administrators are bravely bearing the burden of this collective trauma and the impact on their own well being now and into the future cannot be ignored.

Creating meaningful support for healthcare employees should be top priority.

What could or should that look like? We've put our heads together with HR teams at several large health systems to brainstorm the key elements of a solid program to support healthcare-industry employees.

1. Educate managers on trauma-based and related behavioral health conditions

Goals

  • Equip managers to identify and compassionately guide staff and colleagues to appropriate resources when they observe risk factors
  • Prioritize early intervention so that trauma doesn’t become rooted across the workforce

Suggested Structure & Logistics

  • Initial training, 1 month follow up training and 6-month refresher training
  •  Distribute a pre-training survey to solicit questions and requests and gauge level of knowledge
  • Include up to 30 attendees per training – grouped by level of knowledge
  • Have trainings facilitated by LCSW, PhD, or similar
  • Make facilitator available to attendees following each training for one-off questions, consultation and follow ups
  • Share recording of training and associated course material
  • Train new managers on initial curriculum within 3 months of hire

2. Host facilitated psychoeducational group sessions 

Goals

  • Provide staff with info about post-trauma reactions, grief and bereavement, effective coping strategies and when to seek professional consultation in a supportive group setting

Cover topics including:

    • Understanding grief in the age of the COVID-19 pandemic “community loss”
    • Trauma in the time of COVID-19
    • During a response: understand and identify burnout and secondary traumatic stress
    • Healthcare responders and stress
    • Care for yourself to care for others: patient relationship-based model
    • Staying connected to self and others – healing through connection
    • Anxiety and depression – coping with stress, fear and worry
    • Mindfulness and stress reduction
    • Ways to support your children

Suggested Structure & Logistics

  • Master-level facilitators should follow a structured content syllabus
  • Offer groups multiple times throughout the week to accommodate shift schedules
  • Managers and HR can encourage group participation to employees if risk factors are observed
  • Promote in the break room, company newsletters, internal intranet etc.

3. Give access to a support hotline

Goals

  • Facilitate access to a confidential hotline that allows clinicians to engage with peers offering support
  • This is cited to be a format where clinicians typically feel most comfortable opening up

Suggested Structure & Logistics

  • Create or leverage a toll free number to provide access from at least 8 am-midnight, 7 days per week
    • Managers and HR can encourage utilization
    • Promote in the break room, company newsletters, internal intranet etc.

The COVID-19 pandemic is creating an unprecedented set of global circumstances that are profoundly changing the lives of people everywhere. Among many challenges that we now face, it’s evident that COVID-19 is creating – and in some cases, exacerbating – mental health issues among many groups.

Research shows that 47% of individuals who were ordered to shelter in place have reported negative mental health effects. This is likely due to the fact that what we’re facing currently is global, systemic trauma. As clinical psychologist Sharon Greenfield recently told Reuters, “We’re all a little disoriented. Our brains aren’t quite sure whether we’re being exposed to a traumatic trigger or not.”

While many people around the globe are feeling some of the negative effects of grief and trauma, those who work in healthcare are especially at risk. Healthcare workers – like nurses, doctors and EMTs – are on the front line of the coronavirus fight. As a result, they’re witnessing trauma occur daily as they perform their jobs.

Healthcare Workers’ Mental Health During COVID-19 

If you’re a healthcare worker, research shows you’re more likely to show symptoms of mental health disorders because of the very real stress of managing the pandemic.

Dr. Lorna M Breen, an ER physician in New York, recently died of suicide after the trauma of witnessing COVID-19 firsthand. Research from China shows a considerable amount of Chinese healthcare workers are experiencing symptoms of depression, anxiety, insomnia and distress. These were especially prevalent in women, nurses, those who reside in Wuhan where the outbreak originated, and frontline healthcare workers.

The fallout of this trauma also takes a toll on the spouses and families of healthcare workers. Roughly half (51%) of people who live with a healthcare worker said worry and stress about the coronavirus has had a negative impact on their health. Additionally, many healthcare workers report being afraid to go home, because they have sick or immunocompromised family or housemates and they fear accidentally infecting these individuals.

Weathering the Storm, Together 

While the pandemic continues to unfold, it’s imperative to prepare to address the long-term impact of COVID-19 to help healthcare workers transition, cope and heal from the trauma they’re enduring. One key resource will be perceived social support; feeling interconnected tends to help protect against post-traumatic stress disorder (PTSD). Self-care is also highly recommended.

While acts of self-care are important, however, many healthcare professionals will need additional support if they’re experiencing mental health issues such as anxiety or PTSD. Hospitals and healthcare systems can help by offering emergency transportation and housing options, which can mitigate the stress healthcare workers feel about infecting those around them. Perhaps most importantly, these organizations can help provide counseling services and support groups to these workers. Access to mental health resources and professionals is crucial to helping healthcare workers cope and heal from the events surrounding COVID-19.

Hospitals and Healthcare System Tools

One tool that hospitals and healthcare systems may consider implementing to support healthcare workers is telepsychiatry. Becker’s Hospital Review reported that in 2019 alone, over 100 hospitals had implemented virtual care technology to enable telehealth services for a variety of specialties. Now that telehealth laws are changing quickly in many states to accommodate stay-at-home orders and coronavirus measures, telepsychiatry is emerging as a flexible, no-contact option to connect healthcare workers and others with the services they need.

Countless healthcare workers are fighting to protect our well-being during the pandemic, and these professionals will need their own well-being supported as the immediate crisis fades. Telepsychiatry can help break down barriers to deliver care when and where it’s needed most, giving these frontline heroes access to vital mental health services in the days and months ahead.

The spread of the COVID-19, commonly known as coronavirus, is upending daily life around the globe. On March 11, the World Health Organization (WHO) declared coronavirus to be a pandemic. To date, there have been over 220,000 cases worldwide, with more than 9,000 deaths reported. There are now widespread mandatory closings and travel restrictions, and many major events have been cancelled or postponed.

In response, healthcare organizations are seeking ways to provide safe, uninterrupted care to patients while meeting new behavioral needs brought on by psychological trauma. The stresses of quarantine and anxiety about the illness can lead to serious mental health concerns, creating ripple effects that will be felt for months to come.

By providing care virtually through telepsychiatry, organizations can respond rapidly to patients’ mental health needs and free up in-house clinicians and resources to address escalating medical needs in the wake of the outbreak. Recent legislative updates are paving the way for increased use of telepsychiatry to meet these needs as the coronavirus spreads. Here’s how your organization can effectively prepare.

Legislative Updates to Expand Telehealth Access

Regulators and payers are making moves to expand the use of telepsychiatry during the coronavirus pandemic. Last week, Congress passed an $8.3 billion COVID-19 funding package (H.B. 6074) that included a provision to expand telehealth access for Medicare beneficiaries. This gives organizations more tools to meet community mental health needs while combating the spread of the virus.

Highlights include:

  • The HHS Secretary can now waive originating site restrictions, allowing Medicare providers to deliver services via telehealth, even if the patient is not in a rural area.
  • Qualified Medicare providers can deliver services to patients with whom they have a pre-existing relationship.
  • Patients can receive services in their home instead of traveling to a healthcare facility, lowering the potential risk of the transmission of coronavirus. Patients can now also receive services via phone, so long as the phone has audio and video capabilities that are used for two-way, real-time interactive communications.

Additionally, Medicare reimburses for other services provided to patients at home, including video check-in, remote evaluation of recorded video and images, and digital evaluation through a patient portal.

At the state level, a handful of states already have laws in the books about the provision of telehealth during public health crises, while others are mulling legislation in response to the crisis. For example, Vermont passed a telehealth bill both to assist rural patients and to curb the spread of the coronavirus.

Many private payers are also loosening restrictions to make virtual care an option. A statement by the AHIP encourages state and federal policymakers to expand access to telehealth, in-home care, and other technology-enabled options to stem the infection. In Illinois, Aetna is offering a zero-dollar copay for telemedicine visits for 90 days.

Using Telepsychiatry to Meet Today and Tomorrow’s Needs 

While organizations often adopt telepsychiatry to overcome barriers such as remote geographies, increased demand for clinicians, and the scarcity of mental health specialists, the remarkable spread of coronavirus may force many providers to adopt telehealth solutions to overcome unexpected barriers like quarantines. It will be important for healthcare organizations to act quickly to meet immediate needs and provide the appropriate support as the mental health consequences of the pandemic unfold.

Post-traumatic stress and depression are often found in individuals who have recently been in isolation due to a quarantine, and for those who have existing mental illnesses, this isolation can make those conditions even worse.  While containing and treating the virus must take priority, mental-health care must also be programmed into the response.

Telepsychiatry allows patients and clinicians to connect from anywhere, which helps organizations to:

  • Provide continuous care for patients, even if they’re homebound because of self-ordered or mandatory quarantines.
  • Conserve medical resources for patients most in need, so the healthcare system doesn’t become overwhelmed. Organizations are racing to flatten the curve of the pandemic while they can, and on-demand services can help keep psychiatric patients out of hospital beds needed for the treatment of hospitalized coronavirus patients.
  • Keep clinicians safe by distancing providers from the virus, while still providing necessary mental health support.

How Comprehensive Care Can Flourish with Telepsychiatry 

When it comes to different types of mental health care, telepsychiatry can be used in several important ways to ensure the safety of both patients and clinicians during this time:

  • Scheduled Services - With scheduled services, a consistent clinician or small group of clinicians serves a regular caseload during scheduled hours, helping healthcare organizations expand access, augment in-house resources and support continuity of care.  The remote clinician is able to do anything an onsite clinician would do including assessment, medication management, treatment team meetings and supervision. Adult psychiatrists, child and adolescent psychiatrists, psychiatric nurse practitioners and all other levels of behavioral health professionals are all available under the scheduled service model.
  • In-Home Care - The home-based services model moves behavioral health care outside of the clinics and primary care centers and into patients’ homes.  This would allow patients to continue to get the behavioral health care they need without having to come into the office. With in-home virtual care, healthcare organizations can continue to offer their patients access to behavioral health care while helping to contain the spread of COVID-19.
  • On-Demand Services - An on-demand approach to telepsychiatry offers access to experienced clinicians when and where organizations need them, providing critical behavioral health coverage and enhancing the bandwidth and expertise of in-house staff. With coronavirus threatening to overwhelm capacity at hospitals across the U.S., telepsychiatry can help hospitals evaluate psychiatric patients to quickly determine the right level of care for mental health patients and conserve hospital beds for COVID-19 patients.

Implementing telepsychiatry as the coronavirus worsens also benefits clinicians, who can work safely while still attending to patient needs. With many people feeling the mental health effects of the outbreak, clinicians can provide valuable virtual care for people in high-stress situations like quarantines.

Providing Care Responsibility in Times of Crisis 

The full impact of the coronavirus is still unfolding, but it’s clear that healthcare organizations will need a solid plan to address immediate mental health needs and the longer-term effects of the outbreak. The key will be to leverage recent regulatory changes to integrate innovative delivery models like telepsychiatry. A virtual approach can help protect the health and safety of both patients and clinicians, while delivering care where and when it’s needed the most.

To learn more about telepsychiatry's role in delivering uninterrupted behavioral health services,  contact us today.

The immediate and long-term mental health effects of the COVID-19 crisis has significant implications for hospitals across the country who are bracing for a surge in the number of patients presenting with mental health issues in the wake of prolonged social isolation, rising unemployment, economic instability and pervasive fear, uncertainty and anxiety. Given thexpected groundswell of mental health needs, hospitals are turning to telepsychiatry to provide as-needed psychiatric assessments and care. 

Telepsychiatry is being used in hospital emergency departments (EDs) to help triage psychiatric patients and refer them to the appropriate level of care more quickly and efficiently. Timely access to psychiatric assessment via telepsychiatry has been shown to shorten wait times, reduce overcrowding in the ED and improve patient satisfaction. 

Telepsychiatry is also used to support a hospital inpatient medical unit. Prior to the COVID-19 crisis, there was a nationwide shortage of mental health professionals, particularly psychiatrists. In the wake of the pandemic, these scarce resources are even more strained and overextended, leading to significant delays and long wait times for their services. Telepsychiatry can help alleviate this by connecting the hospital team with remote psychiatrists who can assist with clearance evaluations so medical-surgical patients can be discharged more quickly, reducing the strain on the system and minimizing patients risk of exposure to COVID-19 from an extended hospital stay. 

The Problem: Lengthy Credentialing and Privileging Process 

To address the escalating need for both medical and mental health care in the wake of the COVID-19 crisis, many hospitals across the country are seeking to quickly expand their network of healthcare providers by adding remote clinicians to their ranks. While additional practitioners are needed to handle the increased volume, all new clinicians – both onsite and remote – must be properly credentialed and privileged in order to practice within a hospital.   

Credentialing is a lengthy, complex process that is unique to every clinician and organization. The time it takes to collect, review and approve the necessary documentation for credentialing can extend for months and can significantly impact the time it takes to establish a telepsychiatry program.     

Privileging involves the granting of certain permissions by hospitals to an individual clinician to perform specific aspects of patient care. Privileging decisions are made based on the portfolio of information and materials collected and reviewed during the credentialing process. Examples of privileges include admitting, placing orders, prescribing and performing procedures. If a remote clinician is not privileged with an organization, they may not be able to directly assess a patient. 

Committees at each hospital generally approve privileges. The regularity or frequency with which these committees meet varies widely, which can delay the implementation of telepsychiatry services and further prolong wait times for behavioral health patients in need 

Given that the standard credentialing and privileging process typically takes a few weeks to a few months to complete, alternative solutions are needed during the COVID-19 crisis in order to safely and quickly meet patient care needs.  

The Solution: Grant Temporary Privileges to
Expedite Psychiatric Care 

Temporary and disaster privileges are two options that could help hospitals meet the significant and growing need for care during the COVID-19 crisis and in its aftermath. Granting temporary and disaster privileges would help expedite the provision of patient care since it would allow telepsychiatry providers to start delivering behavioral health services more quickly while they await review and approval by the medical staff committee and governing body of the hospital.   

According to the Joint Commission, temporary privileges can be granted in situations where the patient care volume exceeds the level that can be handled by currently privileged practitioners.  Disaster privileges are temporary privileges a hospital may grant for various reasons according to their bylaws, such as during a declared local or national emergency if the hospital is unable to meet immediate patient needs and requires outside assistance to sustain patient care. 

Disaster privileges are also governed by hospital bylaws or policies, and only extend for the duration of the emergency whereas temporary privileges may allow a physician to practice for up to 120 days and can be extended for intervals of 30-60 days until a full credentials review can be performed and permanent privileges are granted. Since the need for mental health care will persist long after the immediate threat of the coronavirus subsides, hospitals should push for temporary rather than disaster privileging for telepsychiatry providers. 

Geoffrey Boyce, CEO of Array Behavioral Care, the leading telepsychiatry service provider organization in the country, discusses the immediate and long-term mental health effects of the COVID-19 pandemic and the important role of telebehavioral health as a safe and effective way to meet the escalating need for care that will likely persist long after the initial crisis subsides.

MOUNT LAUREL, NJ – Telehealth has reached its tipping point.  These are historic and unprecedented times as healthcare organizations, clinicians, consumers, payers, and regulators recognize the value of telehealth and are quickly pivoting to remote models of care as a safe, effective, and timely way to deliver services during this critical time of need.

In the wake of COVID-19, hospitals need to conserve available beds and resources; clinics and clinicians have countless reasons to virtualize and bring services into the home.  Payers are increasingly supporting new methods of delivering healthcare services across communities at scale.  And regulations are evolving to make all of this happen.  This is the watershed moment for telehealth.  Telehealth is finally in the national spotlight and is being heralded as the ideal solution to meet the escalating need for care during the COVID-19 crisis and beyond.

Telehealth for Mental Health

It is obvious that remote services via telehealth makes great sense for primary care right now.  Many are also recognizing that telehealth makes intuitive sense for behavioral healthcare now and forever into the future.

An individual’s mental health, physical health, and overall well-being are inseparable, and with widespread closures, self-quarantines, and expectations of social distancing, telebehavioral health services have become virtually the only mechanism for maintaining access to care amid this unfolding COVID-19 crisis.

Telebehavioral health has become the new normal, and this mechanism for receiving services is here to stay.  Telepsychiatry will survive as a standard for delivering care long after this crisis because it empowers healthcare organizations to use scarce resources wisely, payers to increase access and manage costs, clinicians to practice safely and effectively, and for individuals to have choice in where, when, and how they access vital behavioral health services.

Telepsychiatry Across the Care Continuum

Telepsychiatry can be used in various settings across the continuum of care to deliver behavioral health services to communities in need.  This form of care delivery also ensures the safety of both patients and clinicians, especially during these challenging and uncertain times.

For Hospitals. 

Quick, safe throughput and the proper use of available ED beds and resources have never been more important. With coronavirus threatening to overwhelm capacity at hospitals across the country, telepsychiatry can bring a psychiatric professional into the hospital on demand to evaluate the patient via video to determine appropriate disposition.  The net effect is that hospitals can better focus on conserving beds for COVID-19 patients.  In addition to improving bed availability via timely and appropriate decision making, telepsychiatry can be used to initiate treatment from the hospital with a bridge back to a community resource.  Telepsychiatry can also help hospitals and their staff conduct psychiatric consultation liaison services safely and remotely and can be used as a peer-to-peer consult resource to support strained and overextended in-person staff in the ED, on the med floors, and within psychiatric inpatient units.

For Community-based Clinics. 

Community-based clinics are facing significant pressure to maintain access to care for patients and decrease the impact of mental health patients on emergency services all while taking measures to contain the spread of COVID-19.  In response to the evolving situation, many healthcare organizations are increasingly turning to telepsychiatry to help address the impact of the virus in their respective communities.  In addition to clinic-based scheduled telepsychiatry services, doc-to-doc consult models for curbside consultations and various in-home care options are also increasingly available.

Perhaps the most significant change occurring right now is the shift of onsite mental health into a virtualized outpatient model where patients receive services within their own homes via their normal clinic.  This allows patients to continue to get the behavioral health care they need from a remote clinician with whom they are already familiar, without having to come into the office. To accomplish this convenient and safe delivery, clinics are being forced to overcome significant challenges and transform a time-tested delivery mechanism nearly overnight.  However, many are rapidly succeeding.  Transforming to in-home virtual care enables these clinics to help contain the spread of COVID-19, sustain their own existence, and continue to serve some of the patients in greatest need with quality behavioral healthcare over video.

For Virtually-Based Clinics.

Some forward-thinking practices had turned to telebehavioral health as the primary delivery mechanism of services well before COVID-19.  These practices have no bricks and mortar locations and exclusively deliver services to individuals via telehealth.  These practices bring life-changing behavioral care directly into people’s homes or any private place of their choosing, which is especially valuable during times like this.  Whether it is individuals seeking care for themselves or employers or payer organizations seeking care for their employees or members, telebehavioral health allows individuals to receive psychiatry and therapy services when and where it works for them through online video.

For Individuals. 

Given the constant news coverage and nearly singular focus on COVID-19 along with the stress of an unexpectedly imposed regime at home and new financial worries, it’s not surprising that people are feeling stressed and anxious.  Many people with mental health concerns now expect their clinic to virtualize or are turning online to an already fully virtualized practice. Virtual visits allow individuals to safely continue or start their care without risk of exposure. Telebehavioral health makes it easier for individuals to get the help they need, when and where it works for them, with licensed therapy and psychiatry providers.

For Employers. 

With remote work as the new standard, employees are experiencing unintended mental health effects such as isolation, anxiety, depression, and new types of burnout.  In response, employers are scrambling to find resources to help their employees cope and to connect them with care options to help them navigate these uncertain times. Employers recognize that providing their employees with convenient access to appropriate psychiatric and mental health care can help boost productivity, reduce absenteeism, improve employee emotional wellbeing and promote a more positive work culture.

For Payers.

Similarly, insurers are embracing telebehavioral health to meet the growing mental health needs of their members who are experiencing additional stress and anxiety caused by social isolation and the spread of COVID-19.  Payer organizations are making dramatic and sweeping changes to ease restrictions and revise reimbursement policies that previously limited the use of virtual care.  In an effort to improve member access to quality behavioral health care, these payer organizations are relying on telehealth to bring these services into the home.  With convenient, secure online appointments, payers have expanded their network, and members are able to access psychiatrists and other behavioral health clinicians who most closely fit their needs.

Regulatory Updates to Expand the Use of Telepsychiatry

In response to the growing need for healthcare organizations to provide safe, uninterrupted care to existing patients and meet new behavioral health needs brought on by the stress and anxiety surrounding the coronavirus pandemic, regulators and payers are making significant moves to expand the use of telehealth and telepsychiatry.  In fact, many of the regulations that have historically challenged the adoption of telebehavioral health have changed in recent weeks in response to the public health crisis.

Federal and state declarations of emergency have given healthcare providers and organizations much more leeway and many more resources to meet community mental health needs while combating the spread of the virus.  Several well-intended but impractical limitations on telehealth have been temporarily waived such as requirements around specific technology, geographic location, provider type, DEA registration, and even prescribing practices.

States are creating temporary exclusions to licensure for certain healthcare professionals in response to COVID-19, both for onsite and telehealth practice.  Other states are crafting pathways toward reciprocal and expedited healthcare licensure that may survive our immediate crisis and represent broader access to care without reconstructing unnecessary limitations to where a healthcare provider may serve patients.

Medicare, Medicaid programs, and private payers are similarly loosening restrictions and expanding reimbursement options to encourage the use of virtual care and telehealth.  The provider community and our healthcare organizations are responding and are embracing these innovative solutions to meet immediate need for care, lessen the impact on the system, and provide appropriate support as the consequences of the pandemic unfold across our country and across our individual lives.

Conclusion

For years, the behavioral health community has suffered from an access problem.  The shortage of qualified professionals has been grossly misaligned against the rising demand for behavioral health services within healthcare.  Almost overnight, the world recognized that a critically important part of the solution was to virtualize behavioral health.  Adoption challenges that previously would have taken the industry years to overcome have nearly disappeared, and telebehavioral health is occurring across the continuum in unprecedented ways.  While our access problems are far from over, I implore us never to let those self-imposed and imagined barriers to care back into our definition of normal.  Telehealth will prove its value in the months ahead, and we can go nowhere but forward from here.

 About the Author

Geoffrey Boyce is the CEO of Array, the leading telepsychiatry service provider in the United States with a mission to transform access to quality behavioral health care.  Boyce is a leader in telemedicine advocacy, education and reform initiatives. He serves as a national voice promoting telemedicine and telepsychiatry and regularly interacts with state and local healthcare regulators and administrators.  In 2017, he received the Industry Leader Award from the American Telemedicine Association.  Boyce is an active participant in several ATA Special Interest Groups and Workgroups including: the Telemental Health SIG, the Interstate SIG, the controlled substances prescribing and telehealth workgroup and the proposed workgroup on the expatriate telemedicine providers. He also serves on the advisory board of directors for the Mid-Atlantic Telehealth Resource Center (MATRC). In 2018, he was appointed to the New Jersey Telehealth Review Commission.  Boyce frequently speaks about the potential of telemedicine and the best practices for establishing new programs. He holds an MBA from Terry College of Business at the University of Georgia with a focus on entrepreneurship.

About Array

Array Behavioral Care (formerly InSight + Regroup) is the leading and largest telepsychiatry service provider in the country with a mission to transform access to quality, timely behavioral health care. Array offers telepsychiatry solutions and services across the continuum of care from hospital to home with its OnDemand Care, Scheduled Care and AtHome Care divisions. For more than 20 years, Array has partnered with hundreds of hospitals and health systems, community healthcare organizations and payers of all sizes to expand access to care and improve outcomes for underserved individuals, facilities and communities. As an industry pioneer and established thought leader, Array has helped shape the field, define the standard of care and advocate for improved telepsychiatry-friendly regulations. To learn more, visit www.arraybc.com.

Did you know that Array also offers therapists? While psychiatric prescribers are our primary niche, we also have a team of therapists who can support on-demand, scheduled and in-home applications of telebehavioral health. These clinicians include licensed clinical social workers and counselors who can work in collaboration with your onsite clinicians or with other Array telehealth clinicians.

The benefits of partnering with a diverse group of clinicians include:

  • Allows for a comprehensive assessment and treatment of behavioral health issues
  • Provides patients with better access to expert mental health care
  • Ensures a seamless care transition with proactive post-discharge outreach
  • Higher patient retention rates due to familiarity and clinician-patient relationship building
  • Ability to form collaborative, multidisciplinary behavioral health treatment teams to ensure the highest and best use of clinicians' time and to encourage practice up to clinicians' level of licensure

Most Array therapists are either Licensed Professional Counselors or Licensed Clinical Social Workers.

Licensed Professional Counselors (LCPs)

LCPs primarily specialize in psychotherapy. The exact title for these professionals varies by state. In addition to secondary education (either a master’s or doctorate in counseling), LPCs must obtain supervised clinical experience and pass state-specific licensing exams. LPCs may specialize in certain areas like marriage issues or substance abuse. LPCs do not prescribe medications and typically do not offer formal diagnoses.

Licensed Clinical Social Workers (LCSW)

LCSWs vary significantly in credentials and licensing and can provide a range of services based on those credentials. Clinical social workers are licensed to practice psychotherapy, recommend treatment from other specialists, and typically work one-on-one with consumers.

Array has an extensive and diverse network of clinicians and works with its partner healthcare organizations to understand needs for clinicians with certain specialties, experience levels, philosophies of care, cultural factors and personality types.

Contact Us to Learn More

Content last updated on June 30, 2020

In a world changing faster than we ever thought possible, the regulations surrounding telepsychiatry are evolving at lightning speed. The demand for telehealth service has exploded in recent weeks and it is imperative to know the rules and regulations as organizations rapidly adapt to this form of care. Below is a brief highlight of the most relevant policies impacting the telepsychiatry industry today. We will continue to update this post in the coming weeks as the situation evolves.

Disclaimer: The information on this page is a summary of the current laws, regulations, and guidance and not to be used as a comprehensive legal document. The information is continually changing so we encourage you to raise any questions to your legal counsel about how it may be applicable to your facility or organization.

Is Congress considering permanent changes regarding the delivery of telehealth services? 

 Yes, there has been a flurry of activity and advocacy efforts surrounding making some of the telehealth changes within Medicare permanent. One of the main advocacy initiatives is for organizations to submit written letters to Congress. Here are some examples: 

  • May 21, 2020: 32 Congressional House members wrote a letter encouraging the House Speaker, Nancy Pelosi and Majority Leader, Mitch McConnell, to urge Congress to expand behavioral telehealth services in any upcoming COVID-19 response package for a reasonable transition period following the end of the public health emergency.  
  • June 15, 2020: 29 Senators sent a letter to Congressional leadership asking that telehealth provisions in the CONNECT for Health Act be made permanent. More letters have also come from organizations such as the Association of American Medical CollegesFTCMental Health Liaison Group, and the ATA 
  • June 29, 2020: InSight + Regroup joined 340 other organizations to sign a letter urging Congressional leaders to make telehealth flexibilities created during the COVID-19 pandemic permanent 

Additionally, the Senate Committee on Health, Education, Labor and Pensions (HELP) conducted a hearing on telehealth lessons learned during the pandemic. Joseph Kvedar, President of the ATA, was asked to testify along with other telehealth advocates. The speakers emphasized how the relaxed regulations around telehealth have had a significant impact of how services can be delivered, the number of patients that have accessed services via telehealth, overall patient satisfaction with telehealth, among other things.  

Furthermore, telehealth advocate organizations, The American telemedicine Association, Alliance for Connected Care and the NCQA launched a task force to lobby for permanent policy changes. The goal of this group is to “develop recommendations for policymakers on how to maximize the benefits of telehealth services while maintain high standards for patient safety and program integrity”.  

What actions have states taken to make some of their temporary COVID-19 regulatory changes permanent? 

Individual states are also taking matters into their own hands and are introducing legislation or have passed regulatory changes that would keep some of the current loosened telehealth restrictions in place permanently: 

  • Rhode Island: a bill is being considered that would require payers to reimburse for telehealth services at rates no lower than the same service delivered in person and would expand the definition of telemedicine to include audio-only telephone services.  
  • Colorado: a bill has been introduced that would require the state’s Medicaid program to provide coverage and payment parity for telehealth services at rural health clinics, federally qualified health centers and the Indian Health Service in addition to expanding the definition of telehealth to include audio-only phones, faxes, messaging platforms and email. 
  • New York: Gov. Cuomo signed into law a bill that allows audio-only telehealth services for Medicaid and CHIP. This amends the previous law that required both audio and video.  
  • DC:  DC Medicaid made permanent the change that authorizes Medicaid to reimburse providers for telehealth services delivered to consumers in their home.  
  • Idaho: Gov. Brad Little signed an executive order making all of the waivers of telehealth regulations that he issued during the public health emergency permanent. 
  • Louisiana: Gov. Bel Edwards signed into law a bill that enables healthcare providers to use connected health platforms to deliver telemental health services and expands the list of providers able to use the technology to include psychiatric mental health nurse practitioners 

Have any other long-term changes have been proposed?  

IMLC Adoption: The ERISA Industry Committee (ERIC), a national advocacy organization that represents large employers that provide health, retirement, and other benefits to their nationwide workforces, has sent letters to the governors of the 21 states that are not currently members of the Interstate Medical Licensure Compact (IMLC). The letters urge the governors to introduce legislation to join the compact, which would allow qualified providers to receive a medical license from any participating state through an expedited licensure application process.  

The states that received these letters include Alaska, Arkansas, California, Connecticut, Delaware, Florida, Hawaii, Indiana, Louisiana, Massachusetts, Missouri, New Jersey, New Mexico, New York, North Carolina, Ohio, Oregon, Rhode Island, South Carolina, Texas, and Virginia. To view a sample letter, click here. 

Existing State and Federal Guidelines and Laws that have been affected from the proclamation of a National Emergency 

The Coronavirus Preparedness and Response Supplemental Appropriations Act 2020 is an $8.3 billion package that provides funding for the United States’ response to COVID-19. The Act was passed with close to unanimous support in both the House and the Senate and was signed into law by the President on March 6, 2020. Additionally, with the proclamation of a National Emergency, it allowed various federal agencies to exercise their authority to allow them to take relevant actions to protect its citizens. Many actions allowed for the expansion of telehealth to be used during this time as well as provide several waivers and exceptions to practice requirements and guidelines. 

With the Ryan Haight Act, can telemedicine now be used more broadly to prescribe controlled substances?

Yes, since the Secretary of the Department of Health and Human Services issued a public health emergency, that “practice of telemedicine” exemption within Ryan Haight can be met. Per the DEA, for as long as the Secretary’s designation of a public health emergency remains in effect, DEA-registered practitioners may issue prescriptions for controlled substances to patients for whom they have not conducted an in-person medical evaluation, provided all of the following conditions are met:

  • The prescription is issued for a legitimate medical purpose by a practitioner acting in the usual course of his/her professional practice.
  • The telemedicine communication is conducted using an audio-visual, real-time, two-way interactive communication system.
  • The practitioner is acting in accordance with applicable Federal and State law

Provided the practitioner satisfies the above requirements, the practitioner may issue the prescription using any of the methods of prescribing currently available and in the manner set forth in the DEA regulations. Thus, the practitioner may issue a prescription either electronically (for schedules II-V) or by calling in an emergency schedule II prescription to the pharmacy, or by calling in a schedule III-V prescription to the pharmacy.

Has there been any guidance related to being able to prescribe when lab tests are required?

The FDA released guidelines related to the use of REMS-required lab testing in order to prescribe certain controlled substances (including Clozapine). They state that providers should consider whether there are compelling reasons not to complete lab tests, or delay them and use best medical judgment in weight benefits and risks of continuing treatment in the absence of lab testing.

Furthermore, the FDA does not intend to take action against those providers for the duration of the PHE for failing to adhere to REMS requirements for lab tests.

What changes have been made to HIPAA?

Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday “non-public facing” communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency.

UPDATED (04/02/2020): The enforcement waiver also extends to failure to enter into a BAA with vendors of non-public facing remote communication and other non-HIPAA compliance remote communication products.

“Public facing” remote communications that are not appropriate to use include Facebook Live, Twitch, TikTok and are not subject to the enforcement waiver

Enforcement waivers apply only to covered entity healthcare providers and not health plans or healthcare clearinghouses.

Furthermore, to what extent the enforcement waiver will apply to these vendors and products will analyze whether there was end-to-end encryption, support individual user accounts, logins, and passcodes to help limit access and verify participants and/or permit participants to assert some control over the interaction.

Are licensure requirements being waived?

Individual states are providing guidance on licensure requirements on an ongoing basis. Currently, 49 states and DC have either waived their licensure requirements, as long as the clinician holds a medical license in another state, or have implemented a temporary emergency licensure process. Arkansas is the only state that has not waived licensure requirements in some form during the PHE. These actions are meant to remove barriers for clinicians to provide services in other states where they do not hold a license or to create an application process wherein applications are reviewed within a very short period of time.

However, waived licensure requirements and the temporary emergency license are only in effect until the public health emergency is terminated or otherwise stated. Ideally, if a clinician is granted an emergency license in a state that will be a permanent assignment for the clinician, they should still proceed with the full, permanent licensure during this time.

Only a handful of states are expediting the process to obtain a full, permanent license. Kansas, for example, is leveraging the Interstate Medical License Compact (IMLC) to expedite the licensure process for physicians who have received a license in another state through the compact within the past 365 days. Wisconsin is also communicating that they are reviewing full applications more frequently.

For more information, please refer to the FSMB’s resource, “States Waiving Licensure Requirements/Renewals in Response to COVID-19”. The resource is updated daily.

UPDATED (04/17/2020): In response to the declaration of a national emergency and emergency declarations by all states, many health care entities have taken unprecedented steps regarding licensure portability and the deployment of skilled health workforce resources. These health care entities rely on the NPDB to make informed hiring, licensing, and credentialing decisions. To support these entities during this national emergency, the NPDB is temporarily waiving query fees (both one-time query and continuous query).

The waiver is retroactive from March 1, 2020, through May 31, 2020. The NPDB will issue query credits to reimburse entities that conducted queries (one-time and continuous) between March 1 and the implementation of the fee waiver.

Are states granting extensions on existing provider license renewals and/or to fulfill CME credit requirements?

States may begin to extend any renewal periods for provider licensure renewals or adjust requirements to fulfill CME requirements as administrative offices are closing or the inability to attend live trainings (e.g. Illinois has extended renewals through September 30 if the licensee was to renew between March 1-July 31).

Are sites able to expedite the privileging process?

Guidance on this topic is still ongoing. Under the Department of Health and Human Services (HHS) and the Health Resources and Services Administration (HRSA), if there is a public health emergency declared, health centers that receive funding under Section 330 of the Public Health Service Act (PHSA), such as FQHC’s and CHC’s, may grant providers temporary privileges by the CEO of the impact health center and reviewed by the applicable clinical department head and/or CMO. The relevant areas that may allow for expedited review and verification that could occur that includes confirming: Identity, Professional Credentials, Claims History, and Fitness/References. Additionally, the AHA (American Hospital Association) sent a letter to HHS on Monday requesting the ability to have expedited or presumptive credentialing and privileging (along many other exceptions which some have been addressed - e.g. HIPAA, Telehealth Technology, etc.).

UPDATED: Additionally, if a state has requested for a Section 1135 waiver, they may include the ability to help facilitate any credentialing and privileging that is needed with payors to help expedite them to submit claims for services rendered by the providers. Currently 49 states have applied for and granted such waivers.

What changes have been made to Medicare telemedicine restrictions?

Medicare has temporarily expanded previous restrictions on telemedicine services. Firstly, the Coronavirus Preparedness and Response Supplemental Appropriations Act allowed the Secretary of Health and Human Services (HHS) to waive the geographic and originating site requirements within Medicare. With this change, Medicare beneficiaries can receive services in their own homes without having to be located in a rural or health professional shortage area. Furthemore, with the recent enactment of the CARES Act, the modality requirement is now open to phone based, audio-only services. Previously, only real-time, audio-visual technology could be used. The CARES Act also relaxed the requirement that the provider must have seen a patient within the past three years in order to be reimbursed. For more information, see the Center for Connected Health Policy’s Telehealth Coverage Policies in the Time of COVID-19.

UPDATED (05/01/2020): CMS released a second round of changes that further expand their telehealth policies during the public health emergency.

Modality Use and Payments: One of the biggest changes CMS made is to waive the requirement that services had to be provided using video-technology. Now, audio-only telephone services can be utilized for evaluation and management services and behavioral health counseling and education services. CMS is also increasing payments for these telephone visits to match payments for similar office and outpatient visits. For a list of eligible codes and whether or not they qualify for audio-only, please refer to CMS’ list of covered telehealth services for PHE.

Additional Originating and Distant Site Changes: Hospitals can now qualify for the originating site facility fee for telehealth services furnished by hospital-based clinicians to Medicare beneficiaries registered as hospital outpatients even when the patient is at home. Furthermore, CMS is now paying for telehealth services provided by RHCs and FQHCs serving as the “distant site." Previously, these clinics were not paid if they were serving as the “distant site,” only if they were the “originating site.”

Types of Providers Eligible for Telehealth Reimbursement: Related to the types of clinical practitioners that can furnish Medicare telehealth services. Prior to the PHE, typically only physicians, nurse practitioners, physician assistants, and certain others could deliver telehealth services. Now, other providers including physical therapists, occupational therapists, and speech language pathologists would also qualify for reimbursable services.

Changes to the Rulemaking Process: when CMS previously added new services that would be reimbursable via telehealth, they would use its rulemaking process. CMS is changing its process during the PHE to speed up the ability to add telehealth services on a sub-regulatory basis by considering requests from practitioners now learning to use telehealth and its effects.

Are state Medicaid programs also making changes during this time?

Individual state Medicaid programs are currently coming out with guidance on an ongoing basis. States are applying for Section 1135 waivers in order to make changes and offer flexibilities in providing resources to their state beneficiaires. Florida, for example, was the first state to submit and be approved for their Section 1135 waiver request to remove unnecessary barriers on clinicians such as prior authorization requirements. CMS has now approved an additional 48 state Medicaid waivers. These waivers are effective as of March 1, 2020 and will end once the public health emergency has been terminated.

UPDATED: Individual state Medicaid reimbursement policies continue to be updated. The Center for Connected Health Policy (CCHP) has provided a good resource on what changes each state has enacted.

What type of virtual services and what codes may apply for Medicare beneficiaries?

CMS has provided a fact sheet of 3 ways that the patient may receive care and what codes the provider may submit which is summarized in the chart below. Additional CPT codes and guidance from CMS related to updated codes can be found here.

What is the Coronavirus Aid, Relief, and Economic Security (CARES) Act doing related to helping healthcare providers and organizations receive assistance to help sustain operations and/or increase access to patients through alternative services like telehealth?

As part of the CARES Act, healthcare providers and facilities who received Medicare fee-for-service (FFS) reimbursements in 2019 may begin to receive payments for relief (not loans) to assist with having to cease operations or who are struggling to keep their doors open from patients delaying care or cancelling services. Here is a link that provides more information including eligibility and how the payments are distributed.

UPDATED (05/01/2020): On April 10, as part of the CARES Act, the FCC announced began accepting applications to assist healthcare providers with funding to purchase and receive the connectivity and devices they need to care for patients remotely. In order to receive funding, providers may qualify as part of a consortium or as an Healthcare Provider (HCP) site (e.g. Community Health Center, Rural Health Clinic, Non-profit hospital).

If you are in crisis, call 988 to talk with the National Suicide Prevention Lifeline, text HOME to 741741 to connect to a free crisis counselor, or go to your nearest emergency room.