When your telehealth link fails, and your telehealth session won’t connect when trying to initiate a client appointment, it’s essential to have backup options in place. As a therapist, you still need a way to conduct compliant remote sessions with your clients. This is where HIPAA-friendly alternative video chat options come in handy as backup solutions.
Pre-approved Exceptions for Alternative Platforms
The use of Rula’s integrated Zoom platform is required for all appointments to ensure a secure, HIPAA-compliant environment and to facilitate accurate time-tracking for your sessions. You may only use a platform other than Rula’s Zoom if one of the following pre-approved exceptions exists and you clearly document the specific pre-approved exception in the session's progress note:
- Technical Difficulties: In the event of a significant platform outage or localized technical failure.
- Patient Request: When a patient specifically requests an alternative secure video platform or phone call due to accessibility or preference.
Note that using another platform does not eliminate your HIPAA obligations.
HIPAA-Compliance
Providers are responsible for ensuring any alternative platform chosen complies with applicable legal and regulatory requirements, including whether a Business Associates Agreement (BAA) is appropriate for platform use involving PHI.
Please note that Rula patients have provided informed consent to receive emails and texts that are unencrypted (details here and here), which provides additional protections against HIPAA risks.
Action Steps for Providers
To comply with the law, the following steps should be taken by you as a provider if you would like to use a video platform as a backup (instead of the phone) when an provider portal link is not working:
- Create an account that supports HIPAA compliance and execute a BAA with the vendor where required.
- Obtain a Business Associates Agreement (BAA) with the service, if needed.
- Continue to schedule all patient appointments within the Rula provider portal.
- Our system will continue to send Zoom links to patients 24 hours prior to their appointment.
- If, and only if, the link within the Rula provider portal is not working, please email the client in real time via the email address on file with a video link you created through your personal account. This link should only contain the meeting link and no unnecessary PHI.
- Continue to document as you normally would to identify the location of service as telehealth/video.
Session Timing and Billing Compliance
Our system is designed to automatically record face-to-face time spent with each client and import that duration directly into your clinical note to alleviate the burden of manual time-keeping. When transitioning to an alternative platform or phone call, please adhere to the following compliance standards:
- No Manual Adjustments: Session start and end times generated by the system should not be changed manually.
- Rare Exceptions: Manual edits should only occur in rare instances of technical difficulties where the recorded time does not reflect the actual face-to-face duration.
- Documentation: Any manual change to session times must be justified and documented in the progress note to remain compliant.
Documentation Requirements for Coding Time-Based Services
Accurate documentation is the foundation of billing integrity. Whether providing psychotherapy or psychiatry/medication management services, in order to bill for those codes on a time-based basis, providers must meet specific documentation requirements:
- Face-to-Face Time: We can only bill for the actual face-to-face time spent with the client. Time spent on documentation or waiting for a late arrival cannot be counted toward the session duration.
- Upcoding Risks: Billing for a higher-complexity CPT code than the service actually provided (e.g., billing for a 60-minute session when only 40 minutes were face-to-face) is considered "upcoding" and is prohibited.
Quick-Reference Summary
Requirement |
Standard Policy |
Required Action for Backup/Exceptions |
Platform |
Must use Rula's Zoom. |
Clearly document the specific reason (Tech Issue or Patient Request) in the note. |
Session Times |
Use system-generated times. |
Document and justify any manual timing edits in the note. |
Session Times |
Must reflect face-to-face time. |
Ensure documentation explicitly supports CPT time requirements; no upcoding. |
Technical Difficulties With Video
As stated in Telehealth Appointment Policies, if you experience any technical connectivity issues causing disruption to a scheduled video visit, you must give the client a call. Then, you can go ahead and continue the session by phone. Refer to your initial email from Support if you need to track down the client’s phone number.
For any HIPAA-related questions or concerns, please contact privacy@rula.com.
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