Operational

This page is intended to be a resource for our provider network to find answers to critical questions during the COVID-19 crisis. As we receive more information, Community Care will be updating the site, so check back frequently for the most up-to-date information.  As new questions are added, they will appear at the top of the list.

Will telehealth continue beyond June 15, 2020?

In accordance with the OMHSAS issued Memorandum entitled, “ Telehealth Guidelines Related to COVID-19 (Updated)” dated May 5, 2020, the Memorandum, including the continuation of the allowance of telehealth, will remain in effect during the emergency disaster declaration authorized by Governor Wolf. The referenced memorandum can be found on paproviders.org.

Will telehealth expansion continue after this crisis?

OMHSAS anticipates keeping some of the practices that have been permitted as part of the telehealth expansion. If you have input that you would like to share prior to the engagement sessions, please submit your thoughts to RA-PWTBHS@pa.gov

Are providers permitted to bring charts home if they are secured in a file cabinet and confidentiality regulations adhered to? This way clinical chart work can be developed in real time and treatment plan reviews/consults completed as well as discharge in

Yes. It is permissible if confidentiality and security of records are maintained, in accordance with the March 2020, COVID-19 & HIPAA Bulletin Limited Waiver of HIPAA Sanctions and Penalties During a Nationwide Public Health Emergency. Safeguards include: maintaining minimal records required to safely and completely provide services, securely locking records, using a secure cloud arrangement (if possible, to mitigate the necessity to download files to private computers, but other processes could be in place).

For those of us in private practice for mental health, are we considered “other health practitioners” on the Telehealth Attestation?

Yes.

Is a HIPAA compliant system required, since telephonic video technology available on smartphones is permitted?

No. However, providers should exercise strict confidentiality provisions when delivering services via Telehealth/telephone. Health and Human Services (HHS) has waived the requirement that telephone video technology be HIPAA compliant during the COVID-19 crisis.

Do we need to adhere to all of the other requirements listed in Bulletin 20-02? Written protocols? Review/inspection of Telehealth technology?

OMHSAS is temporarily suspending certain requirements that govern the provision of behavioral health services using Telehealth. Telehealth must be delivered in accordance with bulletin OMHSAS-20-02 “Guidelines for the Use of Telehealth Technology in the Delivery of Behavioral Health Services” effective February 20, 2020 unless superseded by the contents of OMHSAS Memorandum, dated March 15, 2020 entitled, Telehealth Guidelines Related to COVID-19. These services still require adherence to other requirements that apply to the service being delivered as they would when delivered face-to-face.

Do we need to complete one Attestation Form to Provide Telehealth for each staff member?

No. You may submit one per agency or group. Please be very specific to include the services and locations where you will be providing via Telehealth.

Can therapists provide the Telehealth services from their homes or do they need to be in the office?

Telehealth services can be provided from the home, office or other private location.

Is there guidance on family visitation for individuals currently in residential programs?

Community Care is currently seeking clarification and will update this page with more information once confirmed.