Overview
This section of the guide describes how Mental Health Services can be delivered using Telehealth (voice or voice+video calling).
Provide feedback and suggestions for this policy/procedure using the feedback link below.
This policy/procedure will see frequent updates as the state and federal rules for Telehealth services evolve. Review those updates just below.
Telehealth refers to health care services delivered by technologies that provide video + audio connections between the provider and recipient of the service. Strict rules apply to the delivery of Telehealth services, the strictest of which include HIPAA privacy law.
Some exceptions apply to HIPAA rules at this time as a result of the coronavirus. This chapter will be updated when the coronavirus pandemic has passed (it will!) and old rules are again in force.
Any service provided via Telehealth service must adhere to the following protocols for privacy and appropriateness:
- A Clinical or Administrative Supervisor has prior-authorized delivery of Telehealth services to a specific individual.
Authorization will only be granted if:
- The provider has read and demonstrated understanding of and the ability to adhere to this policy and procedure
- The specific case and service is appropriate for Telehealth
- The recipient has previously agreed in writing (or verbally with a written confirmation to follow) that they agree to services via Telehealth.
For written consent, use the form Consent for Telehealth Services found in forms > authorizations, consents and releases.
- The provider of the service must be located in a private individual space, behind closed doors where no content will be seen or heard by other individuals such as coworkers, by family members or housemates if delivered from home, or by any other individuals. The provider should describe their location and the privacy measures taken at the start of the session.
- Authorized supervisors, mentors, trainers, or trainees may observe Telehealth services with the permission of the recipient, and must be introduced verbally to the recipient at the start of the session. Their exit from the session, if early, must be announced.
- The recipient of the service must be located in a space that they have agreed is comfortable and sufficiently private as they have determined.
- The service must be one that adheres to the definitions below for Appropriateness
- The service must be provided with a Telehealth technology that has been approved by Accend and that can be used effectively by the recipient.
- The service must include all elements of the same service delivered face-to-face, including risk assessment, and a response plan developed if risk of harm is detected.
- Delivery of services via telehealth should end if it is determined by a clinical review of treatment progress that they are not effective, or that the delivery method of Telehealth is itself a barrier to progress.
Consent on the Treatment Plan
Mental health services covered by medical assistance as direct face-to-face services may be provided via telehealth and are covered by MHCP.
When any part of services will be provided via telehealth, verbal consent on the Treatment Plan is allowed. If any part of services will be provided face-to-face, an addditional signature is encouraged.
Telehealth is not a unique service type. Document the service you are providing and use these procedures exactly:
- Document the service location as shown in the table below.
- Describe the Service Location as your location as you delivered the service (e.g. "101 East 2nd St Duluth," "Home Office," etc.) and the approved technology used (e.g. "with Facetime," " with Skype," etc.)
- Service duration for telehealth includes only the time you are actually on the phone or connected with the individual by voice and video technology.
- Exclude all time from the duration of the service where the call was dropped for a period of more than 4 minutes and explain in the narrative if this occurs.
| Telehealth Service |
Telehealth Location |
| Phone call when client is at home, including temporary residences |
Telehealth (AUDIO ONLY) Client at home
-Describe your location and the technology used in the location description |
| Phone call when client is in a location other than home |
Telehealth (AUDIO ONLY) Clt not at Home
-Describe your location, the client's location and the technology used in the location description |
| Both audio and video when client is at home, including temporary residences |
Telehealth - Client at home
-Describe your location and the technology used in the location description |
| Both audio and video when client is in a location other than home |
Telehealth - Client not at home
-Describe your location, the client's location and the technology used in the location description |
The following table describes when Telehealth delivery of services is appropriate.
Telehealth services are limited to three per week per recipient.
| Category |
Service |
Appropriateness |
| Behavioral Health Home Services |
Any service that might otherwise be provided face-to-face |
Appropriate in many or most circumstances when the recipient is at home. Rarely appropriate for assistance with appointments that the recipient is attending outside the home.
Use the face-to-face service type and indicate that it was delivered via Telehealth using the location as described in the documentation procedures above.
Our requirement for face-to-face services for BHH services every 90 days. |
| *Case Management |
*Depending on residence services may be provided by interactive video |
For reasons that are unclear to us, Case Management services provided using audio-visual technologies are referred to as Interactive Video. Circumstances when this method can be used are limited.
For adult MH-TCM, interactive video may be used instead of a face-to-face contact if the client resides in a hospital, nursing facility, residential mental health facility or an intermediate care facility for persons with developmental disabilities. The use of interactive video may substitute for no more than 50 percent of the required face-to-face contacts. |
| ARMHS |
Individual |
Appropriate if the setting is private and secure and the skills being taught can be taught without the need for physical or gestural prompting and redirection. |
| Clinical Professional |
Diagnostic Assessment, Explanation of Findings, Psychoeducation |
Appropriate if the setting is private and secure but prohibited for clients receiving psychotherapy through Medicare (federal funding). |
| CTSS |
Skills Training |
Appropriate only if the skills being taught can be taught without the need for physical or gestural prompting and redirection. |
| EIDBI |
Direct EIDBI Intervention |
When identified as appropriate by the Clinical Supervisor. See the EIDBI Services Guide for detailed information about how and when to provide EIDBI Intervention via telehealth (to be updated the week of April 6, 2020). |
| EIDBI |
Family and Caregiver Counseling and Training |
Appropriate for teaching knowledge elements and when providing guidance and direction to a parent who is working on skills with a child. |
| EIDBI |
Observation and Direction |
Appropriate with the Observer is able to see all interactions and interventions, can be heard and seen by the provider who is implementing observations, and can hear and see the provider and child at all times.
Considerations for provision of Observation and Direction via Telehealth include careful positioning of the device that will be used to facilitate the service in such a way that you can see and hear all interactions between the provider staff you are observing, and the child being treated.
Obtain authorization to provide Observation and Direction via Telehealth from your supervising BCBA. |
| Peer Specialist Services |
Peer Specialist |
Appropriate in many circumstances. |
| Psychotherapy |
Psychotherapy |
Appropriate in many or most circumstances, but including clients receiving psychotherapy through Medicare (federal funding). Interactive video only (no telephone). |
Approved technologies include only those been authorized by Accend for use in delivery of services via Telehealth, and:
- are a technology has been vetted as HIPAA-compliant
- the technology provider has signed a Business Associate Agreement with Accend attesting to HIPAA compliance
- the technology is used in complete compliance with all of the provisions of this policy/procedure
- the technology is listed in this policy as vetted and accepted for use at Accend.
At this time telehealth services are allowed only with the following technologies:
- Zoom
- Microsoft Teams
- Telephone audio-only until June 30, 2025.
What Should Telehealth Look Like?
Services delivered via Telehealth, over video/voice or over the telephone, should look just like a face-to-face service. That includes:
- Risk Assessment and objective Observations (what did the client report is going on with them at this time?)
- Assessment of current needs, triage, and response to needs
- Delivery of a service that includes Active Treatment (teaching skills, problem-solving, and therapeutic interventions
- Data collection and progress review
Services That Cannot be Provided By Telephone or Telehealth
Psychotherapy to clients when the payer is Medicare can be provided with telehealth by interactive video, but cannot be provided by telephone.
Any service provided to a client when the payer is private/commercial insurance (without prior-authorization from our Billing Administrator).
The following technologies are not allowable for Telehealth delivery of services:
- Any technology not listed above as approved
- Facebook Live, Twitch, TikTok, and similar video communication applications are public facing, and should not be used in the provision of telehealth by covered health care providers.
- Facebook Messenger: in spite of language that you might find allowing use of this app for Telehealth, Accend prohibits use of Messenger to communicate with clients at any time with text, voice, or video messaging.
Individually enrolled* (independently licensed professionals and EIDBI) providers who will use Telehealth delivery as an option for delivery of mental health services to individuals in Minnesota Health Care Programs must complete the following enrollment form:
Provider Assurance Statement for Telehealth
and adhere to this policy and the guidelines found at:
MHCP Manual: Telehealth Delivery of Mental Health Services.
Providers should check with the Billing Administrator before offering Telehealth services to any individual with private/commercial insurance.
*Providers who are not independently enrolled with DHS or other payers do not need to complete this form. You are covered by your supervisor's assurance statement.
We're looking for resources for staff and clients. Check back here often.
Assurance Wireless: Lifeline provider offering unlimited calls and texts + 6GB data monthly through May 20, 2020 to its customers.
T-Mobile: All T-Mobile customers as of March 13, 2020 who have plans with data will automatically have unlimited smartphone data through May 13 (excluding roaming). No action required.
LifeLine customers with extra free LTE data up to 5GB per month for each of the next two months.
Q Link Wireless: Lifeline provider offering additional 5G data and unlimited talk and text.
StandUp Wireless: Lifeline provider offering 8G data, Free monthly minutes, unlimited texts.
Q: How much data does a video call use?
A: This varies by the app you use. A rough estimate/average is 250MB/0.25GB per hour (or four hours of video calls per 1 GB of data).
Q: I am not sure if this a platform that Accend is already exploring for Telehealth - but I know for clients of mine that have upcoming appointments with WebMed Mental Health Services in Duluth that WebMed is conducting all their appointments now by Telehealth via 'RingCentral' (https://www.ringcentral.com/home_p.html ) Staff at WebMed informed me that this is apparently a HIPPA compliant platform? Don't know if this is helpful for our agency, but I figured I'd share just in case!
A: Thanks for the suggestion. We not long ago attempted to use RingCentral for office voice telephone service and quickly realized that they were not up to the task. The 5-figure investment in hardware to use their service was a complete loss. The overall experience was a nightmare.
Maybe RingCentral has upped their game, discovered their real strengths, and/or changed their mission/focus, and might be a good option for Telehealth now. Worth checking into at the least, in spite of our sour past experience. We'll put them on the list of options to explore.
Anyone else have experiences with RingCentral that could help us evaluate this option? Send your thoughts in the feedback link above.
Q: What does DHS Commissioner Jodi Harpstead's statement from March 20, 2020 mean for Telehealth options, like services by telephone?
A: Nothing in that statement is a specific action plan or authorization. It only previews what kinds of flexibilities DHS will be pursuing. We're optimistic. We will publish new guidelines as we received them from DHS.
Update: March 26, 2020: Telephone services are not allowed.
Q: What is the effective date for telephone only services? Will it boost productivity for the pay period that just ended?
A: No telephone-only services were authorized prior to March 28, 2020, nor should have been provided, so there should be no impact on past productivity.
Q: Will the authorization form need to be updated now that we can provide telephone-only services?
A: Just the list of prefered methods in the form itself to include telphone-only. That's already updated.
Q (Previous to authorization): I am having a lot of contact with clients via phone, and am wondering if it would make sense to capture that as "Telehealth, phone only" in the event that the phone services is approved?
As of now, I am capturing this time under contact and scheduling. Would there be an opportunity to go back and change the service type (and make it a billable service) if we do get approval for phone service?
A: You're thinking ahead, thanks. We expected word by now on telephone-only delivery of services, but nothing so far. We'd recommend you limit the amount of time spent on the phone only and explore options for approved telehealth for now. We'll let you know as soon as we know anything more.
Update: March 28, 2020: Telehealth by telephone was authorized on March 28. 2020. No telephone-only services prior to that date are authorized, unless you are notified. And, your telephone-only services must meet the definitions of those specific services found elsewhere in this guide.
>> Minnesota Telehealth Statute 256B.0625
>> Minnesota Healthcare Programs Manual: Telehealth Delivery of Mental Health Services Chapter
>> Mn Statute 62A.67
This guide is a living document. We want to improve it with your help. Do you have questions? Found a typo? Find yourself wanting more information? Please send us your thoughts about anything in this chapter by tapping on the link below.
April 14, 2023
Link to Mn Statute 62A.67 added to Resources and References
May 25, 2022
Telehealth Locations are changed to include separated location types for Audio-Only, Audio and Video, and for telehealth services when the client is at home, or not at home.
The term "Telemedicine" where used in this guide is changed to "Telehealth."
July 13, 2022
Instructions for the location description added for telehealth services
March 10, 2023
Resources and References added.
BHH temporary suspension of the 90-day face-to-face contact rule eliminated. This service may still be provided using telehealth.
Language on Case Management changed to use the term Interactive Video per state requirements, and significantly limited.
Language added that audio-only telehealth services are authorized only until July 1, 2023.
May 12, 2022: Effective until June 30, 2023, services provided by audio-only communication (telephone) with the location "Telehealth" following the rules defined in this guide for delivery of Telehealth services.
Additionally for all services, use the meeting type "Telehealth" for audio-only communication (telephone).
This temporary change is authorized by the MHCP Manual.
November 18, 2021: Verbal consent on the treatment plan clarified based on 2021 legislation.
April 5, 2020: Flexibility in telephone service delivery for Case Management and Behavioral Health Home Services has been outlined here.
April 2, 2020: Psychotherapy is now allowed via telehealth (excluding telephone) for Medicare-only patients.
March 29, 2020: Google Duo is added to the list of temporarily approved communication apps for telehealth.
March 28, 2020:
The State of Minnesota Department of Human Services has announced that federal approval has been obtained for the following:
Until further notice, telephone visits (voice only) are now allowed for Telehealth services described as appropriate in this policy.
The requirement for face-to-face visits every 90 days for Case Management services is temporarily suspended. Case Management services may continue by telephone only even if there has not been a face-to-face service in the past 90 days.
The first visit with a referred individual may also be conducted on the phone.
Limits of Telehealth to no more than three visits per week are temporarily suspended.
March 25, 2020:
Expansion of the definition of Telehealth to provide services by telephone in Minnesota are awaiting federal approval. We'll let you know when you can start.
Additional guidance on what services delivered by Telehealth should look like when approved.
Additional guidance on what services cannot be provided by Telehealth.
Fixed some broken internal links on this page.
March 24, 2020: (Not so much and update as a reminder.) You may have heard rumors of other agencies expanding their definitions of what qualifies as telehealth. These agencies are ahead of permission from DHS in going ahead with these strategies. Do not assume you can follow the policies that you have heard other agencies are implementing. We plan to wait for specific permission/go-ahead from DHS to implement changes.
No Telehealth services that do not conform to this policy and to the definitions of the specific service found elsewhere in the guide are allowed.
This update was updated again on March 28, 2020.
March 21, 2024:
The following language was replaced with language that verbal consent for a Treatment Plan is no longer allowed.
For mental health services or assessments delivered through telehealth that are based on an individual treatment plan, the Minnesota Healthcare Programs Manual: Telehealth Delivery of Mental Health Services continues at this time to allow that the provider may document the client's verbal approval or electronic written approval of the treatment plan or change in the treatment plan in lieu of the client's signature.
June 2, 2023: Telehealth services by audio-only technology (example telephone) remain authorized through June 30, 2025 per legislative action. (The previous expiration date was June 30, 2023.)a
January 5, 2024: Telehealth services allowed technologies list updated and shortened.
