California DHCS Telehealth Policy for Facilities Offering Incidental Medical Services
Facilities offering incidental medical services in California must adhere to DHCS telehealth guidelines that require maintaining the same standard of care as in-person treatment, using HIPAA-compliant platforms, obtaining informed consent, and following California-specific licensure requirements. 1
Regulatory Framework for Telehealth IMS
Legal and Regulatory Requirements
- Providers must understand and comply with California-specific laws and regulations for telehealth services
- Maintain awareness of licensure requirements across jurisdictions when providing telehealth services across county or state lines
- Ensure telehealth services maintain equivalent standard of care as in-person treatment
- Obtain proper informed consent from patients before initiating telehealth services
- Address billing and reimbursement issues according to California DHCS policies 1
Technical Standards
- Use only videoconferencing platforms with appropriate verification, security, and confidentiality parameters
- Ensure sufficient bandwidth and resolution for video sessions
- Establish backup communication plans for technology failures
- Implement proper protections for storage and transmission of confidential patient data
- Adhere to HIPAA requirements for all telehealth interactions 1
Operational Protocols
Pre-Telehealth Session Planning
- Develop comprehensive emergency plans specific to each patient's location
- Obtain consent to communicate with other healthcare providers involved in patient care
- Assess appropriateness of patient's setting including:
- Privacy considerations
- Access to necessary technology
- Distance to nearest emergency facility 1
Telehealth Session Documentation Requirements
- Verify and document patient and provider information at the start of each session
- Confirm and record patient's physical location during the session
- Document contact information for provider, patient, and relevant support people
- Establish clear expectations about contact between sessions
- Collect patient-reported outcome data and satisfaction with telehealth services 1
Special Considerations for Specific Populations
Pediatric Telehealth Services
- Ensure providers have appropriate training in pediatric care
- Recognize limitations of remote physical examinations
- Maintain confidentiality for sensitive topics with adolescents
- Utilize telehealth for care coordination while scheduling regular in-person examinations for children with special healthcare needs 1
Mental Health Services
- Support expanded use of telehealth for behavioral health crisis services to mitigate unnecessary emergency department visits
- Enable medical screening through telehealth/telephonic and clinical preadmission assessments by qualified professionals
- Recognize that patients with psychiatric complaints may have co-occurring medical disorders requiring proper evaluation
- Ensure mental health and substance use care remains available based on individual needs 2
Best Practices for Implementation
- Establish a telehealth environment with proper access to electronic health records
- Use share-screen functionality to review imaging and other clinical information with patients
- Coordinate with nursing staff to assist with scheduling future appointments
- Have HIPAA-compliant backup communication options available when technical issues arise
- Stay updated on evolving telehealth regulations in California 2, 1
Common Pitfalls to Avoid
- Using non-HIPAA compliant communication platforms
- Failing to verify patient identity and location at the beginning of each session
- Not having an emergency plan in place for patients in crisis
- Overlooking the need for proper documentation of telehealth encounters
- Neglecting to stay current with rapidly changing California telehealth regulations 1
By following these guidelines, facilities offering incidental medical services via telehealth can ensure compliance with California DHCS requirements while providing high-quality care to patients.