Telehealth Considerations for SHS: Challenges and Solutions
Field Example
In Michigan, state law mandates that parents have limited access to health records for minors over the age 11. While not blocked from viewing all information, they are unable to access appointment information and visit notes related to adolescent sexual health, STI testing, substance use, and mental health. See this blog post from Michigan Health for more information.
Laws and policies around consent for minors seeking SHS, including STI screening and treatment, can vary by state and jurisdiction. Providers should be knowledgeable of the laws in their state, and be explicit with adolescents regarding these laws and how it will affect the virtual appointment and services provided.
To mitigate specific challenges to providing sexual healthcare via telehealth and not performing a physical exam, patients can take still photos of visible lesions and submit them via a secure electronic medical record (EMR) patient portal. Providers can then refer to these photos during the visit with the adolescent. It is important to note that providers and adolescents may be uncomfortable with this option, especially in dealing with minors. Other options such as hybrid models may be necessary for physical examinations in addition to services such as certain contraceptives or follow-up for symptom management. There is a need for providers, healthcare organizations, and national organizations to continue developing best practices and guidance related to sensitive examinations in telemedicine.
Technology, Equity, and Access
Schools have been instrumental in helping to overcome disparities in access to appropriate technology. As adolescents shifted to virtual learning, many schools provided laptops, tablets, and even hotspots to ensure students had the technology needed to complete schoolwork. Providing these devices allows adolescents who previously had limited access to adequate resources to now be able to access SHS and attend virtual appointments with providers. Individual school and district policies differ, and some may have restrictions on accessing outside websites or software on school-issued devices.
Policy Considerations for Billing and Payment
Federal laws such as the Family Educational Rights and Privacy Act (FERPA) and the Health Insurance Portability and Accountability Act (HIPAA) play an essential role in protecting the confidentiality of students’ educational records and health information. During the COVID-19 Public Health National Emergency, the Office of Civil Rights (OCR) has issued guidance to offer HIPAA flexibility to providers and make it easier to utilize telehealth services. See HIPAA Flexibility for Telehealth Technology for a summary of this guidance.
The federal government has eased certain restrictions for the duration of the COVID-19 public health national emergency. These include HIPAA flexibility, Centers for Medicare and Medicaid Services (CMS) waivers, and temporary expansion of telehealth services. Billing and reimbursement remain important considerations and vary across private insurances, while Medicare and Medicaid coverage varies by state. Policy considerations for telehealth also vary by state and should be assessed within individual jurisdictions. The Center for Connected Health Policy’s Telehealth Policy Finder Tool includes more information on individual policies by jurisdiction.
Billing and cost solutions have also been a priority throughout the COVID-19 pandemic as the push to make telehealth services more accessible has continued. Referring adolescents to free SHS eliminates the cost barrier while also eliminating the risk of a bill or EOB alerting parents. Parity requirements require private payors to either reimburse telehealth services at the same rate as in-person services, or cover the same services with telehealth that would be covered with in-person visits. These have become more prevalent during the pandemic, passing in 29 states and Washington, DC. It is important to note that services covered and reimbursement policies vary by jurisdiction and individual payor and should be assessed case-by-case. See The Center for Connected Health Policy for more information on parity requirements by state.