RCPA Telehealth Position Statement

After 18 months of telehealth service implementation, the Rehabilitation and Community Providers Association (RCPA) has conducted provider telehealth satisfaction surveys, created a provider telehealth task force, and developed policy positions regarding the future of telehealth services. As the Wolf Administration, the Pennsylvania General Assembly, and the Department of Human Services seek to make telehealth services permanent, RCPA sets forth our telehealth service recommendations for implementation across the Commonwealth of Pennsylvania. RCPA has compiled the provider comments from these efforts and we believe the following recommendations represent a viable and successful pathway for practitioners and those in need of services.

We offer these recommendations to the provider community to share with stakeholders and legislators as we move forward with the expansion of telehealth services.

RCPA Strongly Recommends and Endorses the Following Telehealth Standards:

• The delivery of virtual services through telephone use only, absent video, should be permitted when the individual served lacks video capability or during an urgent medical situation.
• Payment for services delivered through telehealth should be paid at the same rate as a comparable, in-person encounter.
• Use of telehealth should be expanded to cover services provided by non-clinician mental health practitioners, including unlicensed master’s level therapists, mental health targeted case managers, and mental health certified peer support specialists.
• Use of telehealth should be expanded to include services provided in non-clinical settings.
• Documented verbal consent in the medical record should be acceptable for consent for treatment, verification and acknowledgement of treatment/service plans, release of information, and privacy (HIPAA) notices, in the event that a signature cannot be obtained from the individual served or their legal guardian.
• Given that telehealth use is deemed clinically appropriate, the preferences of the individual served and their caregivers should be given the highest priority when making determinations regarding service delivery method.
• Telehealth service delivery should be expanded to include drug and alcohol providers licensed by the Pennsylvania Department of Drug and Alcohol Programs, including but not limited to counselors, certified recovery specialists, case managers, physicians, physician assistants, nurse practitioners, and nurses for services reimbursed through the MA program.
• Translation services, including sign language interpretation, should be available for all telehealth encounters to ensure equitable access for all individuals.
• Dedicated funding for the expansion of broadband accessibility should be allocated to ensure access to critical services for all Pennsylvanians.

Contact RCPA Children’s Division Director Jim Sharp or your RCPA policy director with questions.