Health Information Compliance Alert

Tip: Examine compliance policies and make adjustments as needed.

Whether your organization has been using telehealth services more during the pandemic or are just getting started, it’s always a good idea to assess your compliance measures and make improvements.

“Because the public health emergency triggered rapid growth in telemedicine and remote patient monitoring and other virtual care services, some organizations were better prepared to scale to that than others,” says Terry Fletcher, BS, CPC, CCC, CEMC, SCP-CA, ACS-CA, CCS-P, CCS, CMSCS, CMCS, CMC, QMGC, QMCRC, owner of Terry Fletcher Consulting Inc. and consultant, auditor, educator, author, and podcaster at Code Cast, in Laguna Niguel, California.

“You may want to look at an internal operational review to take a look at what your practice did during this PHE. If you started billing for remote care for the first time during the PHE, you could benefit from conducting a self-assessment. Evaluate if you had sufficient compliance safeguards in place, do you have a compliance program, do you have proper HIPAA policies, what platforms are you using, what statements are in the patients’ files, are you complying with Medicare rules under the flexibility 1135 waiver, and are your contracts in compliance with fraud and abuse laws?” Fletcher recommends.

Many providers may also be interested in expanding the telehealth services they offer in the future, beyond the PHE, because some patients prefer the accessibility when dealing with minor issues, Fletcher notes.

Ultimately, telehealth won’t replace all face-to-face encounters because a clinician cannot, say, palpate a mass remotely, but providers should still be prepared to offer the services and remain compliant while doing so.