Health Centers and Telehealth: Surmounting Regulatory and Operational Challenges

Community health centers are increasingly adopting telehealth and remote patient monitoring strategies to address provider shortages, expand access to a broad range of high-quality services, and improve patient health outcomes. The important and growing role of such technology within the Health Center Program is increasingly recognized by the Health Resources and Services Administration. In fact, several recent funding opportunities explicitly contemplate the provision of key services via telehealth. In addition, the UDS reporting methodology was updated for 2019 to capture all in-scope telehealth visits. Despite its many clinical benefits, telehealth raises a number of significant legal considerations that must be addressed prior to adoption. This presentation will highlight the key legal considerations applicable to telehealth arrangements, including HRSA scope of project, FTCA coverage, contractual pitfalls, and payment barriers. Presenters will provide real-world examples of telehealth arrangements and tips on how a health center manager can develop and implement a telehealth strategy that complies with applicable requirements. They will also discuss various state Medicaid programs' approaches to including FQHCs in payment for telehealth encounters and other e-health services.