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CCBHCs Using Telehealth or Telemedicine

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Certified community behavioral health clinics (CCBHCs) are encouraged to use telemedicine to expand access to services and alleviate workforce shortages.

Definitions of telemedicine and telehealth vary across jurisdictions. SAMHSA uses the federal Medicaid definition of telemedicine:

“Telemedicine seeks to improve a patient's health by permitting two-way, real time interactive communication between the patient, and the physician or practitioner at the distant site. This electronic communication means the use of interactive telecommunications equipment that includes, at a minimum, audio and video equipment... [Medicaid] does not recognize telemedicine as a distinct service.”

By contrast, telehealth is usually used as a broader term. Telehealth typically includes not only telemedicine but also other forms of telecommunication, including asynchronous or “store and forward” systems, which transfer a patient’s data or images for a physician or practitioner at another site to access at a later time. With these systems, the patient and provider do not have to be present at the same time.

Fundamental Telehealth/Telemedicine Considerations

All CCBHCs should consider the following issues, regardless of their state:

  • What type of telehealth/telemedicine/telecommunications are reimbursable by the state (for example, interactive audio-visual, asynchronous, store and forward, remote patient monitoring)?
  • For what services does the state permit telehealth/telemedicine delivery?
  • Which providers does the state permit to deliver services via telehealth/telemedicine?
  • Does the state limit where the consumer must be physically located and where the distant provider must be physically located?
  • Are there state licensure restrictions related to the distant provider?
  • Are there state or other credentialing restrictions related to the distant provider?
  • Does the state permit facility, transmission, and/or other fees to be reimbursed?
  • Does the state require someone to be in attendance at the originating site and, if so, is it reimbursed?
  • Are there any prior authorization or other utilization controls that restrict telehealth/telemedicine use?
  • What security and confidentiality restrictions does the state place specifically on telehealth/telemedicine?

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