Fall 2017: Volume 73, Number 2
By William Thorbecke, Ph.D.
In 2014, legislation to allow mental health professionals the ability to bill for telemedicine services was being introduced. Seeing this as a way to expand ones private practice, board member Bill Thorbeck, Ph.D. proposed developing a telemedicine practice start-up kit as a way for WSPA to stay up on current trends and provide new revenue source by selling the kit. Sara Smucker-Barnwell, Psy.D. was contracted to help develop a great majority of the content. During the process it was decided that the word “telemental health” versus telemedicine or telehealth was proper term to be used for our document. With the help of our executive director’s marketing and association management company WSPA’s Telemental Health Start-up Kit began to take form and was made available for sale at the beginning of November. The following is the introduction of the kit.
With the passage of RCW 48.43.735, (RCW 74.09.325 for Medicaid) a significant change has taken place in the provision of medical treatment. RCW 48.43.735 states “it is the intent of the legislature to broaden the reimbursement opportunities for health care services… Telemedicine is a meaningful and efficient way to treat patients and control costs while improving access to care.” While videoconferencing between physicians or other medical providers improves medical communication for patient care, telemedicine could become a major service delivery mechanism for providing mental health treatment. It would allow mental health providers to conduct psychotherapy through videoconference with their clients as a billable service. RCW 48.43.735 does not mandate coverage for telemental health therapy to a client’s home in 2017 but does mandate it for 2018.
Regence Blue Cross Health Plan recently defined reimbursable telemedicine as a means of billable communication with other healthcare providers and with clients. “Telemedicine services is the use of medical or behavioral health information to improve a member’s health exchanged from one site to another via real time interactive audio and video telecommunication system… services are live, interactive audio and visual transmission of a physician-patient encounter from one site to another using telecommunication technologies. They include transmissions of real-time telecommunications. The provider and patient are physically separated and are at different locations. There is no intervening provider involved in the telehealth encounter. The service provided is diagnostic and treatment focused.”
While billable consultation between medical and behavioral providers for clients would be valuable, RCW 48.43.735 mandates telemedicine that allows psychotherapy with a client in their home could be revolutionary for mental health providers. Telemedicine starts a new mechanism of practice service delivery which may have far reaching impact for psychologists. RCW 48.43.735 mandates that insurance companies cover in home services by 1-1-2018; check with the insurance company if they will reimburse before this time. We have included some insurance company’s telemedicine policy links in our addendum.
What are some of the implications of the new telemental health services, you might ask? The intent of the law is to allow service delivery to be more convenient and encompassing so that, for example, rural clients and clients with significant disability would have greater access to providers. Additionally, the difficulties of traffic congestion and commuter time from jobs and home in the major cities for some clients could be addressed with telemental health. Convenience by video-conference services could be appreciated by some persons that have difficulty leaving the office during business hours. Among digitally savvy clients, videoconferencing is becoming more a part of many people’s common experience and some clients may prefer this type of communication. Creative clinicians may value the opportunity to include family members that are geographically distant through telemental health services. Some clinicians have even utilized telemental health services for in-home, in vivo, hoarding groups. One thing the law currently mandates is that only Washington providers can serve Washington clients given the necessity to have Washington state law govern the medical practice for all providers in the state.
Although there are some exciting possibilities with the new telemental health services, there are some major potential problems that are reviewed in this WSPA packet of information. Telemental health services are evolving and Washington state legislation has established the Washington State Telemedicine Collaborative to make recommendations with yearly reports through 2018 for any needed legislative changes. We would like to periodically update this packet of information to track changes in telemedicine legislation and practice, as well as to gather feedback from our members’ experience with this new service delivery system so that we can share the collective wisdom we have acquired with you.
A major pitfall identified with telemental health involves maintaining confidentiality. Simply, the adequacy of the videoconferencing software is important for confidentiality as well as clearly defining the confidentiality of the client video-conferencing site. Other potential pitfalls involve safety considerations of dealing with clients at a distant site, clinical considerations around the relationship distance that occurs through videoconferencing, establishing an adequate informed consent, and dealing with emergency services in a geographically distant area from one’s clinical practice. One major consideration involves making a decision on the appropriateness of use of telemental health services with clients of significant clinical severity. Given the pitfalls and lack of clear guidance on utilizing telemental health services, it takes clinical judgment to implement telemental health services. Professionally, it would be in our best interests to demonstrate to medical agencies and insurance companies that psychologists have a well-established system to provide telemental health services. It would also help healthcare consumers to have confidence that psychologists have resources and expertise in the provision of telemental health services.
One major benefit of the provision of telemental health services is the ability of a mental health practitioner to provide services to anyone in Washington state. This transformation is likely to result in practitioners being able to advertise on a statewide basis about their ability to provide telemental health services. As the Affordable Care Act has become implemented, many medical practitioners are joining hospitals and other large agencies to shield themselves from the possible changes in the healthcare environment. Large groups have leverage in negotiating their roles with the healthcare exchange and insurance companies. In some areas insurance companies and hospitals are creating joint corporations that some analysts would say make them “too big to fail” and give them leverage in the healthcare environment. For mental health care practitioners, a statewide network of psychologists providing telemental health services can allow a similar large scale of practitioners to compete in this new environment. For example, individual practitioners and small groups could band together to advertise statewide telemental health services in an affordable manner. It would be potentially difficult for practitioners to take on the cost of advertising if this is not the central service being offered. Given the WSPA website features a list of practitioner’s practice information, practitioner information can now promote the expertise and interest of psychologists that provide telemental health services.
Fall 2017, Volume 73, Issue 2.