Residential OMH guidance on use of telephonic service delivery

Here are 2 formal OMH announcements:

– Supplemental Guidance Regarding Use of Telehealth for People Served Through OMH-Funded Programs During the Disaster Emergency

– Supplemental Guidance Regarding Use of Telehealth for People Served in OMH-Licensed or Funded Residential Programs During the Disaster Emergency

One states that you can use telephonic service delivery in ALL residential and housing programs, licensed and unlicensed, including congregate, although you still have to have staff in the congregate programs.  Although this does not address specific aspects of your service delivery, e.g., service plan review v billing notes , I do believe that they expect you to use telephonic service delivery in any case where you must.  I have submitted that question;  if I get different advice I will let you know, but assume that you can do any part of the service by phone, including service plan reviews.  

Also, the link below is a waiver announcement from HHS about the use of telephonic devices and HIPAA: https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html

Please read the entire notice, but here are the basic dos and don’ts: 

• DO:  Use phones. Do use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype without risk that OCR might seek to impose a penalty for noncompliance with the HIPAA Rules related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency. 

• DON’T:  Do not use Facebook Live, Twitch, TikTok, and similar video communication applications are public facing, and should not be used in the provision of telehealth by covered health care providers.