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Telemental Health: National Policy Considerations

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While national policies and guidelines are in place to facilitate telemental health delivery, some aspects vary state-by-state. Telemental health practitioners should review the below information to find out about licensing, prescribing, and reimbursement as it pertains to their state and scope of practice as well as other helpful best practice guidance.

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State Licensure and Collaborative Agreements

  • Licensure: RNs and APRNs should review their individual state requirements, as every state addresses the scope of practice based on licensure.
  • Collaborative Practice Agreements: APRNs need to review their individual state requirements for collaborative practice.
  • APRNs can deliver telehealth services in multiple states, depending on rules set by the states, federal polices, and interstate compacts.
  • Providers must be appropriately licensed in the states where the patients are located.
  • Providers must also have a DEA number in the state where the patients are located to prescribe controlled substances.

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Reimbursement

  • Telehealth services are reimbursed for audio, audio/visual, and G-codes for brief interactions through email or text. Telehealth services will continue after the public health emergency for mental health patients only.
  • The rules for Rural Health Centers, Federally Qualified Health Centers, Tribal health Centers, or Medicare/Medicaid may be different, as each state provides guidelines for reimbursement.
  • Each state generally follows CMS guidelines, however states have flexibility to modify Medicaid rules for telehealth. Check state regulations through:

Prescribing

Depending on your state’s prescribing guidelines, the DEA, and the Ryan Haight Online Pharmacy Consumer Protection Act of 2009, APRNs are able to prescribe medications, including controlled substances.

  • Prior to the COVID-19 pandemic, least one face to face evaluation of the patient was required to prescribe controlled substances.
  • During the pandemic this rule was suspended due to the Public Health Emergency. It is currently being revisited as recovery from the pandemic takes place.

APRNs must have a DEA number in the state where their patients are located in order to prescribe controlled substances in that state.

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Case Management

Case management for chronic mental health issues such as substance use disorder by RNs is facilitated by telehealth. Guidelines and reimbursement for the delivery of this services are provided by institutions and funding agencies.

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Therapy

Research supports the use of telemental health as an effective way of delivering individual, and to some degree, group therapy. Guidelines and reimbursement for the delivery of these services are provided by the institutions and funding agencies.

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