So, John, let me ask you a few questions. People are active on the board. So, a group of questions are not surprisingly around what technology should I use that's HIPAA compliant. So, let me ask you about a few of them, and hopefully you know about them. So, is Gmail video chat HIPAA compliant? So, like, I'll have to post this to our website as a question, because I haven't, likely not, because again, you need a business associate agreement with the company to use. So, just because the technology is encrypted, if you're using it as part of clinical care, you do need to likely have a BAA, a business associate agreement, with, in this case, it would be Google who makes Gmail, just like with Skype, you would need a business associate agreement with Microsoft, who makes it. So, I don't, I know there is Google, there's a professional version of Google Mail, and if that has a BAA, that you've told them what you're using it for, and Google understands it, and they're kind of saying that we are guaranteeing it meets these security requirements. So, it could be, I guess, is the answer, depending on if you have a business associate agreement with them. But if you don't, likely the answer is no for Gmail video. Okay. What about, two people have written in about what kind of software do you recommend for using when you're doing tele-mental health to do testing? Do you have any tips on that? So, if you're doing testing, again, as we talked about in the last paper, if you, none of us want to upset our patients, and we're not going to make patients paranoid, but if you want to get upset patients, you're going to have a bad internet connection, you're going to have poor video quality, you're going to have buggy software. So, I would say if you're testing, you're not seeing patients, you're just testing of a colleague, you can certainly test your network, your internet by doing Google Hangouts, by using Skype, but you do want to then test with the actual platform you're using to make sure there's no changes to the bandwidth requirements for what it's doing. So, you really do want to test with what you're doing. You can do some initial tests to make sure you can run Google Video, you can run Skype, but you really do want to actual test it with your platform, again, make sure it's crystal clear. Yeah. I think they meant to do neuropsych testing with a patient. Oh, sorry. That's okay. That's okay. So, if they were doing some sort of psychological testing, like this is a clinical psychology intern and another person wrote in, like what software is, is there a particular software that's better for that or would you just use your usual? So, like they used Zoom in the past to deliver interventions, but it doesn't work well for testing. So, for some of the testing, when the test is owned by, it's copyrighted or owned by a company, say like Pearson, there's a lot of educational testing, Pearson will have its own kind of educational, Pearson will have its own platform to access certain tests that you'll have to use. If you're just using, if you're administering the test yourself kind of remotely, you could be using any kind of video platform that's HIPAA compliant, but if you're doing kind of specific tests on the computer that involve running a program where you're kind of dragging or dropping things or patients are sorting cards or taking intelligence tests, usually the trend seems to be the companies that own those tests have built their own platforms. And when you sign up to do that, you sign a business, a BAA, a business associate agreement with them. Got it. Can you use tele-mental health to act as an attending for a psych unit in a rural area where the clinician staff patients with you? So there's a clinician at the site, but you're the attending via tele-psych. Have you, have you seen that arrangement before? So I think it depends on who is going to be the position of record or clinician of record delivering the care, if that makes sense. So if you're offering a consultation, if it's going to be in your name as the attending position, you would need to have the license in that state. At the end of the day, the liability and billing is going to be attending, not the resident. You would need to do it. If you're offering consultation to the trainee or advice, that would be a cross-state consultation, which is actually a kind of, the American Psychiatric Association just put out an update on that. That's a little bit more complex, but certainly if you're supervising someone, at the end of the day, your license and your name is the one that's responsible, you would need to have the licensure in that state. Okay. So this person says, I'm particularly interested in the tele-mental health needs assessment. Where can I find that document or that information? So this is a good question, saying the first kind of part in kind of the tele-mental health best practices is doing this needs assessment, being to learn about how can you do it? What are the capabilities? What would the business implications be? What are the safety implications? And there's a couple, the best way may, if whoever has that question, they can submit a consult about this. I can then upload or send a form. I'll send it, post it publicly because there's a couple of states that have put out forms. Alaska has put out a form and I'll put a shameless plug for the learning collaborative we're going to have. The learning collaborative actually is going to go through over a course of weeks and really go through each aspect of that and say, how do we understand readiness for tele-psychiatry? How do we evaluate our capabilities? How do we learn to access the resources to say, what is the medical implications? What are the legal implications? What are the professional implications? How do I pick a platform? What do I consider? So it's a good question. And I said, if someone can submit a quick consult that really says, can you share some forms, I'll share you existing forms that you can look through and realize that we'll have a whole learning collaborative to fill out those forms. Great. The person said they're going to submit a consult. Excellent. All right. Can you, someone said, these are sort of, again, I think there's a lot of questions about what platform should I be using? Is there, for example, top three platforms you recommend? Or are there free platforms you recommend? Or how can someone figure out what platform they should be using? How does someone start to find a platform? Good question. What platform? The American Telemedicine Association, ATA, used to have a buyer's form that was basically trying to be a consumer report of picking a platform. But if you look, and I looked in researching for this webinar, the ATA's buyer form went away in part because there are so many detailed factors that go into which platform to pick. What is it offering? Are there interesting state nuances that may matter for it? And I think depending on what you want to do, it's kind of, we've had platforms on how tricky it is to pick a smartphone app. And that's kind of offering usually one service or one thing. I wonder if the best way, if you're curious about a platform of questions, if you submit a consult, I think all the SMI advisor can kind of work with you to say, what are you trying to use it for? What are your needs? What are some of your considerations? And we can go through it from there. Because some of these platforms have even different business models where you're paying a percentage of clinical income, you're paying per use. You're giving up patient data anonymously that the company owns. You're not giving it up. You're able to document in a platform, some you're not able to document in. There's a lot of varieties in these. So I think these may be really good for individual consults. So we can kind of work with you to help understand it because the point being, it's complex. And again, even if the American Telemedicine Association took away its buyer's form, that just tells you there's a lot of pieces in this that are not even, even the ATA couldn't find a simple way to answer this question. There are so many questions still left. I hope these people will put in consults since we're, I'm going to have, I think one more, one more question then we have to end. So a nurse practitioner at my facility stated that she is unable to prescribe controlled substances via telehealth. She would have to see them in person to do so. Is this true? Not true? Does it depend on the practice location? So we talked about the Ryan Hath Act, which says you're prescribing controlled substances. You have to initially see the person in person at least every 24 months, but that's the federal level. And states and even healthcare systems may have additional rules that can be more burdensome in terms of needing to see, burdensome is not the right word, but kind of increased requirement needing to see people. But certainly at a very minimum, you would need to see the person with an in-person evaluation at least once to meet the federal requirements. Again, depending on your state, even perhaps your county and your healthcare system, there may be rules that kind of require even more. So it is certainly could be possible what's happening, what that nurse practitioner is experiencing. Okay. I have to ask this one last question. Can a session recording count as documentation? So we kind of went over the best practices and American psychological best practices saying you should be documenting a tele-psychiatry visit the same way you would document a in-person visit. So you should be writing a note and documenting it. So I think the answer to that would be no, unless there's a new law or regulation that's popped up. But I think you would maintain the same kind of standards around documentation as you would in face-to-face care. Okay.

tele-mental health

HIPAA compliance

Gmail video chat

software recommendations

session recordings