A. Need to be clear with TeleMedicine- modify to:

1. Used for individuals to come into a clinic/facility location with a nurse/staff present and that the provider can be off site.

2. Provider can be in another state, if licensed in both states. 

B. Modify Telehealth verbal consent to: can be obtained at first apt with written consent obtained prior to any follow up apts.  

In an effort to expand service delivery to those whom are most at need, I believe that ongoing reimbursement for Telehealth Audio for Outpatient Therapy would be a benefit for public health. Reimbursing for only Tele-medicine (requiring both video and audio simultaneously) excludes some of our most vulnerable population whom not have access to the technology and reliable Internet service available to take advantage of this. As a clinical services manager I have seen first-hand the benefit of Telehealth Audio during the pandemic, to the point where our ability to serve clients in need exceeded pre-pandemic levels. This is because the Telehealth Audio option not only provides effective social distancing but it also provides a means for clients to overcome barriers to treatment that were present pre-pandemic namely transportation (i.e. for some of our clients it could take them 4-5 hours out of their day traveling round trip by bus for a one hour therapy session). This has proven to be a time comment that many of our clients are not willing to make when they are attempting to work toward securing employment and attending to other personal needs in the community.  Therefore, in the spirit of providing equitable treatment for those in need, I believe allowing for Telehealth audio to be a reimbursable method of service delivery would be a step in the right direction to provide expanded access to those most in need in our community.

Julius Smith, LPC 

Adult Outpatient Clinical Services Manager 

Hampton Newport News Community Services Board 

Recommend allowing audio only mental health and substance use services when visual means are not able to be met by a client. This will help increase equitable access to services. Socioeconomically disadvantaged clients may not have access to visual means via computers, internet, or smart phones. Phones provided through public assistance programs have limited minutes and lower ability to support visual interactions. People living in rural areas may not have access to internet regardless of income. The ability to receive crisis help and counseling services will be increased by allowing audio only services in circumstances where visual connection is legitimately not available. 

By providing reimbursable telehealth - audio, CSB clinicians would be able to reach a population that, because of chronic transportation challenges, work challenges, etc., have not historically received regular and ongoing therapy.  In rural communities, public transportation is almost non-existent; what is available in the majority of the counties, could require a day long venture to access face to face services.  This is an opportunity to be able to broaden the scope of therapy to the most vulnerable populations, to include more effective follow up with individuals who have been psychiatrically hospitalized and who are not able to access needed services in a routine, organized manner due to the organization it requires to access transportation.

In an effort to expand service and supports to those who are most in need, maintaining telehealth-audio and telehealth-audio/visual (A/V) for services and support would be a benefit for public health.   Limiting telehealth to A/V only excludes Virginia’s most vulnerable population who do not have access to the technology and reliable Internet service available to take advantage of this.   Including telehealth-audio for services when telehealth-A/V is not available will help increase equitable access to services.  Limiting telehealth flexibilities to only A/V and only specific providers of/for specific services, impacts equitable access to any and all services and supports for individuals that are likely already limited due to more than only geographical and/or economical constraints.

The benefit of telehealth delivery (both audio and A/V) for services and support during the pandemic increased providers’ ability to serve clients in need.  Individuals utilizing Service Facilitation services through the telehealth delivery model (both audio and A/V) were able to find support and needed daily care during the height of the pandemic.  Moms In Motion (Moms), specifically, quickly developed the infrastructure necessary to become a telehealth provider (both audio and A/V) in order to facilitate long term services and support for those individuals that were displaced from facilities when the pandemic began to wreak havoc.  As providers, we have maintained preparedness throughout the pandemic providing service and support to all members who continue to struggle with isolation, fear, and uncertainty.  Continuing the benefit of the telehealth delivery model (both audio and A/V) complies with the persistent social distance protocols and limits hurdles to services and support.  Telehealth (both A/V and audio) for services has been an asset that many were able to effectively use and lessen the impact or loss of services and supports during the pandemic.  Continuing to allow all service providers, inclusive of Service Facilitation providers, to maintain telehealth delivery (both audio and A/V) is an added benefit to all Virginians being served.

Chronic challenges (transport, economical, employment, etc) have impacted certain disadvantaged populations to receive regular and ongoing services and support.  Telehealth, both A/V and audio-only, is an opportunity to be able to provide effective & on-going access to families/communities facing these challenges.  Not all individuals/families have the means or access to devices that enable A/V connections, and phones available through public assistance programs have limitations. Rural areas specifically do not have access to reliable internet regardless of income. The ability for all individuals and families to obtain necessary services and support during this on-going crisis and beyond would expand access to those most in need in our communities.  Supporting the continuation of the telehealth delivery model, both audio and A/V, would increase member support and well-being as providers expand their reach to bring those services and supports to the member in the least restrictive manner. By continuing to include all providers for all services in the telehealth delivery model (both audio and A/V), more members and Virginians will be served and supported despite any obstacles.