Checklist: Kicking the Tires of Your Telehealth Compliance

This checklist was developed by attorney Joseph F. Zielinski, with Dinsmore & Shohl. He spoke with attorney Katea Ravega of Quarles & Brady about implementing telehealth effectively and legally April 21 at the Health Care Compliance Association’s Compliance Institute.[1] Contact Zielinski at joseph.zielinski@dinsmore.com and Ravega at katea.ravega@quarles.com.

Telehealth Compliance Assessment Form

Organization:

Person Completing Assessment:

Title of Person Completing Assessment:

Date Assessment Completed:

Notes:

Area 1: Written policies and procedures

#

Description

Yes

No

Evidence of Compliance or action required

Include specific references to documents that support and “Yes” response

Additional Notes

1.1

Do you have a written policy(s) and procedure(s) that describe compliance expectations for telehealth?

1.2

Have you implemented the operation of telehealth compliance program?

1.3

Do you have a written policy and procedure that provides guidance to employees on dealing with potential telehealth compliance issues?

1.4

Do you have a written policy and procedure that provides guidance on how to communicate telehealth compliance issues to appropriate compliance personnel?

1.5

Do you have a written policy and procedure that provides guidance on how potential telehealth compliance problems are investigated and resolved?

Area 2: Designate an employee vested with responsibility

#

Description

Yes

No

Evidence of Compliance or action required

Include specific references to documents that support and “Yes” response

Additional Notes

2.1

Has a designated employee been vested with responsibility for the day-to-day operation of the telehealth compliance program?

2.2

Are the designated employee’s duties clearly defined?

2.3

If the designated employee’s telehealth compliance duties are combined with other duties, are the telehealth compliance responsibilities satisfactorily carried out?

2.4

Is there a “subject matter expert” outside of the designated employee with oversight of telehealth compliance?

2.5

Does the “subject matter expert” have qualifications satisfactory to be an “expert”?

2.6

Does the designated employee periodically report directly to the governing body on the activities of the telehealth compliance program?

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