Educational settings and health care facilities across the United States are taking preemptive action to prevent exposure to and the spread of Coronavirus Disease 2019 (COVID-19). Many facilities are turning to telepractice as an alternative service delivery model for continuing to meet needs. For many providers, clients/patients/students, and other stakeholders, this may be their first exposure to telepractice. Be aware of payment and coverage issues as you consider implementing telepractice as an alternative service delivery model during the COVID-19 pandemic.
The coordinating committee of the ASHA Special Interest Group 18 (SIG 18; Telepractice) helped to compile the following list of resources which should be reviewed before engaging in telepractice services:
What to Consider Before Beginning Telepractice Services
- Consider the appropriateness of telepractice for meeting the needs of individuals. There is research on the use of telepractice for certain clinical populations. The U.S. Department of Education [PDF] and Medicaid [PDF] issued guidance that pertains to using telepractice to serve students with disabilities.
- Use of telepractice must be equivalent to the quality of services provided in person and consistent with adherence to the Code of Ethics (ASHA, 2016a), Scope of Practice in Audiology (ASHA, 2018), Scope of Practice in Speech-Language Pathology (ASHA, 2016b), state and federal laws, and ASHA policy.
- Best practice is to use videoconferencing platforms that are encrypted to provide the first level of compliance with the Health Insurance Portability and Accountability Act (HIPAA, 1996) and the Family Educational Rights and Privacy Act (FERPA; 20 U.S.C. § 1232g; 34 CFR Part 99) laws. (See ASHA’s Telepractice Practice Portal page for further information on HIPAA and FERPA as well as U.S. Department of Education guidance on FERPA and COVID-19 [PDF]). Encryption provides the clinician and employer assurance of protecting client confidentiality. The organization/practice should be able to demonstrate encryption of the platform used for telepractice (e.g., having a Business Associates Agreement [BAA] with the videoconferencing company; a BAA is an agreement between the videoconferencing company and your employer that assures that the transmission of information from provider to client and client to provider is encrypted). However, during the Coronavirus/COVID national emergency, the Federal Government has relaxed HIPAA enforcement of federal penalties, providing more flexibilities for health care providers to choose telepractice platforms. See additional guidance from the Office of Civil Rights [PDF]. While this may help many audiologists and SLPs, these loosened regulations do not apply in all situations and do not address regulations governed by FERPA. State governments and third-party payers may also have their own regulations and policies of which providers should be aware. Additional information about this can be found on ASHA’s page related to Payment and Coverage Considerations for Telepractice Services During Coronavirus/COVID-19.
- Ensure that there is a secure location for providing uninterrupted services (e.g., not having others walk into the room where you are providing service).
- Ensure remote access to electronic documentation must be considered to protect client privacy and confidentiality.
- Consult your state’s teacher certification and speech-language pathology/audiology licensure laws regarding use of telepractice.
- Verify that you and the client/student/patient has necessary equipment and internet speed to engage in a telepractice session.
- Verify that a facilitator will be physically present with the client/patient/student who can support your services, if needed.
- Verify contact information for the client/patient/student including a phone number, email, physical address, and relevant local emergency services.
ASHA members are encouraged to be informed and to advise stakeholders and other decision-makers on the implementation of telepractice.
Contact firstname.lastname@example.org for additional information related to coding and payment for telepractice services. For clinical questions, contact email@example.com, firstname.lastname@example.org (health care settings) or email@example.com (school settings).