It is my understanding that with this regulation, audio only services will not be covered.  I must strongly object to this change in telehealth/telemedicine.  There are several individuals on my  caseload that do not have financial means to access the internet or pay for a data plan with their phones.  Some of the other individuals do not even have a smartphone.  If this new regulation is put in place, a majority of my clients will be more or less forced to pick between face to face conversations in the community or not have access to services at all.   Not everyone has means or access to the proposed telemedicine services.  Some of the individuals on my caseload also live at Assisted Living Facilities that have the use of one tablet/computer for the entire population that lives there.  Public internet options are limited in the area.  Even if an individual has a smart phone or another device that could access the internet, the individual and person providing services face possible HIPPA violations and PHI information being leaked into the general public.  Access to free internet does not mean that the individual's PHI remains protected.  Anyone could potentially overhear a conversation, see what the individuals sees, and gather confidential information.

I also serve individuals with Intellectual Disabilities that have difficulty with understanding and using the proposed telemedicine services.

If I am to provide true person-centered, individualized, and client driven services,  there must be a variety of choices presented: Audio only, telemedicine as it is described in the proposal, and face to face discussions.  Taking away options that have worked for the individuals on my caseload in the past looks more like force choice and less like inclusion and broad access to services.