A Social Work Guide to Telehealth in Ohio during the COVID-19 OutbreakOn March 19, NASW Ohio staff recorded a short video for both members and non-members about using telehealth to adapt practice during the outbreak. Watch the video here.
In Ohio, telehealth practice (the use of electronic information and telecommunications technologies to support and promote long-distance clinical health care, patient and professional health-related education, public health and health
administration) is subject to the same standards as traditional practice. The social worker must comply with guidelines for the locations of the social worker and the client. The social worker must accurately represent themselves and
practice within their competencies. Informed consent must be expanded to address additional risks of using technology. July 2021 Update: On June 26th, the CSWMFT Board voted to extend the suspension of enforcement for certain rules pertaining to telehealth to allow licensees to transition toward full compliance of the pre-Pandemic telehealth rules. The suspension of enforcement is in place for 90 days ending September 24th, 2021 and refers to the following requirements: - Requirement to hold an initial face to face meeting (in-person or via video).
- Requirement to obtain written consent prior to treatment.
- Use of a HIPAA-compliant platform that exceeds current U.S. Department of Health and Human Services guidance regarding remote communications during the federal COVID-19 nationwide Public Health Emergency.
Most major private insurance plans and state Medicaid Managed Care plans were covering telehealth services prior to COVID-19 and will continue to do so though certain provisions such as coverage for audio-only services may expire. Regarding reimbursement rates, there is currently no state law or regulation that requires parity in reimbursement for telehealth services, though NASW Ohio has not received any official information about health plans lowering their telehealth reimbursement rates which have generally matched in-person rates. We want to hear about your current experiences with telehealth and your plans for offering telehealth services in the future. Please complete this form to share your experiences>>> Jim Broyles with the Ohio Psychological Association recently compiled the following update regarding various health plans and their telehealth policies. *Note that where Jim references psychologists, the policy can generally be assumed to refer to social workers as well. Anthem Blue Cross Blue Shield Anthem’s emergency policy remains the same and will stay in effect at this point until 9/30/21 “Effective from March 19, 2020, through July 31, 2021, Anthem’s affiliated health plans will cover telephonic-only visits with in-network providers. Out-of-network coverage will be provided where required by law. This includes covered visits for mental health or substance use disorders and medical services, for our fully-insured employer plans, individual plans and Medicaid plans, where permissible. From March 19, 2020, through September 30, 2021, Anthem will cover and waive cost shares for telephonic-only visits with in-network providers for our Medicare Advantage plans. Cost shares will be waived for in-network providers only. We encourage our self-funded customers to participate, and these plans will have an opportunity to opt in.”
Aetna
Aetna is giving no definite ending date to their policy
“Aetna’s liberalized coverage of Commercial telemedicine services, as described in its telemedicine policy, will continue until further notice.
“All member cost-sharing waivers for covered in-network telemedicine visits for outpatient behavioral and mental health counseling services for Commercial plans are active until January 31, 2021. Aetna self-insured plan sponsors offer this waiver at their discretion.”
Medical Mutual Medical Mutual was covering telehealth before the pandemic. During the pandemic they created the following exception to their more permanent policy. No ending date for this exception as been set. “Individual (telehealth) therapy can be conducted by a provider to their patients. At this time, Medical Mutual is waiving the requirement that an initial behavioral health visit be done in person before visits can be conducted via telehealth (telemedicine). Also at this time, Medical Mutual is waiving the requirement that telehealth (telemedicine) visits have a visual encounter. Therefore, telephonic visits with an audio-only connection will be covered.”
Cigna
“During this time of heightened awareness of the novel Coronavirus, COVID-19, and its classification by the World Health Organization (WHO) as a global pandemic, we want to keep you up to date on how Cigna Behavioral Health is working to help support you and your patients with Cigna coverage.
“Many behavioral providers have contacted us about delivering telehealth sessions. While we have been reimbursing for telehealth since 2017, and will continue to do so post-pandemic, we have made some temporary revisions to telehealth requirements to support continuity of care during this unique situation. The following changes are effective through July 20, 2021, unless otherwise noted.
“Please note:
Optum Optum states they will continue their temporary policy which includes audio (telephone only) coverage and waiving the requirement for attestation and use of their telehealth platform through June 30. They encourage those interested to arrange to be permanent telehealth provider: “For the past several years, virtual visits (telemental health) for certain outpatient services have been covered under certain behavioral health plans or Employee Assistance Programs (EAP) offered to members. After the COVID-19 emergency period ends, Optum will continue to allow members to receive certain covered services via the telehealth modality. If you would like to continue to provide telemental health services to our members and permanently participate in our virtual visits network, please visit the virtual visits page on Provider Express. There, you will find information about virtual visits and you can complete an attestation to participate in our virtual visits network. If you are already a virtual visits provider or have already completed an attestation, no further action is required. “If you have any questions about Optum’s standard virtual visits program, please contact our Provider Service Line at 1-877-614-0484, or contact your Provider Relations Advocate.”
Humana Continues to offer coverage for telehealth with emergency policies in place. This includes audio only and cost share waivers. The policy will be in effect through the end of the national Public Health Emergency. However, they note this policy may be terminated by them at any time without notice.
Medicare Adaptation to Medicare’s telehealth policy will continue throughout the national Public Health Emergency. APA and others are currently lobbying congress to make these changes permanent. Please look for your opportunity to support these efforts.
Ohio Medicaid Shortly after the onset of the pandemic last year, the Ohio Department of Medicaid created emergency rules for telehealth to make virtual services more accessible to providers and our clients. These new rules were meant to be temporary, and their expiration was set to coincide with end with the state level public health emergency. On November 15, 2020, a new set of permanent rules regarding telehealth was implemented by ODI which replaced the temporary rules. These may be found here:
https://codes.ohio.gov/ohio-administrative-code/rule-5160-1-18
NASW Member Benefits
Upcoming Webinars: As of July 2021, NASW Ohio is still hosting monthly member meetings. See the schedule, register for upcoming meetings and review past recordings at www.naswoh.org/membermeetings
Recorded Webinars
Thursday, March 19, 2020
Topics: Overview of telehealth policy changes due to public health crisis and NASW Ohio resources.
Watch video
Friday, March 27, 10-10:30 am
Topics: New emergency rules, House Bill 580 for mandatory telehealth reimbursement, documentation tips, ideas for teletherapy with young children, billing
Watch video
Friday, April 3, 2020
Topics: Update from Brian Carnahan, Executive Director of CSWMFT Board on electronic service delivery rule changes, license renewal, scope of practice, out of state practice.
Watch video Friday, April 10, 2020 Topics: CSWMFT emergency rule filing re. telehealth, telephonic assessments, private insurance coverage for telehealth, Medicare reimbursement for telephonic services, community mental health services and COVID-19 impact Watch video
Friday, April 17, 2020 Topics: Billing guidance, waived copays, internet security for you and your clients Watch video Friday, April 24, 2020 Topics: waived cost sharing, verbal consent, workers' rights and protections Watch video Friday, May 1, 2020 Topics: New CMS guidance, safety and health when in-person sessions, contact tracing and HIPAA, anti-oppressive practice post-pandemic Watch video Please review the following:
- Ethics and NASW Standards
- Ohio Licensing
- Risk Management
- Billing
What Telehealth Platform to Use
NASW-Ohio does not endorse any telehealth platform. We do recommend that you do not use a non-HIPAA compliant platform if it can be avoided. The Department of Health and Human services has lessened requirements due to the COVID-19
outbreak. On March 17, 2020 HHS said, “covered health care providers subject to the HIPAA Rules may seek to communicate with patients, and provide telehealth services, through remote communications technologies. Some of these
technologies, and the manner in which they are used by HIPAA covered health care providers, may not fully comply with the requirements of the HIPAA Rules.” HIPAA compliance has been mirroring technological change. Ensuring that your
platform is HIPAA compliant is critical so as to reduce your risk and to maintain patient privacy.
Here are some platforms that are HIPAA compliant (again, NASW-Ohio is not endorsing any of these platforms.) A key element to HIPAA compliance is a signed Business Associate Agreement.
- Regroup Therapy, regrouptherapy.com, free unlimited, secure video conferencing with BAA
- Google G Suite, gsuite.google.com, G Suite can support HIPAA compliance with a BAA, allowing PHI with core apps including Gmail, Calendar, Drive, Keep, Sites, Hangouts, Chat, Hangouts Meet,
and TasksSignal
- signal.org, free, end-to-end encrypted messaging that should qualify as conduit under the HIPAA business associate rule
Insurance Coverage for Telehealth Services
Insurance coverage for teletherapy services is impacted by federal and state laws, as well as individual insurance company policies. Providers should check with their liability insurance and their patient’s insurance plan regarding how
telehealth services are covered. NASW-Ohio is collecting that information now. Medicaid & Ohio providers of telepsychiatry services are reimbursed as long as certain conditions are met. Licensed Independent Social Workers (LISWs)
are eligible telepsychiatry providers for certain services. Exceptions to reimbursement include: the recipient is located in a jail, detention center, prison; the provider is not an enrolled provider, or the provider does not follow
established criteria for the service provided.
Medicare
Medicare Part B (Medical Insurance) covers certain telehealth services. The Medicare enrollee will pay 20% of the Medicare-approved amount for the healthcare provider’s services, and the Part B deductible applies. For most telehealth services,
the Medicare enrollee will pay the same amount that they would if they got the services in person. Part B covers mental health services provided by LCSWs.
Private Insurance
Ohio private insurance companies to cover telehealth services. Many still do, but it depends on the company and policy. To be sure to contact the companies you are paneled with. For a list of private insurance information visit
this link. It is still important to verify with your insurance companies what is covered for your specific plan.
Interstate Telehealth Services
The licensing board for a state has jurisdiction when a client is physically in their state, so that state’s board decides if you are in compliance with their laws and rules when you work with someone who is inside their borders. Quite
a few licensing boards have provisions for licensees of other states to practice temporarily with clients in their state. It is imperative to check the social work licensure rules in the state within which a potential client resides
to determine if you are eligible to practice temporarily. Rules have been changed due to the COVID-19 outbreak. For a list of current state rules (as of March 20, 2020) visit this link>>
Tech To-Dos
- Enable full-device encryption on my desktop PCs, laptops, and smartphones
- Implement a strong password policy, setup a password manager, use two factor authentication (2FA)
- Move to Google G Suite or Microsoft Office 365 for Business for email
- Install antivirus and anti-malware apps Conduct a tech risk assessment
Phone Calls
- The Ohio Counselor, Social Worker, & Marriage and Family Therapist Board permits phone based sessions as long as the first session is done face-to-face (can be video face-to-face).
- You'll need to check with your insurance companies as to whether they cover it. NASW will be advocating for more coverage of phone-based sessions. For more information about what plans are covering phone-only sessions visit this link>>
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