(Recorded Webinar) Drafting Policies and Contracts for Virtual Services
The adoption of telehealth as a modality to provide a range of services is rapidly expanding throughout the Health Center Project, fueled by the COVID-19 public health emergency. Adopting policies that govern the provision of care via telehealth is essential to support this expansion in a clinically and operationally appropriate manner, and to promote compliance with applicable laws.
In fact, the Health Resources and Services Administration (HRSA) recently issued Program Assistance Letter (PAL) 2020-01: Telehealth and Health Center Scope of Project, establishing that HRSA “strongly encourages” health centers that provide or are planning to provide health services via telehealth to maintain written telehealth policies that are compliant with Health Center Program requirements; Federal, State, and local requirements; and applicable standards of practice.
In addition to establishing written policies, health centers must also assess whether and how telehealth activities will be supported via contractual arrangements with other providers. Such transactional relationships, while often essential to the provisions of services via telehealth, raise a host of operational and legal considerations, including but not limited to compliance with the federal Anti-Kickback Statute and HRSA requirements applicable to contracting for in-scope services.
This webinar will outline key elements that should be incorporated into your organization’s telehealth policies and will provide sample language that specifically addresses key HRSA-related requirements. In addition, this webinar will describe contracting opportunities, best practices, and the key risk areas, with information regarding the requirements to align such transactions with a “safe harbor” to the federal Anti-Kickback Statute.
- Administrative/Operations Leadership and Staff
- Compliance Officers
- Contract Management Staff
After this webinar, you will be able to:
- Identify key state laws, regulations, and licensing requirements that are applicable to the provision of services via telehealth
- Begin the process of drafting a telehealth policy and procedure that addresses HRSA-related requirements
- Navigate contracting considerations, with a better understanding of best practices and the key applicable federal laws
- Understand the standards that must be satisfied to align a transaction with an applicable “safe harbor” to the federal Anti-Kickback Statute
CARRIE BILL RILEY
Carrie Bill Riley is a Partner in the health law practice group. She counsels a wide variety of health care clients, including Title X grantees and subrecipeints, and other private and public health care providers, on contracting, regulatory compliance, fraud and abuse, and reimbursement matters. Carrie also provides counsel on transactional matters, including formation and agreements for multi-provider affiliations/joint ventures, general contracting, and residency training arrangements. Prior to going to law school, Carrie worked at a Title X regional training center for several years. [Full Bio]
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