Written on August 24th, 2010 by tasha
Nothing is free, unfortunately. And much as I am impressed with the options for video-conferencing, there are important elements to keep in mind.
Deborah Randall of Deborah Randall Consulting, gave a superb overview of things you will need to consider in her excellent session at the Boston NHPCO conference on delivering care across the continuum. Here are some of her observations, along with some commentary of my own:
- CMS has not yet approved telehealth services for universal reimbursement. Currently CMS does reimburse for video-conferencing in rural areas, with special criteria and applications required ahead of time. Universal reimbursement is probably some ways away. Disappointing as this may be, the private sector appears to be opening up to telemedicine. Blue Cross/Blue Shield of Western New York announced plans last spring for an MD/patient video conferencing reimbursement program. In addition, changes are afoot at CMS. The new director is a known change-agent who is merciless in his quest to drive Medicare into a solvent 21st century. The productivity gains of telehealth and video-conferencing point to a high likelihood that Medicare will eventually change its position. It may not replace the face2face requirement for hospice recertification any time soon, but that doesn’t mean there aren’t many other ways to use it cost-effectively.(There’s still time to voice your support for telehealth for recertification, by the way. Select the document type “proposed Rules” and search within submissions “Open for comment” using the keyword “telehealth”. You’ll want to comment on Docket ID: CMS-2010-0213, Medicare Program: Home Health Prospective Payment System Rate Update; Changes in Certification Requirements for Home Health Agencies and Hospices. The site closes for comments September 14, 2010.)
- Check with your insurer. Confirm that your liability insurance carrier understands what you want to do with video-conferencing and that you are covered for these services. (You might also let them know about the reduced mileage you anticipate with staff not having to travel as much to make their “visits.” This may be cause for a reduction in premiums.)
- Be mindful of HIPAA regulations. Web cams are transmitting audio, video images, and medically sensitive content, all of which fall under the definition of PHI (Personal Health Information). As such, you are responsible to make sure that the carrier assisting you with video transmissions is HIPAA compliant. The most popular software for video conferencing, Skype, says that it is encrypted at a reasonably high rate (256 bit), but there have been blogpost wars among techies disputing its security (e.g., Tech Crunch 2010, Computer World 2007, and Wikipedia 2008-2010). And no-one is mentioning whether it meets HIPAA standards. Wish I could be more conclusive.What you want to look for is a carrier that meets new HITECH regulations by providing password-only access; encryption of the transmission; periodic security audits; the ability to report back what username/password logged on to the transmission and when; assistance with breach notification if there is unauthorized access. There is some thought that patients can sign a waiver consenting to unprotected transmission (e.g., the use of Skype) although this latter has not been tested in court.
- Obtain consent: You will likely need to collect additional consents concerning Internet transmission of video information and PHI, especially if you are not using a specifically HIPAA-compliant service provider (e.g., the waiver mentioned above). Before proceeding, you also need to weigh the ability of the patient to understand the consequences and therefore to consent to video-conferencing.
- Research licensing issues: Especially if you are using video conferencing for something like a family meeting, or a consult that involves professionals across state lines, you may need to confirm with your attorney what the licensure requirements are, and from which state, in order to be in compliance with the regulations. (With any Internet-based service delivered in multiple states, there are legal dilemmas concerning which state has jurisdiction on the World Wide Web.)
This is by no means an exhaustive list of logistical considerations. And as Glenn commented last week, you need to have your people procedures in place also before launching a telemedicine venture. But this list seemed to me like a good place to start looking at the hard realities. It certainly brought up some concerns, like licensure and consent, that were not immediately evident to me.
For those of you, like me, who are fans of Deborah’s work, you can see her next at the Second International mHealth Networking Conference in San Diego in September. “mHealth” stands for “mobile Health,” essentially apps and such that leverage the cell phone as the delivery device. (Seems like we’re just wrapping our heads around eHealth and now they are talking about mobile devices. Somehow doing all this on a cell phone reminds me of the quip that Ginger Rogers did everything Fred Astaire did except backwards and in heels. I know I’m going to need to get better glasses!)
Tags: telehealth
Posted in Elder Care, Family Caregivers, Technology
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