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.
Organization: | |
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Person Completing Assessment: | |
Title of Person Completing Assessment: | |
Date Assessment Completed: | |
Notes: |
# |
Description |
Yes |
No |
Evidence of Compliance or action required Include specific references to documents that support and “Yes” response |
Additional Notes |
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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? |
☐ |
☐ |
# |
Description |
Yes |
No |
Evidence of Compliance or action required Include specific references to documents that support and “Yes” response |
Additional Notes |
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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? |
☐ |
☐ |