I am an LCSW in the state of Virginia and a Behavioral Health Director. I often treat elderly or disabled patients via telehealth,  especially since the onset of the pandemic. Is it correct that you will be eliminating telephonic only as an option for treatment? I must strongly object to this plan as many of these patients  live in rural settings with little to no access to reliable internet services. Many of them are minimally able to use a smart phone and even when they are, connections are often slow and sessions are frequently interrupted. Telephonic sessions are experienced as a lifeline for many of these patients, who struggle with severe depression and anxiety exacerbated by the pandemic. I strongly urge you to reconsider this decision on behalf of these patients.

Claire Capron, LCSW, BCD

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.

It is my understanding that this document proposes removing reimbursement for telephone based telemental health services.   I am a licensed professional counselor in the Richmond are and have been working the safety net for the past nine years.  Additionally, I am board-certified in telemental health service delivery and have been providing telemental health services for the past two and a half years with a private telemental health agency.  It has been my experience that telephone based telemental health services increases access to care in the safety net population by eliminating barriers to care such as transportation and limited internet access, while also providing a means for service utilization for those who lack the technological literacy required to use an electronic device such as smartphone, tablet, or computer.  It is also useful to be able to offer telephone only services in the event of a technology failure, i.e. loss of internet connection, loss of power, etc.  It is my belief that individuals should be offered as many service modalities as possible so that they are able to meet their mental health needs in such a way that works for them.  Further there is a substantial body of evidence that demonstrates the effectiveness of telephone based mental health services for the treatment of various mental health concerns.  Therefore, I strongly advocate that telephone based telemental health services continue to be reimbursable. My concern is that if this service were to be nonreimbursable, then access to telemental health care in the safety net could decrease due to the inability to sustain these services without reimbursement.

Please consider continuing to allow reimbursement in some form for audio only services. Audio only improves access to needed care for many individuals, particularly rural communities and other vulnerable populations that do not have consistent access to smart phone devices, tablets, and stable internet connection. Consider allowing reimbursement for audio only but including language that use of audio only must be clinically appropriate and documented in record why audio only is most appropriate method of service delivery based on client's needs.