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Resource Overview

General cybersecurity guidance would suggest that Health IT breach should not be considered a matter of "If", but rather a matter of "when". How an organization prepares and responds to an episode of breach is just as important as defending itself from breach. Unfortunately, Health Centers are seen as a domain with high potential for data breach and consequently it is critical for Health Center leadership to embrace breach mitigation across their entire organization vs being a matter to be addressed by their Health IT team.

Breach can occur through both internal and external network leaks, through malware such as Ransomware, and through physical means on site. The resources provided below are meant to provide general knowledge about breach mitigation and methods for mitigating against breach incidences.

Breach Mitigation and Response Resources
HITEQ Center
/ Categories: Privacy and Security, Privacy & Security Best Practices, HIPAA, Telehealth, Telehealth Resource Centers

Telehealth Policy during Coronavirus/ COVID-19 Pandemic

Updated 11/16/2020 with NIST Guidance on Securing the Telehealth Remote Monitoring Ecosystem

We are adding additional telehealth information, including policy and regulatory developments, relevant to coronavirus/ COVID-19 pandemic as it impacts health centers as it becomes available. Please see the resource links below.

 

  • CMS Loosens Restrictions on RHC and FQHC Telemedicine Services – COVID-19 Updates

    • Published by BKD on April 10, 2020.
    • Key Information: Coding and regulatory requirements for implementing telehealth in accordance with CMS's loosened restrictions. Effective March 27, 2020, the CARES Act removed restrictions in place prior to the COVID-19 emergency, and now allows FQHCs to serve as distant site providers for telehealth audiovisual (but not audio-only or telephone) visits, and these can be rendered to new or established patients. CMS also added 80 codes to the existing list of eligible telehealth (audiovisual) services.

 

  • Telehealth Coverage Policies In The Time Of COVID-19 to Date

    • Published by the Center for Connected Health Policy, updated regularly in March and April 2020.
    • Key Information: Telehealth waivers under Medicare and Medicaid are in place, as well as DEA actions permitting prescriptions for controlled substances via telemedicine. Scroll to the bottom of the page for FQHC specific information.

 

 

 

 

  • Telehealth and Telephone Visits in the Time of COVID-19: Sample FQHC Workflows

    • Published by the Center for Care Innovations, March 24, 2020.
    • Key Information: Many health centers and safety net clinics are switching their scheduled in-person visits to telephone or video visits, this resource provides some sample workflows and guidance for how clinics are making this transition, including examples from eClinicalWorks, NextGen, and OCHIN Epic. 
    • An appointment rescheduling flowsheet from a health clinic is available from NEMJ.

 

  • COVID-19 Public Health Emergency Response and 42 CFR Part 2 Guidance

    • Published by the Substance Abuse and Mental Health Services Administration (SAMHSA) on March 19, 2020.
    • Key Information: There has been an increased need for telehealth services, and in some areas without adequate telehealth technology, providers are offering telephonic consultations to patients. In such instances, providers may not be able to obtain written patient consent for disclosure of substance use disorder records. The prohibitions on use and disclosure of patient identifying information under 42 C.F.R. Part 2 would not apply in these situations to the extent that, as determined by the provider(s), a medical emergency exists.

 

  • State Data and Policy Actions to Address Coronavirus

    • ​Published and updated March and April 2020 by Kaiser Family Foundation.
    • Key information: This site is tracking state-by-state policy actions such as state waivers of cost sharing for COVID-19 testing, state waivers of prior authorization requirements, early perscription refills, and expanded marketplace insurance enrollment.
    • Other important sources of state information are Medicaid Federal Disaster Resources which includes details on each state’s 1135 Waiver as approved by CMS and the Center for Connected Health Policy's tracking of COVID-19 related state actions.

 

Resource Links

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Tags: telehealth telemedicine Office of Civil Rights 42 CFR Part 2 COVID-19

Acknowledgements

This resource collection was cultivated and developed by the HITEQ team with valuable suggestions and contributions from HITEQ Project collaborators.

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Improving the U.S. health care system requires four aims: improving the experience of care, improving the health of populations, reducing per capita costs and improving care team well-being. HITEQ Center resources seek to provide content and direction aligned with the goals of the Quadruple Aim

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