Part 5: Crafting an effective telehealth policy for your home health agency
Editor’s note: Our series of posts on telehealth in the home health field concludes today with these pointers for agencies ramping up their telehealth usage. Many home health agencies weren’t ready for this spring’s sudden upsurge in telehealth brought about by the COVID-19 pandemic, and had no pre-existing policies and procedures in place to guide them in providing virtual services. “We’re seeing agencies scramble right now to get together policies and procedures, and figure out how they will use virtual visits within the scope of the individual patient’s plan of care,” said J’non Griffin, owner and president of Home Health Solutions, a nationwide consulting and outsourcing firm for home health, hospice and long-term care. “It’s been a challenge for many of them.” Here are some of her recommendations for consideration in developing an effective telehealth program. These points should help your agency craft its telehealth policies and procedures. Know the rules first. Rules are constantly changing in home health, and the COVID-19 pandemic has bought about a flurry of changes for telehealth with multiple waivers from the Centers for Medicare and Medicaid Services (CMS) exempting agencies from the usual rules. State laws really muddy up the picture, as each state has its own laws regarding telehealth – except for the sates which haven’t addressed telehealth at all. To make it more confusing, some states are allowing temporary waivers from the usual state laws during the public health emergency, while other states aren’t. When it comes to the rules, it’s a jungle out there. Who will monitor the program? Who will keep up with the rules for your agency? Monitoring evolving telemedicine principles and staying abreast of regulatory changes is an important responsibility. At most agencies, a member of the senior management personnel holds this responsibility. You’ll also need to designate a member of your team to review operation to make certain your own agency policies are being followed. Determine specific review procedures which will be used, and how often, and include these procedures in your agency’s telehealth policy. Which staff members will participate? Generally, staff members who are allowed to participate in an agency’s telehealth program will be registered nurses, licensed practical/vocational nurses, nurse practitioners, pharmacists, physical, occupational or speech therapists, social workers, nutritionists and physicians. Your telehealth policy should spell out everyone who will be allowed to participate at your agency. What training will staff receive? Personnel orientation and continuing education should focus on equipment set-up, use, maintenance, troubleshooting, transportation, cleaning and storage.
It’s also a good idea to require personnel participating in the program to successfully complete a specific telemedicine skills competency assessment prior to delivering any services. You will probably also want to require an annual competency review. Set up patient admission criteria. Special rules apply during the public health emergency, allowing COVID-19 patients who might not otherwise qualify as homebound to receive services in the home. Patients must still be certified as eligible for home health services, and a valid face-to-face encounter has to occur, but the rules for both these requirements have changed.
CMS is allowing the face-to-face to be completed at the patient’s place of residence via telehealth now, and the provider who certifies the patient for home health does not necessarily have to be a physician. Medicare allows a nurse practitioner, clinical nurse specialist or a physician’s assistant to certify the patient.
Be aware, however, that state law could still restrict who can certify patients in your state. Some states still do not allow non-physician practitioners to certify patients for home health. While many states have changed their scope-of-practice rules temporarily during the public health emergency, each state is handling this differently, and when the public health emergency ends the old regulations will still apply. You’ll have to check your state requirements and waivers. Your agency’s telehealth policy should specify the types of providers who may certify your patients. When setting up patient admission criteria, be sure to note that a patient-specific plan of care will need to be developed for each patient admitted to your telehealth program. Virtual visits will not be billable visits and should be incorporated as part of the overall plan of care without replacing routine in-person visits. The plan of care must also specifically address how the use of technology is expected to help achieve the patient’s specific goals. Other admission criteria should include the patient's desire to participate, cognitive ability to learn and correctly use the equipment, physical ability to use the equipment, and whether the place of residence has the electrical capacity or other operating requirements to support the use of equipment.
What training will patients receive?
Initial and ongoing training for both patient and caregivers is essential for a successful telehealth program. A patient training session should always be completed prior to initiation of telehealth services, and both patient and caregiver should be asked to demonstrate understanding. Staff should document in the clinical record the training providing and how patient and caregiver demonstrated their understanding and ability to assume designated responsibilities.
Remember that a visit for the purposes of setting up telehealth in the patient’s home, and/or training patient and caregivers will not be a Medicare billable visit on its own, without the provision of another skilled service, unless CMS enacts another rules change.
Consider providing patients written information such as procedures for operating, cleaning and maintaining the equipment, helpful diagrams and pictures and electrical safety tips. You may also want to provide information about what the patient should do if services are interrupted in the event of a natural disaster or severe weather conditions.
Your telehealth policy should spell out how your agency will address privacy issues. How will you address patient privacy rights and ensure that the patient will be protected during all telemedicine transmissions and patient encounters?
It’s recommended, for example, that the patient sign an informed consent prior to being admitted to the program to allow for the interactions and any recording/pictures that may be taken as parts of the telehealth interaction. Have the patient sign a specific consent to photograph. Set up a plan to require patient consent before allowing any additional staff members or an additional remote site to participate in the interactive telehealth encounter. consent. Patient feedback
Be sure to implement a means of collecting patient feedback to help your agency improve its telehealth service. This information can also be helpful in your ongoing performance improvement efforts.
DOES YOUR AGENCY HAVE A SCIC POLICY? If you need help in developing a Significant Change in Condition (SCIC) policy which works under the new PDGM, our webinar can help. It comes with a sample SCIC policy! The webinar addresses questions about whether the OASIS, claim and plan of care have to match under PDGM, how to handle a changing focus of care under shorter, 30-day billing periods, and when to complete the RFA 05 OASIS under PDGM. Click here to read more.