Can we use telehealth for Initial Mental Health Evaluations?
Yes. The CAMHD is encouraging telehealth as the default method for conducting IMHEs. If possible, we would like the family to stay at home while the IMHE interview is happening. Providers should inform families of the risks and benefits of using telehealth. The risks include that clinical important information could be missed due to not being physically present with the clinician. The CAMHD believes that for most cases telehealth will not impact the ability of the clinician to obtain the most important information during a virtual IMHE. The CAMHD also believes that most clients can be safely assessed from an IMHE from their homes or other community locations so coming into the family guidance center is not necessary in most cases.

Does the CAMHD have a recommendation for what should be included in a telehealth consent form?
A conventional consent form for services is required for all treatment. Telehealth can be added as a service modality to your existing form. Sample: “The family agrees to services offered via telehealth, defined as secure video and audio, in addition to in-person sessions.”

Can we replace in-person sessions with telehealth sessions (UPDATED 3/20/20)?
Yes. Your therapists and programs can DEFAULT to telehealth sessions for all in-home services. Your family guidance centers have been instructed to approve this service method across the board. If the therapist or family guidance center has concerns about using telehealth (e.g., lack of technological resources, poor internet), the treatment team should discuss those concerns together. For clarification on Secure video services for telehealth, it is CAMHD’s standard to use a secure platform that is under a HIPAA BAA with the service provider. For example the DOH has a BAA covering services for telehealth via Zoom. We are most concerned about providing services to youth in this time of crisis.

Using: Zoom, Teams, Webex, GoToMeeting, Vidyo, and similar services is permitted, under a signed BAA with the service and encrypted settings configured. Under CAMHD contracts the requirement is for all therapists in one provider agency to use one standard platform. This is for training & ensuring all therapists support youth and families the same way in telehealth.

As an added clarification on a temporary basis during this Covid19 crisis, CMS issued further guidance that Facetime and Skype may be permitted at the present time, however not permanently.

Please reference:

• COVID-19 & HIPAA Bulletin Limited Waiver of HIPAA Sanctions and Penalties During a Nationwide Public Health Emergency
• HIPAA for Professionals & Emergency Preparedness
• Medicare Coverage and Payment of Virtual Services

Is there a simple way you to explain when we can bill for a phone call?
Updated temporary guidance for telephone calls with affected families:

1. Providers need to make every effort to conduct services via telehealth.
2. Telehealth is defined as audio + video sessions, for Medicaid billing of healthcare services.
3. Should providers be able to reach families and youth via phone calls, and telehealth is not possible (customers without smartphones or other youth circumstances), limited audio- only services are temporarily permitted.
4. Providers must document all services, and the specific reasons for audio phone calls and not telehealth in the first phone call service note. All services still must be completely documented in DAP note format.
5. Service notes must be entered in MAX as “Telehealth = Yes”, and “Audio-Only = Yes”** (** CAMHD will notify providers once this field is added in the next week). These notes must also include filling out the “Provider site” & “Client site” details. Providers sending batch notes will need to enter these Audio-Only notes on the MAX Portal.
6. Services rendered via telephone are subject to additional CSO restrictions and/or limits. (CSO will monitor for appropriateness all notes exceeding 6 units.
7. CAMHD is to reimburse for these services without federal match from Medicaid.