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Flatten the Curve: Telehealth Expansion Tips While Minimizing Risks

Heather Annolino

Things are moving rapidly. Every day is different. Keeping our healthcare systems up and running is imperative during this global pandemic. One way to alleviate the burden on local health systems so that the limited in-person care can be reserved for those with the greatest need is by expanding telehealth offerings. Using telemedicine or e-visits to triage COVID-19 patients and keep non-COVID-19 patients away from the hospitals will help slow the spread and flatten the curve.

On March 6, 2020 Congress passed a $500 million spending plan to combat the virus by expanding telehealth services during this public health emergency. On March 17, 2020 the Centers for Medicare and Medicaid Services (CMS) announced it would lift additional restrictions on telehealth paid through Medicare. Previously, telehealth visits paid by Medicare had been restricted to older adults living in rural areas or those who have established patient-provider relationships for telehealth care that took place through a rural healthcare facility. This expansion also allows for beneficiaries to receive care in their own homes through devices that support video/audio capabilities.

License portability is key to telehealth expansion

One hurdle is the federal government’s strict telehealth rules regarding state licensing. State licensing rules stipulate that a provider can only provide telehealth care to patients in that same state, which has translated into some physicians having to pay for multiple state licenses – or being unable to provide telehealth care to patients in neighboring states.

The U.S. Department of Health & Human Services, Office for Civil Rights (OCR), the HIPAA enforcement agency, recently issued a Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 National Public Health Emergency. This notice addresses workforce issues through temporary rules and regulations for expedited licensure and portability to give healthcare providers the freedom to practice across state lines, opening the door to larger telehealth networks and improved access to care during the Coronavirus pandemic.

In light of this national public health emergency, OCR is exercising its enforcement discretion and will not impose penalties for non-compliance with HIPAA in connection with the “good-faith provision” of telehealth during the national public health emergency, including telehealth services unrelated to COVID-19.

Tips to implement and expand your telehealth services while minimizing risk

Although from a risk management perspective, telemedicine or virtual visits have lower risk, it is still important to provide consistent processes and protections to mitigate those risks. In times like these when surges are imminent, telemedicine is the best means to still provide care to those who are less sick or screen and triage for COVID-19. Any errors that do occur should be entered into your incident reporting software or healthcare risk management software system such as Ventiv’s Patient Safety event reporting tool. The only way to learn from mistakes is to do analysis. While doing that now might be difficult, when this is all over it will be important to have that data to prepare for the next disaster.

Below are tips to consider when implementing or expanding telehealth services. This will help you develop optimal strategies and the framework for a telehealth program that minimizes your risk and the patient’s.


  • Ensure the facility providing the telemedicine practitioner complies with the Medicare Conditions of Participation (CoP) credentialing standards as well as any national, state and local regulations; modify any existing telemedicine agreements as needed.
  • Consider the relevant licensing and regulatory requirements for Advanced Practice Nurses and Physician Assistants requiring that each hold required licensing, qualifications and experience necessary. Confirm Nurse Practitioners have appropriate collaborative agreement, if required and necessary prescriptive authority.
  • Require that both the hospital and the telemedicine provider have professional liability insurance at a specified coverage level.
  • A few states have defined a distinctive standard of care for telemedicine such as rules about the physician-patient relationship, proper patient identity, electronic prescribing and in-person follow-up.
  • Obtain licensure requirements guidance from the FSMB federal, state, and local governments and government agencies that seek emergency changes to license portability during the COVID-19 pandemic.
  • Develop and maintain a list of telemedicine providers.
  • In addition to clinical notes, ensure that your staff document other details of the telemedicine session such as the mode of service, names of all attendees, sites that were linked and any technical issues or concerns.

Security, Privacy and Confidentiality during COVID-19

  • Develop backup and downtime procedures.
  • Establish secure procedures for patient encounters and incorporate them as part of their permanent medical records.
  • Create ease of access to existing medical records.
  • Implement an effective method of patient authentication.
  • Provide cyber security protections.
  • Use OCR’s suggested applications Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype, to provide telehealth. 
Informed Consent
  • Require patient consent forms and include the following information:
    - Names, locations, credentials and affiliations of the staff involved in the consultation and follow-up
    - Description of the procedure or exam
    - Potential benefits and risks of the procedure or exam
    - Explanation of how care is to be documented and assessed
    - All security measures that will be taken
    - Technology issues that may arise and contingency plans
  • Ensure physicians know the informed consent requirements for telemedicine.
  • Have physicians discuss the benefits and risks of telemedicine verbally with patients before obtaining a signed consent form.
  • Define the scope of service for each type of telemedicine service provided.
  • Criteria for patient selection.
  • Process for managing patient-provided health information.
  • Archiving and retrieval of video and images as applicable.
  • Prescribing practices.
Click here to request a demo of Ventiv Patient Safety event reporting tool that helps healthcare organizations anticipate and prevent patient safety incidents, improve the patient experience, and make the safety culture more transparent and effective. Whether you’re a risk manager, patient safety manager, Ventiv is here to deploy a single enterprise risk software system for your patient safety needs and deliver ongoing support.

Learn more about Ventiv Patient Safety Technology Solutions


Apr 3, 2020

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