Telehealth Guidelines for Faculty

CPE staff hosted information-sharing discussions with personnel from a variety of campus functional units.  In a session with mental health outreach staff, there was a request for telehealth guidelines.  More specifically, campus personnel requested guidelines for behavioral health approaches.  Below, we have compiled some links and resources to assist in creating service delivery plan for the upcoming fall semester.

State Emergency Orders

The American Psychological Services has compiled a list of state emergency orders and other important information regarding telehealth policies: https://www.apaservices.org/practice/clinic/covid-19-state-telehealth-policies. 

For Kentucky, Status as of June 11, 2020

Existing state telehealth coverage mandate?

YES for commercial health plans (including self-insured plans as permitted by ERISA) and Medicaid; includes reimbursement parity; and patient’s home or office as an eligible originating site.(Ky Rev Stat § 304.17A-138, Ky Rev Stat § 304.17A-005)

Emergency orders expiration

State of emergency declared on 3/6/20 and is still in effect; not yet terminated. 

Temporary COVID-19 policies for Medicaid and private insurance are tied to the state public health emergency declaration. 

Senate Bill 150 signed by the Governor on 3/3/20 temporarily allowing out-of-state licensed providers to provide health care services via telehealth so long as they register with the appropriate board and requiring insurers to cover said services will expire immediately upon termination of the public health emergency.

Emergency state action on coverage of telehealth services?

Insurance Commissioner issued guidance dated 3/18/20 stating that insurers cannot require that the patient have a prior relationship with the provider in order to have services delivered through telehealth, if the provider determines that telehealth would be medically appropriate.

See Kentucky’s Telehealth Program for more information about telehealth coverage and reimbursement policies for both Medicaid and private insurance.

Emergency state action on telehealth reimbursement parity?

CMS Section 1135 Medicaid Waiver approved 3/25/20 allows for reimbursement of payable claims by out-of-state licensed providers not enrolled in the state Medicaid program subject to certain conditions for the duration of the public health emergency.**

Emergency state action to include audio-only phone?

Insurance Commissioner issued guidance dated 3/18/20 temporarily waiving state requirements for HIPAA compliance consistent with the OCR guidance so long as providers use telehealth such as non-public facing audio or video communication products in good faith.

Emergency licensure waiver?

No, guidance from the Kentucky Board of Examiners of Psychology dated 3/13/20 provides that out-of-state licensed psychologists must comply with existing temporary non-resident registration process to provide services, including telehealth, in Kentucky. The Board has temporarily waived the registration fee.

Board memorandum dated 3/25/20 allows out-of-state licensed psychologists employed by the state to provide services immediately upon written notification to the Board and verification of holding an IPC, CPQ or ABPP board certification; out-of-state licensed psychologists to practice temporarily pursuant to the ARC-APA disaster response network upon notification to the Board; and encourages licensees to use telehealth to provide services including electronic supervision to supervisees.

Supervised trainee telehealth services – Telesupervision and Medicaid reimbursement

Postdocs who hold the Psychological Associate license would be eligible to perform telehealth services to Medicaid beneficiaries. Interns and other trainees would not.

Board memorandum dated 3/25/20 states supervision shall not be required to be face-to-face or by direct observation until the state of emergency is lifted. Licensees are not required during this time to seek Board permission for electronic supervision.

Other Resources

American Psychological Association Telepsychology

The content on this webpage, usually reserved for paid members, is being made available to all readers during the COVID-19 crisis to aid the psychology community in their ever-vigilant effort to improve lives. https://www.apa.org/members/your-growth/practice-management/telepsychology/index 

MATRC Telehealth Resources for COVID-19 Toolkit

A compilation of frequently asked questions and requested resources into this COVID-19 Toolkit.  Continuous updates to this Toolkit every day as new questions and resources come to attention.  Bookmarking of this page is encouraged and check back regularly. https://www.matrc.org/matrc-telehealth-resources-for-covid-19/.