8 Things Therapists Should Think About Post-COVID
by Barbara Griswold, LMFT (July 4, 2021)
As I write this, COVID-19 pandemic infection rates are coming down in many areas of the country, and many states are “opening up” after over 15 months in lockdown. But as this happens, and as we look ahead, what should psychotherapists and their clients be thinking about?
- The federal Public Health Emergency (PHE) declaration is set to expire July 19, 2021. What does this mean for us? Well, maybe nothing. It is likely to be extended for another 3 months. In fact, President Biden has expressed a desire to extend this to the end of 2021.
However, we can’t make the assumption that just because this emergency declaration is in place, telehealth will be covered. While some health plans have expanded their telehealth coverage during this PHE, others have ignored the PHE and already stopped their expanded coverage. And even within the same health plan, you may find some clients have telehealth coverage and others won’t — it varies by client account. And many individual states have their own state PHE orders plans there are following, some which have already expired (ex. Massachusetts) So, let me again stress: Emergency orders may not be what insurance plans follow when it comes to telehealth coverage. You need to contact each client’s plan.
- The practical: Clients may lose telehealth coverage at any time, without much notice. So even if you’ve contacted the plan for coverage information, you (or your client) will need to check back often to get updated coverage information.
- Submit claims earlier and more often (and encourage private-pay clients to submit superbills more often) so you can quickly find out about loss of coverage.
- Out-of-network providers and those doing phone sessions may be particularly vulnerable to losing telehealth coverage. If not covered, contact the plan and see if you can work out a special arrangement (often called a Single Case Agreement) so your client can continue to be covered for telehealth for this client.
- Don’t wait: Talk to all clients now about possibility they might lose telehealth coverage, perhaps suddenly. Discuss how this would affect their treatment, and their options, including whether in-person care is an option, whether they would want to continue with telehealth but pay out of pocket, or whether a referral will be necessary. This type of discussion means if coverage is lost you are both prepared, and the client doesn’t feel blindsided. This is particularly important if you have given up your office, and are only are able to offer telehealth care to clients.
- Check telehealth and in-person coverage carefully for all new clients before you see them (but I always recommend this!). Talk to new telehealth clients about the possibility of losing telehealth coverage. One therapist said she was only taking new clients who lived nearby, in case there was a need to switch to in-person sessions to be covered
- If practicing across state lines, seeing clients in a state that has temporarily allowed emergency interstate practice, plan ahead for when emergency declarations are lifted. This planning is crucial to avoid sudden abandonment of the client or breaking the law. Now is the time to look into what that state might require to continue treatment.
- If you are not using a HIPAA-compatible telehealth platform, it is a good idea to start switching over now. This means you should stop using non-HIPAA compatible platforms like Facetime, Skype, and the free version of Zoom, and find one that issues you a Business Associate Agreement, or BAA. While HIPAA is not enforcing the use of these platforms at this time, at some point they will restart their enforcement. An incomplete list of platforms that claim HIPAA-compatibility are listed below (no endorsement implied):
- Skype for Business
- Microsoft Teams
- Zoom Pro and Zoom Healthcare
- Google Meet (G Suite)
- Cisco Webex Meetings/Webex Teams