Telehealth Coverage Post-COVID: What Therapists Should Be Thinking About Now

By Barbara Griswold, LMFT (July 5, 2021)

1. The federal Public Health Emergency (PHE) declaration expires July 19.  What does that mean for us?  Maybe nothing.  It will likely be extended at 3 more months. In fact, President Biden has expressed a desire to extend this to the end of 2021. However, we can’t assume that just because there is a federal emergency declaration in place, telehealth will be covered. While some health plans have expanded their telehealth coverage during this PHE, others have already stopped this expanded coverage. And even within the same plan, you may find some clients have telehealth coverage and others don’t — it can vary by client account. And many states have their own PHE orders, some which already expired (ex. Massachusetts). So, emergency orders may be irrelevant. You need to contact each client’s plan. Do it by phone for the most complete details.
2. 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.
3. Submit claims more often (and encourage private-pay clients to submit superbills earlier) so you can quickly find out if there is a loss of coverage.
4. 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 Single Case Agreement so your client can continue to be covered for telehealth with you.
5. Don’t wait: Talk to all clients NOW about the 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 able to offer telehealth care to clients.
6. Check telehealth and in-person coverage carefully for all new clients before you see them. I know, I always recommend this, but this is more important now than ever. Talk to potential new telehealth clients about the possibility of losing telehealth coverage. As I mentioned in a previous article, one therapist told me she was taking only new clients who live nearby, in case clients were to lose coverage for distance sessions.
7. If practicing across state lines, and 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.
8. If you are not using a HIPAA-compatible telehealth platform, it is a good idea to start switching over now. This means you will need to stop using non-HIPAA compatible platforms like Facetime or the basic versions of Skype or Zoom, and find one that issues you a Business Associate Agreement (BAA). While the HIPAA folks are not enforcing the use of a HIPAA-compatible platform at this time, at some point they will restart their enforcement.  A very incomplete list of platforms that claim HIPAA-compatibility include SimplePractice, Doxy.me, VSee, SecureVideo, CounSol, WeCounsel, Evisit, Updox, Go To Meeting, Skype for Business, Microsoft Teams, Zoom Pro/Zoom Healthcare, Google Meet (G Suite), and Cisco Webex Meetings/Webex Teams (no endorsement implied).

Want to find out what I see coming in terms of telehealth coverage Post-COVID?  Check out my brand new webinar “Telehealth Coverage Post-COVID.”  Get tips on how to avoid treatment interruptions and loss of income, and I’ll help know the biggest mistakes providers are making.  We’ll discuss what to think about if you give up your office, and whether insurance plans will allow you to see clients in another state — click here for more information on the webinar.