As you consider providing teletherapy services, there are additional considerations for your practice. Below are several resources to help you get started. Check out our Teletherapy FAQs page for answers to frequently asked questions.
Security
To ensure you’re complying with HIPAA privacy rules, consider your location when conducting a teletherapy session. Conduct your session in a private, confidential space where no one is within hearing range. Check to see if your governing body has any resources to ensure you’re complying with HIPAA guidelines and your code of ethics when practicing via teletherapy. Below are a few resources to get you started:
- APTA - Telehealth Ethics, Best Practices, and the Law: What You Need to Know
- APTA - HIPAA and Telehealth
- ASHA - Telepractice Ethical Considerations
- ASHA - Telepractice Privacy and Security
Licensure
Currently, providers need to be licensed in the state where they reside and in the states where their clients reside. For example, if you practice in Arizona and service a client in California, you would need to be licensed in Arizona and California. This means you may need to obtain and maintain licenses in more than one state.
However, some governing bodies are working on or have in place licensure compacts. These compacts allow the provider to practice in multiple states. Make sure you check with your governing body and the state’s licensing board to verify licensing requirements before initiation of services. Below are some resources for therapists about licensure compacts:
- Audiology & Speech-Language Pathology Interstate Compact (ASLP-IC)
- APTA Physical Therapy Licensure Compact
- AOTA Interstate Professional Licensing Compact
Billing
Reimbursement for teletherapy can vary by state, services, and payers. Some payers will reimburse for teletherapy services; however, each state and payer has their own policies for billing and reimbursement. Before initiating teletherapy services at your clinic, make sure you check with each payer and get a written response to confirm:
- That services delivered via teletherapy will be reimbursed, and at what rate
- Any guidelines for reimbursement, such as billing, coding, and modifier use
- Additional changes that may need to be on the claim form, such as the place of service code, originating site, or distance site
- How services can be delivered (e.g., real-time or asynchronous)
- Supervision guidelines (if applicable)
- Documentation requirements
- Any additional limitations
Here are some resources to get you started when setting up to bill for teletherapy services:
State Regulations
Some states may have regulations or policies in place surrounding teletherapy. For example, some states may require that the initial visit be in-person before the client can be seen via teletherapy. Additionally, some states may require written patient consent. Below are some resources to reference when finding out what policies your state has implemented, but make sure you review and confirm your state’s published policies or regulations.
- ASHA State-by-State
- Center for Connect Health Policy: Current State Laws & Reimbursement Policies
- State-By-State Chart of Telehealth Laws for Occupational Therapy
- APTA - Legislation and Regulation
COVID-19
Policies and legislation are changing almost daily in response to COVID-19. Governing bodies and other professional organizations have issued statements and compiled resources to help therapists navigate different service delivery models and stay up-to-date with changes to policies and regulations.