Therapy During COVID-19: Implementing Telehealth for ABA Therapy

As an Applied Behavior Analysis therapist, you may be considering telehealth as a way to see your clients in light of the Coronavirus outbreak in the United States. Many mental and behavioral health therapists are seeing an increased demand for telehealth services and many are making — or considering — a transition to telehealth.

However, the challenge of implementing telehealth services for ABA therapy can seem daunting. ABA therapists are currently thinking over the ethical considerations of transitioning to telehealth, understanding the technology requirements and regulations, and working to keep up with insurance company policies that are affecting the use of telehealth during this fast-changing situation.

In this article, we’ll shed light on some of the issues that you may be thinking about as you consider implementing telehealth during the current healthcare crisis.

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Important Considerations for ABA Therapists Implementing Telehealth

The Council of Autism Service Providers has released a set of recommendations that address some of the considerations of using telehealth for ABA therapy. The major relevant points with regards to the current pandemic are as follows:

Since telehealth changes the structure of typical one-on-one sessions in close quarters, ABA providers will need to understand how to safely and effectively deliver care through telehealth.

Patient privacy and confidentiality must be ensured for telehealth sessions.

Providers must adhere to rules and regulations involving the use of telehealth. These are often specific to the state. They may include licensure requirements, patient privacy regulations, and “the rules surrounding employment of telehealth practitioners residing outside the service area, supervision ratios and on-site visitation requirements.”

Clinical Considerations of Using Telehealth for ABA Therapy

Many providers are unsure about how to implement direct services via telehealth. What kinds of therapy can I practice over telehealth? How can I create a safe and effective therapeutic environment with telehealth? What about the informed consent of the client? We’ll be covering these issues in more depth in the second article of this series, which will be based on our Facebook Live stream events with ABA expert Dr. Joyce Pollard, CEO of the Behavior Change Institute.

Telehealth Regulations That Affect ABA Therapy

Regulations will vary by state, but the following resources can help you research and understand the telehealth regulations that may affect you.

eVisit State Telemedicine Legislation – Provides information about state legislation via a clickable, virtual map.

American Telemed’s State Policy Resource Center and State Toolkits – Publishes detailed reports on telehealth regulations and policies by state. Policies are tracked in real-time to ensure that it’s up-to-date.

CCHPCA State Laws and Reimbursement Policies and their State Telehealth Laws and Reimbursement Policies (April 2017) – Helps you stay current on telehealth regulations and policies and Medicare/Medicaid program by state.

Technologies Needed to Conduct ABA Therapy Sessions

ABA therapists will need to protect the privacy and confidentiality of their clients by choosing secure technologies. According to CASP, providers should comply with the regulations imposed by the Health Insurance Portability and Accountability Act (HIPAA) and the Health Information Technology for Economic and Clinical Health (HITECH) Act.

For technology, providers will need:

A HIPAA-compliant video conference system.
Computer with a built-in or external webcam
Headset for noise reduction and patient privacy.
Second monitor and vertical monitor mount (recommended by CASP).
White-noise machine for a telehealth home office for patient privacy (recommended by CASP).

Telehealth is easy to use with an all-in-one solution that also includes billing, scheduling, and reporting features

All sessions should be conducted through a secure Internet connection with adequate bandwidth so that the session is not interrupted.

Why HIPAA Compliance is Important in Teletherapy

Protecting your client’s private health information is the number one priority. Private health information, if compromised, can cause the client economic harm, embarrassment, and discrimination. Medical information can also be many times more valuable than a credit card number on the black market.

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During the Coronavirus pandemic, the federal government has temporarily lifted the restrictions on non-HIPAA compliant technology to allow therapists to use telephones and unencrypted video conferencing technology like Apple Facetime or Skype to conduct sessions (but never public facing platforms such as Facebook Live, Twitch, or TikTok). Some insurance companies may loosen the restrictions as well. However, using non-HIPAA compliant technology is not recommended since protecting your client’s privacy is paramount, and many users have seen that these platforms are crashing due to the serious demand that comes with so many users seeking virtual conferencing options.

Insurance Companies and Telehealth

Insurance companies will have different requirements for the provision of telehealth services and it’s informed by state laws (which will vary by state). We are seeing many insurance companies temporarily amending their rules to adapt to the current situation. Here are some major points:

Many states require insurance companies to cover telehealth. Currently, many insurance companies that had not authorized telehealth services are authorizing them as a response to the pandemic, including for behavioral health treatment.
Many states require real-time video sessions to be covered by insurance companies—and sometimes other methods of communication including secure email and store-and-forward telehealth.
In some states, insurance companies are required to pay the same amount for a video appointment as an in-person appointment, while other states do not make that requirement.
Insurance companies generally require HIPAA-compliant technology for telehealth services to safeguard the privacy and confidentiality of the patient’s private health information. Some insurance companies may loosen the restrictions in response to the federal government temporarily lifting penalties during this pandemic. However, using non-HIPAA compliant technology is not recommended since it’s critical to protect your client’s privacy.
Some insurance companies require providers to complete an attestation (e.g. virtual visit attestation) before they provide telehealth services. During this pandemic, that requirement may be bypassed in some cases.

As an ABA therapist, you can contact your funding sources to secure any authorizations that are needed to provide services via telehealth and follow the guidelines that they provide you with. This may mean sending in forms or applying online. Some questions to ask your funding source:

What is needed to be able to provide telehealth services?
What specific software and equipment is required by the funder?
What are the billing modifier and service location codes?
Which HCPCS and CPT codes apply to telehealth reimbursement?
Do I need a GT modifier for reimbursement?
Are there any location restrictions by patient or provider?
Do the reimbursement rate for telehealth match the rate for an in-person visit?
Which providers are eligible for reimbursement?
Are there any specific details that need to be documented for reimbursement?

Since insurance companies are temporarily amending some rules as a response to COVID-19, it’s also important to check on the date of when the amended rules will no longer be effective.