Telemedicine Information, Recommendations, and Consent Form

Note: Please see our FAQ page for coverage information

Best Practices for providing Telehealth services:

• Select a product that is secure and HIPAA compliant
• Confirm that you are appropriately credentialed and privileged to provide telehealth services and that your policy complies with documentation and record-retention requirements
• Before providing services, do your best to identify the patient and their location
• Inform your patient of your name and credentials
• Document the visit as you would a telephone message or an office visit. Make sure you are documenting the physical location of the patient and platform of the visit. Keep your notes consistent across the practice and make sure they are easily accessible for future use
• Be careful sharing personal cell phone information with patients and communicating over social media

AMA Resources by State
American Telehealth Association
CMS Telehealth
What to Say During Telehealth Visits with Older Adults

Information for providing Telehealth services:

• The Office for Civil Rights (OCR) at the Department of Health and Human Services (HHS) has announced it will temporarily allow consumer audio or video chat applications for telemedicine use.
• The Centers for Medicare & Medicaid Services (CMS) has waived requirements relegating Medicare payments for telemedicine visits.
• The purpose of these temporary actions is to accommodate telemedicine needs during the COVID-19 health emergency and encourage infection control and outbreak response measures to help control the spread of the infection.

In order to continue to communicate and care for your patients, the use of non-public facing audio or video chats during the COVID-19 public health emergency is permitted.  The purpose of telehealth by means of these routes is not limited to COVID-19 specific diagnoses but any patient care issues that may arise.

For clarification purposes, examples of acceptable non-public facing audio or video chats include:

• Apple FaceTime
• Facebook Messenger video chat
• Google Hangouts video
• Skype

Examples of unacceptable examples of non-public facing audio or video chats include:

• Facebook Live
• Twitch
• TikTok

We are currently in a crisis that has resulted in abnormal circumstances and has launched the use of consumer audio and video chat applications normally noncompliant with the HIPAA Security Rule. Any communication applications use for telemedicine would require a Business Associate Agreement with the vendor.

Recommendations for Clinicians:
Be prepared to use consumer audio and video chat applications to communicate with patients as needed during the COVID-19 health emergency.

For IT/Security Staff:

• Draft Temporary appropriate technology usage policies needed to accommodate telemedicine use
• Accommodate requests for access to non-public facing audio and video chat applications for telemedicine purposes as an appropriate businesses need
• Consider role-based firewall web-filtering rules

For more information on this process, please click here.

Recommendations while utilizing Telemedicine:

• Clinicians should make certain an informed consent discussion occurs when using technology or the phone to treat a patient.
• Healthcare providers should document the results of the informed consent conversation with the patient in the medical record.
• It is recommended that the provider verify the patient’s identity to the best of their ability.

Telemedicine Consent Form template download