5 comments
Hello. Thank you for formulating the draft Guidance Document 30-12. A few comments:
Bullet 3 under #4: What defines "appropriate documentation", is it only informed consent or otherwise.
Bullet 5 under #4: There is no way for an SLP or A to ensure equipment is in "good working order and properly maintained" on the patient's site.
Bullet 2 under #5: Is there an expectation as to specific training. And how will competence be assessed. Is documentation of training and competence required, and what form would that take.
~LPV
I am interested in how competency will/should be documented relative to a provider's use of the technology which is utilized to provide services. What specifics relative to training are required as proof of training?
I have a few concerns and questions in regards to telepractice. Currently, I know telepractice is being used widely throughout SWVA school systems. In regards to the Guidance Document, section 5, is it the sole responsibility of the practitioner to determine the appropriateness of clients? What would you consider an inappropriate client? This seems like a gray area.
In regards to section 4 and informed consent, does this mean that parents (speaking largely to the school system) should be notified and provide consent if teletherapy is to replace previous delivery model?
Thank you!
On behalf of the American Speech-Language-Hearing Association, I write in support of the Board of Audiology and Speech-Language Pathology’s Guidance for Telepractice (Guidance Document 30-12).
The American Speech-Language-Hearing Association (ASHA) is the national professional, scientific, and credentialing association for more than 204,000 members and affiliates who are audiologists; speech-language pathologists; speech, language, and hearing scientists; audiology and speech-language pathology support personnel; and students. Over 4,400 ASHA members reside in Virginia.
As the leading national organization for the certification and advancement of audiologists and speech-language pathologists, ASHA supports the development and use of telemedicine or “telepractice.” Research demonstrates the equivalence of telepractice to in-person service delivery for a wide range of diagnostic and treatment procedures for adults and children.i Studies have shown high levels of patient, clinician, and parent satisfaction supporting telepractice as an effective alternative to the in-person model for delivery of care.ii Telepractice expands practitioners’ availability to those in need—regardless of geographic location—saving time and resources for both the provider and the patient.
Despite the proven benefits of telepractice, it is still underutilized within audiology and speech-pathology in part because practitioners struggle to understand state laws and regulations governing its use. The proposed guidance developed by the Board is an important tool that will help ASHA’s Virginia-based members better understand what constitutes telepractice and how to use telecommunications tools and information technology appropriately when providing services.
ASHA strongly encourages the Board to adopt the proposed guidance and will be pleased to share it with ASHA members in Virginia when it is approved. If you or your staff have any questions, please contact Tim Boyd, ASHA’s director of state health care and education affairs, at tboyd@asha.org.
Sincerely,
Shari B. Robertson, PhD, CCC-SLP
2019 ASHA President
I appreciate the Board specifying/defining telepractice, particularly in section #3, stated that telepractice is considered a method of service delivery and that it falls under the regulations that apply to all methods of service delivery.
Something to consider, would the Board have resources available if practitioners are in need of support to ensure that the technology being used meets HIPAA/FERPA/etc? People may not know where to go or what to specifically look or what to specifically ask when talking to vendors, especially if they are brand new to this service delivery method.
Again, thank you