COVID-19 Teletherapy Policies for Behavioral Health Providers (BHPs)

Martha Saucedo
Martha Saucedo
Last updated 
COVID-19 Teletherapy Policies for Behavioral Health Providers (BHPs)
Winston-Salem, NC 
3-15-20 (initial)
3-18-20 (revised) 
Prepared by: Linda M. Nicolotti, PhD and Aubry N. Koehler, PhD
These policies are recommended for Behavioral Health Providers (BHPs; e.g., counselors, psychologists, clinical social workers, psychiatrists) within the WFBH system during the COVID-19 pandemic.  
When should this take effect?
This policy should take effect immediately given the rapidly developing situation concerning COVID-19 in our community and the expanded use of teletherapy visits.  Consult WFBH policy daily for updates to these policies.  Discuss the timing of implementation of changes to service delivery with Medical Directors as there may be variability depending on the patient population and clinic. At this time, less-essential clinical personnel have been advised to reduce patient contact per WFBH policy. As such, BHPs should consider transitioning to teletherapy, as opposed to face-to-face patient care, in an effort to decrease exposure to and transmission of COVID-19 when at all possible. 
Please note that, as of March 17, 2020 the Office for Civil Rights (OCR) at the Department of Health and Human Services has issued notification that “OCR will exercise its enforcement discretion and will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules against covered health care providers in connection with the good faith provision of telehealth during the COVID-19 nationwide public health emergency.”  
The protocol set forth below assumes availability of HIPAA compliant video-conferencing platforms. However, in the absence of availability of these platforms, BHPs should work with their supervisors and system administrators to balance patient care, WFBH policy/procedure, ethical obligations, and current OCR regulations/allowances to determine the best course of action.
Outpatient Therapy
  • BHPs should prepare their patients for transitioning to teletherapy for the coming weeks and months. 
  • Should patients not be amenable to teletherapy, discuss community alternatives, but also caution them that face-to-face outpatient behavioral health services may be difficult, if not impossible, to obtain at this time due to the evolving pandemic.
  • For noncritical patients receiving supportive services, the continuation of therapy can be optional at this time depending upon patient preference.  
  • For patients at the highest level of risk, for whom teletherapy is contraindicated, they may have a face-to-face session under the circumstances that: 
    • The BHP is able to come to clinic and is not sick (consult WFBH and CDC guidelines)
    • The patient or person bringing them to appointments is not sick (consult WFBH and CDC guidelines)
    • The patient is amenable to coming in for a face-to-face appointment
    • The session does not violate WFBH policy regarding COVID-19 restrictions and taking into account CDC recommendations and state and national directives. 

    • The benefits of a face-to-face session outweigh the risks of possible exposure to COVID-19.
  • When using personal home phone/cell phone to deliver patient care, dial *67 followed by the patient’s number to ensure your number is “blinded” to the patient.  Do NOT give out your personal phone number to the patient.  Rather, direct the patient through your Clinic Patient Service Representative (PSRs; i.e., front desk staff), My Wake Health (if there is access), or the Access Center (336-713-4500) for callback needs.
  • When the BHP is able to establish connectivity with the patient (by phone or videoconferencing) to conduct teletherapy, BHP will send an inbasket message to the Clinic Patient Service Representative (PSR) alerting PSR to “arrive” the patient. This will allow for the session to be billed and the encounter to be closed following the visit. 

Outpatient Assessment

Care should be taken in conducting psychological testing via phone or videoconference as this format may result in invalid test results.   
Notifying Patients
  • Behavioral Health Providers should contact (by phone) patients with previously scheduled face-to-face visits to discuss transitioning to teletherapy.  See Appendix B. 
  • Patients should be notified about changes to care delivery as soon as possible via an outgoing letter, phone calls, and My Wake Health (if there is access). See Appendix A for the draft of this letter. 
  • Access Center should be given appropriate instructions for patients calling in for appointments (see Appendix B).  Behavioral health coordinators, when available, can also assist with calling to notify patients.  
Integrated Care Clinics
  • Screenings - The continuation of psychosocial screenings usually performed by the BHPs (e.g., PHQ-9/PHQ-A, GAD-7, CRAFFT, etc.) should be discussed with the Medical Director of the clinic if clinic visits are to continue. It will be left to the discretion of the Medical Director whether or not to continue psychosocial screeners during clinic visits in the absence of an onsite BHP.  If the medical providers proceed with psychosocial screenings, the BHP will be available for remote consultation with medical providers and/or patients and family members by phone per the usual schedule.  The medical provider will likely have to take increased responsibility for the screening measures and results in the case that psychosocial screenings are continued.   
  • Warm Handoffs - At this time, face-to-face warm handoffs to the BHP will not be offered in an effort to decrease exposure and transmission to, from, and between non-essential clinical personnel (including BHPs), other providers, and patients/family members.  Should medical providers encounter patients in need of behavioral health support, medical providers should reach out to the BHP by phone or through the Electronic Health Record to coordinate BH phone or video-conferencing follow-up.
Inpatient Consultation/Liaison
Inpatient medical consults should be conducted remotely if at all possible, rather than face-to-face with the patient and/or family members.  The BHPs will continue to be available for inpatient medical consults per the usual schedule located on Wake On Call. Medical providers should reach out to the BHP by paging them to initiate a consult per the usual procedure. Follow-up with the patient will be conducted via phone (patient room phone or cell phone of patient/caregiver) or via a teleconferencing platform.
  • Department of Psychiatry and Behavioral Medicine is on-call to the medical hospital as well, and they should be available for inpatient consults in addition.  Department of Psychiatry and Behavioral Medicine can advise on policy regarding psychiatry involvement with consults on the inpatient medical unit. 
Phone and Videoconferencing Sessions
Phone sessions are acceptable and expected to be billable, if retroactively.  Use phone sessions if videoconferencing with patients is not available or if patients do not have access.  If videoconferencing is accessible to the patient, this is the preferred mechanism of session delivery. Videoconferencing is also expected to be billable, if retroactively.  
  • When using a personal home phone/cell phone, dial *67 followed by the patient’s phone number to ensure your number is “blinded” to the patient.  Do NOT give out your personal phone number to a patient; rather direct the patient through your Clinic PSRs or Access Center (336-713-4500) for callback needs. 
  • If using a videoconferencing platform, consult with WFBH policies.  Dr. Josh Brown, Director of Telehealth Services, has identified appropriate video-conferencing platforms for use in teletherapy.  
  • At the beginning of each teletherapy session, in case of emergency, the BHP MUST always obtain from the patient the patient’s current location address (ideally their home).
  • First Session:  The BHP must obtain from the patient the name and phone number for an Emergency Contact Person during the patient’s first teletherapy session.  In the case of a minor, this will be the parent or legal guardian. This information is required to enhance patient safety in case of emergency. 
    • The Emergency Contact Person’s name and phone number (along with the date information was gathered) should be documented in the medical record in both the session progress note as well as in the social history tab.
  • BHPs should gain knowledge about and competency with the technology associated with the teletherapy platform prior to using this with patients.  BHPs should also be aware of the limitations (e.g., emergency management, information security, ability to deliver certain modalities of therapy via teletherapy, etc.) and the potential impact of this mode of therapy with patients. 
  • Telehealth trainings and information are in the process of development through WFBH.  There are also trainings through American Psychological Association and Telebehavioral Health Institute, among others.  BHPs are encouraged to participate in telehealth trainings as soon as possible if you are planning to use teletherapy.  
  • Phone and video-conferencing sessions have separate CPT codes, which should be utilized.  See below. 
  • Schedulers will need to be trained to send out appointment invitations via the video-conferencing platform.  Details to follow.  
  • The BHP may need to consider altering their scheduling template if BHP expects sessions to be of shorter duration than is typical during face-to-face sessions.  
Conducting Teletherapy:  First-Session Questions
Teletherapy with At-Risk Patients
Patients with the highest psychiatric risk (e.g., suicidal, homicidal) should be followed regularly via teletherapy services if they cannot be seen in person.  If there is a patient who is expressing active risk to self or others:  
  • Assess for ideation, plan, access, intent.  If they have passive SI/HI without plan or intent, discuss coping plan, safety planning, and ensure that they have crisis numbers (Cardinal Innovations 24/7 Access/Crisis line 1-800-939-5911; National Suicide Prevention Lifeline 1-800-273-8255; Crisis Text Line 24/7 support: Text “HOME” to 741741). 
  • If patient is expressing a specific SI plan or intent to harm self: 
    • Gauge patient’s willingness to connect with social supports remotely or otherwise.  

    • If the patient is an adult, request names and numbers of social supports or utilize the emergency contact person, identified at the first session.  Attempt to obtain the patient’s verbal consent for BHP to reach out to supports to carry out a safety plan (e.g., removal of firearm(s), medication stockpiles, etc.). 
      • If a patient has no social support, refuses to share this information, or does not consent to BHP contacting supports, then BHP should engage Mobile Crisis or 911.  

      • If the patient is a minor, inform the legal caregiver of the situation, safety plan, etc.  If the legal caregiver refuses to engage with a safety plan, is not reachable, or does not think they can keep the patient safe, BHP should engage Mobile Crisis or 911.  

      • Mobile Crisis #: 1-866-275-9552 or 336-607-8523 (Daymark Recovery Services in Forsyth)

  • In the case that a patient has reported a specific HI plan and/or identified victim(s) with possible intent, call law enforcement in the county where the patient resides or 911, and alert the potential victim if this information is available. Reporting of HI should proceed per usual ethical and legal guidelines.
  • If you suspect that a patient has been abused and is not safe in the home environment, call local law enforcement in the county where the patient is located or 911.  If the suspected abuse pertains to the safety of a minor, elder, or incapacitated adult in their home environment, also call DSS.  Reporting of suspected abuse should proceed per usual procedure.  
Privacy/Confidentiality during Teletherapy Sessions  
  • Behavioral Health Provider: If the BHP will be conducting teletherapy from home, the BHP should take every precaution to select a location in their home that is conducive to HIPAA compliant practice (out of earshot of other household members, quiet environment, professional appearance [if video-conferencing] and demeanor; removal of personal items [e.g., photos] in background).  
    • If there is any paper documentation during teletherapy sessions conducted from the BHP’s home, utmost care should be taken with paper records to keep these confidential (in a locked file cabinet in a room that is locked).  Paper documents need to be in a locked case and secured for transport back to the WFBH setting. The BHP should avoid paper documentation from home if this is not necessary. 
  • Patient and legal caregivers (in the case of a minor): Patients and legal caregivers should be educated as to the limitations of confidentiality when using teletherapy. They should be encouraged to conduct sessions in a location where they can have privacy out of earshot of other household members and in a quiet environment, if possible.  
    • If disruptions occur during sessions, BHPs should be mindful of this, and pause the session if necessary. If the disruption to the session is prolonged, the patient and BHP will determine whether the session is to proceed or be rescheduled for a better time. 
Informed Consent
Informed Consent for phone and videoconferencing is required.  If the adult patient or legal caregiver is not able to sign the consent form given that they are in a different physical location than the BHP, review the form with them verbally by phone or videoconference, and obtain verbal consent that is documented in the medical record.  See Appendix G for the teletherapy informed consent. See Appendix C for the Wake One smart phrase. 
Well-being of Behavioral Health Provider
If a BHP is concerned about their own health vulnerability as related to COVID-19, the BHP should work from home (when well) and conduct sessions with patients by phone or teletherapy platform (when available) rather than conducting in-person sessions. 
Medically Vulnerable Patients  
As psychologists, we are not qualified to determine who is medically vulnerable, even though some cases are more obvious. The medical subspecialist or PCP should make the determination about medical vulnerability. This is relevant if the hospital policy varies based on medical vulnerability of the patient.  
  • Use of Personal Protective Equipment (PPE) should be limited.  As such, students and learners should not have contact with patients for which PPE is required.  This should be as of immediately. 
  • Supervisors may conduct necessary ongoing supervision by phone or videoconference. 
    • Verify with the supervisee’s educational institution that phone or videoconference format for supervision is acceptable given the current circumstances.  
    • Ensure quality of supervision through phone or video-conferencing format. 
    • Ensure that supervision session length is not compromised by phone or video-conference format so that supervisee is meeting supervision requirements.  
    • Consider that the supervisee may not be able to meet face-to-face patient contact hours during this medical crisis.  This should be addressed with the supervisee’s educational institution. 
Billing Guidelines/Considerations
  • Insurance Companies
    Blue Cross Blue Shield NC announced it will cover all care delivered via telemedicine as if it were face-to-face. This will be for a 30-day period (March 6-April 6), although they request that providers not bill the system until later in March. 
  • Medicare
    The Centers for Medicare and Medicaid Services (CMS) has waived certain requirements for Medicare Advantage and Part D Medicare plans to help prevent the spread of COVID-19. Flexibilities include: 
    • Waiving cost-sharing for COVID-19 tests
    • Waiving cost-sharing for COVID-19 treatments in doctor's offices or emergency rooms and services delivered via teletherapy
    • Removing prior authorizations requirements
    • Waiving prescription refill limits
    • Relaxing restrictions on home or mail delivery of prescription drugs
    • Expanding access to certain teletherapy services
  • NC Medicaid
    NC Medicaid will phase in its expansion of coverage as needed. For now, beginning today, March 13, "designated providers" (MD/DO/PA/NP) will be able to bill "telephonic codes" for established patients. These are short, check-in visits that might be appropriate for medication refills, etc. There is also a new set of CPT codes that psychiatrists can use (99441-3) that are timed codes for routine patient follow-ups. There are separate codes that can be used by other behavioral health providers in your practices. NC Medicaid notes that it is important to use the "CR" modifier on all billing. The modifier prevents it from being rejected if they have billed an E/M code within the last 7 days or within 24 hours after the phone call. There are two goals for these changes: 1) reduce patient exposures for routine office visits, and 2) make provisions for physicians who will need to work from home for a variety of reasons. 
    • Please connect with your department billers/coders on the most up-to-date information regarding any additional modifiers that may need to be added to the visit to ensure that it is properly coded and reimbursable.
  • It is important to note that patient clinical needs are the priority over billing. If a patient is in need of a clinical service and the service is not billable, the BHP should provide the service. 

Appendix A
Letter to patient re: teletherapy 
Behavioral Health Team
Wake Forest Baptist Health
Dear Valued Patient,
We are writing to inform you that any outpatient behavioral health visits conducted by your provider [insert BHP name] will be converted to teletherapy in response to the ongoing risk of COVID-19, the Coronavirus.  This means that your sessions, which previously took place face-to-face, will now be conducted by phone or videoconference. 
For future behavioral health visits, please be aware of the following:
  • Do NOT report to the clinic at the time of your appointment; your appointment will be conducted by phone or videoconferencing. 
  • Check that the phone number(s) in your medical record are up-to-date and reflect where you would prefer to receive your provider’s call.  You can check and/or update your numbers through your Clinic Patient Service Representative (i.e., front desk staff), My Wake Health, or the Access Center (336-713-4500).
  • At the time of your appointment, be prepared to receive your provider’s phone call in a location where you can have privacy and in a quiet environment, if possible.  For most, this will be at home.  
  • Because providers may be working from home, note that a phone call may come through as an “unknown number.”
  • You and your provider will determine whether your visits will be conducted by phone or videoconference based on your access, preference, and the best clinical care.  
  • If you will be using videoconferencing, your behavioral health provider will ensure that you have the proper instructions for use.  
If you have any questions or concerns about engaging in teletherapy, please reach out to your provider through your Clinic Patient Service Representative (i.e., front desk staff), My Wake Health, or the Access Center (336-713-4500).  
Thank you for understanding as we adapt to offer you the best care possible with awareness for the ongoing COVID-19 health crisis.

Appendix B
Access Center script for teletherapy scheduling
  • For return or new patients calling regarding scheduling for a behavioral health appointment on or after (date to be determined; may differ for individual providers), state the following:
Return Patient Visit
  • “Due to the ongoing health risks related to COVID-19, the Coronavirus, your face-to-face appointment is being converted to a teletherapy appointment.  This means you will not be seen in person at the clinic. Instead, your visit will be conducted by phone or video-conference with your provider.”
New Patient Visit
  • “Due to the ongoing health risks related to COVID-19, the Coronavirus, your newly scheduled appointment will be conducted by phone or video-conference with your provider.  You will not be seen in person at the clinic.”
All Patients (both new and return)
  • “Do NOT come to the clinic at the time of your appointment. 
  • “May I confirm that the phone number(s) in your medical record are up-to-date and reflect where you would prefer to receive your provider’s call?”
  • “Your provider requests that you are in a location that is private and quiet during your teletherapy visit.”
  • “Please be aware that your provider’s call may come through as an ‘unknown number.’ ”
  • If patients have questions or concerns about teletherapy, Access Center should send an inbasket message to the provider or designated Work-Q. 

Appendix C
Smart Phrases
  • Use of teletherapy - consent:  “The informed consent form for teletherapy was read to .name (adult patient) or legal guardian (insert name) of .name (minor patient).  Benefits and potential risks of this mode of therapy were discussed.  Limitations to confidentiality when using teletherapy were reviewed.  The adult patient or legal caregiver of minor indicated understanding of the consent form and expressed agreement with the content therein.  Verbal (spoken) consent to conduct teletherapy services was obtained by (or legal guardian) for services administered to .name commencing on .date.   It was discussed that teletherapy is a billable service, and insurance or patient (if no insurance) will be billed accordingly.” 
  • Use of teletherapy - encounter:“Due to the health risks associated with COVID-19, it is necessary to conduct this visit via teletherapy. Mode of teletherapy used during this session was (state whether phone or videoconference and which platform).”  

Appendix D
CPT Codes
Teletherapy CPT Codes
Phone Session CPT Codes:The following codes will be used to report behavioral health telephonic assessment and management by a licensed non-physician behavioral health professional (licensed clinical social worker (LCSW): licensed clinical social worker associate (LCSW-A); licensed professional counselor (LPC); licensed professional counselor associate (LPC-A); licensed marriage and family therapist (LMFT); licensed marriage and family therapist associate (LMFT-A); licensed clinical addiction specialist (LCAS); licensed clinical addiction specialist associate (LCAS-A); psychologist and licensed psychological associate (LPA):
  • 98966: Telephone assessment and management service provided by a qualified non-physician health care professional to an established patient, parent or guardian not originating from a related assessment and management service provided within the previous 7 days not leading to an assessment and management service or procedure with the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
  • 98967: Telephone assessment and management service provided by a qualified non-physician health care professional to an established patient, parent or guardian not originating from a related assessment and management service provided within the previous 7 days not leading to an assessment and management service or procedure with the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion.
  • 98968: Telephone assessment and management service provided by a qualified non-physician health care professional to an established patient, parent or guardian not originating from a related assessment and management service provided within the previous 7 days not leading to an assessment and management service or procedure with the next 24 hours or soonest available appointment; 21-30 minutes of medical discussion.
Video-conferencing CPT Codes: 
Information is forthcoming. 

Appendix E
Important Numbers
  •  24/7 Crisis Lines 
    • Cardinal Innovations 24/7 Access/Crisis line: 1-800-939-5911
    • National Suicide Prevention Lifeline: 1-800-273-8255
    • Crisis Text Line 24/7 support, Text “HOME” to 741741
  •  Mobile Crisis 
    • 1-866-275-9552 or 336-607-8523
    • **OR** 911

Appendix F
Provider Resources 
1.     American Psychological Association (APA) Guidelines for the Practice of Telepsychology 
  • It is recommended that BHPs who will be using teletherapy with their patients read and understand these guidelines prior to commencing teletherapy sessions with patients.  
  • Note that during the medical crisis, in-person therapy may not be an option at this time, even for high-risk patients, so all patients in need should be offered teletherapy.  When face-to-face sessions are possible in the future, these in-person sessions should be offered, and patients should be transitioned back to in-person therapy.  This is especially the case for high-risk patients.  Should teletherapy remain an option for patients in the future once the health crisis pases, the APA telepsychology guidelines regarding goodness of fit for teletherapy should be adhered to.  This refers to Guideline 2: Standards of Care in the Delivery of Telepsychology Services. 
2.               American Psychiatric Association Resources
3.               PESI
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Appendix G
Consent Form
Wake Forest Baptist Health
 (Adapted from Julie A. Jacobs, PsyD, JD)
This authorization and consent to participate in teletherapy is not a substitute for Patient Consent for Treatment and HIPAA Notice of Privacy Practices, which should be completed separately at the initiation of services with adult patients or legal caretakers. 
Definition and Details: Teletherapy refers to counseling/therapy services that are provided remotely using phone or videoconferencing.  To participate in videoconferencing, there is necessary technology, hardware, software, internet access, and competency with technology that is required.  The patient or legal caregiver and provider together will determine the best form of teletherapy to use during sessions based on access, patient preference, and clinical indications.  If a patient will be using videoconferencing sessions, they will receive the appropriate instructions in advance. 
Patients are entitled to the same rights and have the same responsibilities as with face-to-face sessions.  Providers will maintain the same level of ethical conduct and protection of privacy, including the maintenance of records, as with in-person sessions. 
Benefits and Risks:  
Benefits: Benefits of teletherapy include: a) patient and provider do not have to be in the same physical location, promoting more consistent visits and easier access to care, b) saving time and money involved with traveling to and from appointments, c) teletherapy can be as effective as in-person therapy, d) allowing for therapeutic visits to continue in the context of social distancing recommendations to limit the spread of Coronavirus (COVID-19).  
1)    Confidentiality.  Your provider will ensure that your sessions are private and confidential to the extent possible.  However, there may be challenges with confidentiality using telehealth including: the potential for others to overhear sessions on the patient’s end and technology-related issues (e.g., others accessing your private conversations or stored information without your knowledge).  It is recommended that you are in a private and quiet place during your session to maximize privacy. 
2)    Interruptions during the session.  (a) While privacy is a priority during teletherapy, unexpected interruptions may be more likely to occur outside of the therapist’s office.  (b) Technology may unexpectedly stop working during a session. If the connection is lost during a session, your provider will try to reconnect with you immediately and then every 5 min for 15 minutes or until your session time has expired.  If your provider is unable to reconnect with you during the session time and the situation is not urgent, your provider will reach out to schedule a follow-up session at a later time.  If you are disconnected from your provider and your provider is unable to immediately reach you during an urgent or emergency situation, your provider will contact your emergency contact person and might call 911 or the Mobile Crisis Unit to respond, if necessary.   
3)    Effectiveness. Most research shows that teletherapy is effective.  However, certain aspects of teletherapy may be different and less ideal compared with in-person sessions.  For example, it may be more difficult for the provider to pick up on nonverbal communication during teletherapy compared with in-person sessions.  
4)    Crisis Management.  It can be more difficult and riskier to manage a crisis situation via teletherapy versus in-person.  Given the current COVID-19 pandemic, however, these teletherapy services may be offered to patients in crisis who might otherwise be seen for face-to-face sessions.  To ensure patient safety, the following measures will be taken.
a)    At the beginning of the session, the patient will be required to inform the provider of his/her location address in case of emergency. 
b)    The patient will be required to inform his/her provider of the name and phone number(s) for at least one emergency contact person, who may be contacted in case of emergency.  In the case of a minor, this is usually the legal caregiver.  
c)     f a patient is at high psychiatric risk as determined by the provider, then the provider might require that there be a responsible adult located close-by during the session. 
d)    If a patient is at high psychiatric risk, the provider will work with the patient to develop an emergency response plan to address potential crisis situations that might arise during teletherapy. 
e)    If there is an active crisis situation during the visit, or if your provider is concerned about serious risk of harm to the patient or others, 911 or the Mobile Crisis Unit may be called.  If the patient is a minor, the parent or legal caregiver might be instructed to bring the patient to the nearest emergency department with psychiatric services. 
Financial:  Teletherapy is a billable service, and insurance or patient (if no insurance) will be billed accordingly.  Fees for teletherapy may be comparable to face-to-face session fees. Most insurance companies have wider coverage of teletherapy services in the context of the COVID-19 pandemic. Check with your insurance behavioral health plan or the billing department at WFBH for more information.  There may be additional costs to patients incurred due to data use or technology during teletherapy visits, and patients/legal caretakers are responsible for such costs. 
I have been advised of all the potential risks, consequences, and benefits of teletherapy. My provider has discussed with me the information provided above.  I have had an opportunity to ask questions about this information, and all of my questions have been answered. I understand the information provided herein.
I (name of adult patient or legal caregiver) acknowledge that I have read and understand the policies herein, and I consent for (name of patient) to participate in teletherapy services with (name of provider) starting on (date).  
Signature of adult patient or legal caregiver:___________________________________ 
If signed by person other than patient, provide relationship to patient:__________________

Appendix H
Questions and Answers for BHPs Regarding Teletherapy
Question 1:  If a BHP is unable to enter a telehealth CPT code into LOS or Charge Capture for billing (because it is not yet added to the Wake One system), are they able to use the usual CPT codes for face-to-face sessions?  
--If so, BHP would have to document that the session was conducted via phone or videoconference, and billed as usual face-to-face given contact restrictions due to COVID-19. (create dot-phrase).   
Question 2:  If using telephone CPT codes, because these codes are of shorter duration, is the BHP able to bill more than 1 unit of the code, if the BHP is already billing the maximum time for the code-type.  (e.g., Can be BHP bill 2 units of 30 minutes for a total of a 60 minute teletherapy session). 
Question 3:  Should providers adjust the length of session to be in line with the time-frame of phone or video-conferencing CPT code definitions? 
Question 4:  If the BHP decides to conduct shorter sessions for teletherapy as compared with face-to-face sessions, how should this be reflected with session scheduling and/or with the scheduling template? 
Question 5:  If an interpreter is needed for the session, what is the procedure during teletherapy (phone or videoconference)? 
Question 6:  How do we handle the situation if a minor is home alone during teletherapy visit with regard to safety? Do we require that a minor is not home alone without a responsible adult during the visit?  
Question 7: Are there teletherapy billing restrictions with regard to provider type or licensure type? 
Question 8:  If a patient is engaging in teletherapy/telehealth, what is the best way to document consent for this service? For example, is there a way to get an electronic signature? Does the provider read the consent form via phone or videoconference, obtain verbal (spoken) consent, and then document that this was completed in the medical record?  Can the BHP sign on behalf of the patient with their verbal consent? Does the consent form eventually have to be scanned into the medical record, even if it was not signed? 
Question 9: How does the BHP handle the situation in the case that the BHP calls the patient at the designated appointment time and does not get an answer?  Does BHP wait 5 min and then attempt to call again? How many call attempts and over what period of time (during designated session time) does the BHP call? If the BHP is calling from a personal phone, BHP will not be able to leave a call-back number?  Or should BHP leave call back number for Access Center or front desk staff, who will notify BHP if patient does return the call? 
Question 10:  How does the BHP handle teletherapy/telehealth visits if patient is a minor?  Does BHP establish contact with the adult legal caregiver first? Does legal caregiver have to be in close proximity (same home) in case of emergency during the visit? 
Question 11:  Is there a crisis phone number/24-hour access to mental health services through WFBH for after-hours or times when the main BHP cannot be reached? How should patients be advised in case of behavioral health crisis or emergency when their BHP cannot be reached immediately? 
Question 12:  How do patients complete consent forms for assessment and treatment, HIPAA notice, consent for billing, etc. via teletherapy if they are not “checking in” with front desk staff?