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This webinar is part of the Navigating Telehealth for FQHCs During COVID-19 webinar series and can be purchased individually or as part of the series. To purchase the full series, click here.

The adoption of telehealth as a modality to provide a range of services is rapidly expanding throughout the Health Center Project, fueled by the COVID-19 public health emergency. Adopting policies that govern the provision of care via telehealth is essential to support this expansion in a clinically and operationally appropriate manner, and to promote compliance with applicable laws.

In fact, the Health Resources and Services Administration (HRSA) recently issued Program Assistance Letter (PAL) 2020-01: Telehealth and Health Center Scope of Project, establishing that HRSA “strongly encourages” health centers that provide or are planning to provide health services via telehealth to maintain written telehealth policies that are compliant with Health Center Program requirements; Federal, State, and local requirements; and applicable standards of practice. 

In addition to establishing written policies, health centers must also assess whether and how telehealth activities will be supported via contractual arrangements with other providers. Such transactional relationships, while often essential to the provisions of services via telehealth, raise a host of operational and legal considerations, including but not limited to compliance with the federal Anti-Kickback Statute and HRSA requirements applicable to contracting for in-scope services.

This webinar will outline key elements that should be incorporated into your organization’s telehealth policies and will provide sample language that specifically addresses key HRSA-related requirements. In addition, this webinar will describe contracting opportunities, best practices, and the key risk areas, with information regarding the requirements to align such transactions with a “safe harbor” to the federal Anti-Kickback Statute.