I decided to provide telehealth, or telemental health, services to expand my practice, meet the expectations of my increasingly technology-savvy patient/client population, and to help meet the needs of local underserved populations. I quickly learned that getting ready to start providing telehealth services requires some research and training – my “homework.”
My first step was researching whether my licensing board allows, or at least does not forbid, telehealth. In Minnesota, it is OK.
Next, I researched whether my contracted insurance companies cover telehealth services, and if so whether they have limitations on this coverage. One crucial question is whether they cover telehealth services when the patient/recipient is in a non-clinical setting – most commonly in their home.
In Minnesota we are fortunate because the Minnesota Department of Human Services (DHS) has mandated that:
- Minnesota Medical Assistance cover telemedicine services “in the same manner as if the service or consultation was delivered in person;”
- Telemedicine services are reimbursed at the same rate as in-person services;
- Mental health providers are allowed to bill for telehealth services;
- And, telehealth services may be provided to clients/patients in their home.
The next step was to research the policies of non-MA companies. Most companies make their policies and procedures available online, but it is not unusual that these documents are difficult to locate. When in doubt, call the company’s provider relations staff, who either guide you the information online or just read it to you.
I learned that all except one of the insurance companies doing business in Minnesota cover telehealth services. Some provide more specific information about what they cover, and some just state that it is a “covered benefit.”
Regarding the crucial question of whether they cover telehealth services when the client/patient participates in their home, many insurance companies had policies that did not specifically speak to this. For these companies, however, their provider relations staff consistently told me that as long their company’s policies did not specifically exclude telehealth services in the home, it should not be a problem. Blue Cross Blue Shield of Minnesota is an outlier, as their policies specifically require that the patient/recipient participate in a clinic setting. Since BCBS MN has a contract with Minnesota DHS to manage Prepaid Medical Assistance Program services, and their contract with DHS specifically requires them to cover MA benefits, this would seem to be a problem – for BCBS MN. I have exchanged messages with a BCBS MN provider relations specialist, without progress. There is the option of informing DHS about this – stay tuned.
Here are a couple of take-aways for you from my research: First, I felt that it was important to contact all the companies that I am contracted with, and this meant spending a few hours on the phone. This also meant calling both companies based in Minnesota and national companies doing business in Minnesota. It was, I think, worth it because was able to verify that all except one cover telehealth services provided by mental health providers.
Second, it was not unusual for insurance company staff to have to research my questions. It was evident that telehealth was new to them. All of them were aware of telehealth, but not all were aware of their own company’s telehealth policies.
Third, I did learn that one major local insurance company, BCBS MN< has restrictive telehealth policies that only cover telehealth services when the client/patient receives them at a clinic site. The company specifically excludes telehealth services received in the home as a covered benefit. You want to make sure that your plan for telehealth services fits with the policies of your contracted insurance companies.
Finally, I learned that many of the insurance companies require some documentation before I could start billing for telehealth services. This usually involved completing a one-page form which required me to attest that I:
- Will use a HIPAA-complaint telehealth service,
- Will provide telehealth services in compliance with my licensing board’s requirements;
- Have written policies and procedures that are specific to telehealth;
- Have confirmed that my malpractice insurance covers telehealth services;
- And (required by some, but not all) have completed training for telehealth. No company mandated specific training, but several recommended an online course provided by the American Telehealth Association. There are many other online courses available. Of course, you may be able to attend an in-person training in you community, or one provided as part of a professional conference.
I was able to locate several examples of telehealth policies and procedures online. It was easy to adapt them to create a set of documents that met my needs: an internal telehealth policies and procedures document, a handout for clients/patient about “what to expect for your telehealth services,” and a consent form that they sign before beginning the service. I’ll discuss this paperwork in a future blog posting.
Once I had completed all of tasks, I really felt ready for the next step, managing the technology challenges for providing telehealth – which turned out to be much easier than the startup homework. Stay tuned to MHConcierge for more blog posting as I progress through the process of providing telehealth services.