Telehealth Trauma-rama (Work in progress)
- Aaron X.
- Jan 7
- 4 min read
Updated: Jan 13
Concerning Emergency amendments to telehealth and telework regulations during the year
of and subsequent years following the Coronavirus and the findings of the studies done during this time period.
Expiration: December 31, 2024
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The Data...
Health and Human Services
--The Telehealth Integrity Study--
--Who/What/When/Where/Why
-- Contact 1-877-696-6775
Office of the Inspector General Report -- June 15, 2023 the Inspector General of the Department of Health and Human Services shall submit to Congress a report on program integrity risks associated with Medicare telehealth services.
Consolidated Appropriations Act 2022
Title III -- Medicare
SEC. 308 -- Medpac Report
Sub-section (a) Medpac Report sub-paragraph (1) Study.
sub-paragraph (A) (verbiage may vary...)
The Medicare Payment Advisory Commission shall conduct a study on the expansions of telehealth services.
--(Expansion of telehealth services to include third-party guidance and reliance on what ISPs and hardware vendors?)
--Beginning July 1, 2022, the Secretary of Health and Human Services shall post on the public website of the Centers for Medicare & Medicaid Services on a quarterly basis data with respect to Medicare claims for telemedicine services, including data on utilization and beneficiary characteristics.
--Office of the Inspector General Report - Not later than June 15, 2023, the Inspector General of the Department of Health and Human Services shall submit to Congress a
report on program integrity risks associated with Medicare telehealth services.
Consolidated Appropriations Act 2023
Office for the Advancement of Telehealth (pg. 136)
--$38,050,000 alotted to include grants, contracts, and cooperative agreements to support programs with the heading: ``Primary Health Care'', ``Health Workforce'', ``Maternal and Child Health'', ``Ryan White HIV/AIDS Program'', ``Health Systems'', and ``Rural Health''
Chapter 4--Administration of Non-Department Care
Subtitle D-Improvement of Rural Health and Telehealth
Section 151-Established of Strategic Plan Requirement for Office of Connected Care of Department of Veteran's Affairs
Sub-paragraph (a) Findings. -- sub-section (9) Questions regarding the efficacy of using telehealth for certain health care services and specialties remain, and should be further studied. (What were the findings of the study?)
Sub-paragraph (b) Sense of Congress. -- The telehealth services offered by the Department of Veteran's Affairs should be routinely measured and evaluated to ensure the telehealth technologies and modalities. (How are these measured and what are the metrics?)
Sub-paragraph (c) -- Sub-section (3)
Sub-paragraph (B) -- An assessment of the effectiveness and patient outcomes for each type of health care specialty delivered by telehealth or virtual care by the Department. (Where are these outcomes located?)
Section 153-Comptroller General report on telehealth services of the Department of Veteran's Affairs. (Where can this report, if published, be found publicly
and what does it contain?)
Section 3606 - DECENTRALIZED CLINICAL STUDIES
(***alert: definition of informed consent in comparison to electronic informed consent especially in regard to capacity to contract.)
Sub-paragraph (b) Content of Guidance
sub-section (1) decentralized clinical studies, including guidance on considerations for selecting technological platforms and mediums, data collection and use, data integrity and security, and communication to study participants through digital technology. (ethical considerations, human rights considerations, cybersecurity considerations, psychological considerations, judicial consideration, and legal ramifications? belmont report informed consent?)
sub-section (2) states "electronic informed consent" -- (ethicality? definition of consent?? legal ramification if evidence of exploitative data collection??)
Sub-paragraph (b) definition of "decentralized clinical study" means a clinical study in which some or all of the study-related activities occur at a location separate from the investigator's location. (HIPAA compliance considerations?)
Section 4113 - ADVANCING TELEHEALTH BEYOND COVID-19
-Sub-paragraph (a) Removing Geographic Requirements and Expanding Originating Sites for Telehealth Services.
-sub-section (1) December 31, 2024 is stated as expiration. (enforcement agency?/over-sight committee?/task-force?-->Penalties and fines?)
-Sub-paragraph (e) Allowing for the Furnishing of Audio-only Telehealth
-amendment to the Social Security Act resultant in the allowance of stated service delivery method until December 31, 2024. (enforcement agency?/over-sight committee?/task-force?-->Penalties and fines?)
-Sub-paragraph (g) Study on Telehealth and Medicare Program Integrity
--("Operational Definition of program integrity? Scope and objective of the study?")
Section 5124 - SUPPORTING ACCESS TO A CONTINUUM OF CRISIS RESPONSE SERVICES UNDER MEDICAID AND CHIP.
-Sub-paragraph (a) Guidance. Not later than July 1, 2025: specific questions to the effect of, "Where can this "Guidance" be found and to what extent and limitation can telehealth be utilized to deliver crisis response services with regard to the amendments of the Social Security Act in accordance with the deadline set forth in Consolidated Appropriations Act.
Consolidated Appropriations Act 2024
The Consolidated Appropriations Act of 2024 states the expiration of the
Something?:
--Local city to state Mental health and Medical organizations utilizing... tl;dr | out of compliance malpractice lawsuits??
--Long-term consideration of billable telehealth services?
--audio-only telecommunications technology?
--Outcomes, results, and findings of short-term and long-term studies concerning healthcare services provided utilizing technologies capable of connecting audio/video from 2 or more disaparate locations across varying levels pf practitioners.
--effectiveness, efficacy, ethicality of mhss/ihs/therapeutic interventions delivered by teleservice with the following considerations:
Comparisons one-to-one to groups
Age, race, gender, and education demographics, utilizations in populations to include but not limited to those with mental health disorders across the neuro-divergence spectrum.
Utilizations in substance abuse rehabilitative programs and treatments. e.g. Narcotics Anonymous, Alcoholics Anonymous, Chemical Dependency Anonymous
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References
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(congress.gov, 2022) -- https://www.congress.gov/bill/117th-congress/house-bill/2471/text
-H.R.2471 - Consolidated Appropriations Act, 2022
(congress.gov, 2023) -- https://www.congress.gov/bill/117th-congress/house-bill/2617/text
-H.R.2617 - Consolidated Appropriations Act, 2023
(congress.gov, 2024) -- https://www.congress.gov/bill/118th-congress/house-bill/4366/text
-H.R.2617 - Consolidated Appropriations Act, 2024
(HHS, 2024) https://www.hhs.gov/hipaa/for-professionals/special- topics/telehealth/index.html
-HIPAA and Telehealth
-Guidance on How the HIPAA Rules Permit Covered Health Care Providers and Health Plans to Use Remote Communication Technologies for Audio-Only Telehealth
-Telehealth for behavioral health care
--Sections of note--
Consolidated Appropriations Act, 2022
--Section 151 Extension of temporary order for Fentanyl-related substances
(This in regards to telehealth services.)
--Section 161 Wavier of federal fund limitation for the drug-free communities support program.
(This in regards to telehealth services.)
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Glossary
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allopathic - term in the medical field that is used to catagorize conventional or mainstream medicine that treats symptoms and diseases with medication, surgery, or other therapies.
BAA -- Business Associate Agreement
ISP -- Internet Service Provider
CFR -- Code of Federal Regulations
PHE -- Public Health Emergency
ePHI -- electronic Personal Health Information
HHS -- Health and Human Services
HIPAA -- Health Insurance Portability and Accountiability Act
HITECH -- Health Information Technology for Economic and Clinical Health
HRSA -- Health Resources and Services Administration
PHI -- Personal Health Information
PSTN -- Public Switched Telephone Network
NPRM -- Notice of Proposed Rulemaking
OCR -- Office of Civil Rights
TSP -- Telephone Service Provider
~Aaron X.