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Telebehavioral Health

RCPA attended the Office of Mental Health and Substance Abuse Services (OMHSAS) telehealth webinar on Monday, January 29, alongside many provider members, regarding the Federal payment conditions related to the delivery of telehealth services and the requirement that the physicians or clinicians must present in the office, or that the client must be in the office during the telehealth session, to meet the guideline. It was explained that despite the standards outlined in the current OMHSAS Telebehavioral Health Bulletin, under the Federal “4 walls” statute, this is a required Federal Medicaid payment condition. These requirements cannot be waived.

The purpose of today’s call was twofold: explaining the “4 walls” requirements, and for providers to give vital feedback to OMHSAS on the impacts, challenges, and barriers to accessing services that this may create for consumers and families. This Medicaid standard remains in effect, and RCPA recommends provider members review their operating practices to ensure compliance.

During this time, RCPA will continue its efforts and work with OMHSAS, the HealthChoices partners, and stakeholders to ensure access to services via telehealth. You can review today’s OMHSAS telehealth webinar slide deck. We are also looking to obtain a recording of the webinar to share with our members.

If you have questions, please contact RCPA Policy Director Jim Sharp. The next RCPA Telehealth Operations Committee meeting is scheduled for Tuesday, February 27; however, we will be reviewing if we need to meet sooner based on current information.

Please share this information with your stakeholder networks.

As organizations continue the practice of telehealth, outcomes continue to support telehealth utilization and expansion, as well as the development of resources and guidance. In the coming weeks, RCPA will release the results of its recent telehealth member survey as a follow up to the original RCPA Telehealth Survey Overview in 2020. This updated initiative, in partner with Woods Services, takes a deeper look into the intersects of service delivery, funding, and satisfaction metrics. This new RCPA Telehealth overview will be available the week of March 29, 2021.

The Department of Health and Human Services recently shared a new best practice guide on telehealth for behavioral health care. Behavioral health – like other areas of health care – has changed significantly due to the COVID-19 public health emergency. It is now easier for mental health providers to offer and be reimbursed for telebehavioral health services. Telehealth can also make behavioral health services safer, more private, and convenient for patients who can access care from their home. Find resources in the telebehavioral health best practice guide on getting started, developing a strategy, billing, preparing patients, and more.

Additionally, in response to the increased use and expanded coverage of telehealth during the COVID-19 pandemic, CMS’s From Coverage to Care (C2C) released two new resources to support providers and patients in making the most of virtual care:

  • Telehealth for Providers: What You Need to Know – Providers can learn how and when to use telehealth. Topics include how to set up telehealth services, how to conduct a successful visit, and how to keep up to date on telehealth payment (particularly for Medicare and Medicaid).
  • Telehealth: What to Know for Your Family – Patients can find out the types of care they can receive through telehealth, how to prepare for an appointment, what to expect during a visit, and more. This resource is also available in Spanish.

Providers and partners can download graphics to post on their social media channels and help spread the word about these new resources. All of these resources can be downloaded at go.cms.gov/c2ctelehealth.

If you have feedback or questions regarding your organization and telehealth, please contact RCPA Policy Director Jim Sharp.