We would like to extend our appreciation for DMAS’ recognition that telehealth and telemedicine services are beneficial and may increase access to services, particularly through the allowance of various community locations as Originating Sites.  Unfortunately, Attachment A provides insufficient detail for providers to move forward with using telehealth to provide Mental Health and Substance Use Disorder services, particularly those that are more intensive than Outpatient therapy and medication management.  Specific questions along these lines include:

• Is there a limit to the number of hours per week that an individual may participate in billable telehealth services for programs such as Assertive Community Treatment, Intensive Outpatient, Partial Hospitalization, and Psychosocial Rehabilitation?  If so, is this connected to a maximum number of units/hours or to a percent of service hours that may be provided via telehealth?
• Assertive Community Treatment requirements specify fidelity to a specific model.  How does the use of telehealth impact the level of fidelity?
• Please confirm that this allows for Case Management face-to-face contacts to be provided via telehealth.
• Is the DBHDS Office of Licensing in agreement with these changes? 
• As written, Attachment A implies that a provider could run entire programs virtually, if only people for whom telehealth is an acceptable modality for delivery of services are accepted.  However, these services are licensed by DBHDS as “center-based”.  Will providers be sanctioned by DBHDS Office of Licensing if services are only available via telehealth?   
• If the provider maintains a consent agreement, but 100% of services are provided virtually, will documentation that the consent agreement was reviewed and the individual provided verbal consent to participate in telehealth services be acceptable?
• Will DMAS accept verbal approval of/agreement with individual services plans if the discussion occurs during a telehealth service?  Will DBHDS Offices of Licensing and Human Rights accept this?  What about for other documentation where a participant signature has been required historically? If the service is provided via telehealth and in-person contact does not take place for several days, weeks, or months, will signatures obtained at that time be accepted if there is documentation of verbal agreement?
• Will DMAS provide additional guidance and resources regarding best-practices for implementing services that have traditionally relied on the benefits of a clinical milieu and peer support in community, nonresidential settings (e.g., psychosocial rehabilitation, day treatment, partial hospitalization) in shifting to greater use of telehealth services?

On a more general level:

• Will services provided be billable to DMAS if the individual is located outside of Virginia?
• What actions will DMAS take to ensure standardization across the various contracted MCOs regarding expectations in the provision of telehealth and telemedicine?