Page 8 - Telemedicine - Essentials of Virtual Care Delivery Part Two
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SVMIC Telemedicine: Essentials of Virtual Care Delivery
During the more flexible pandemic emergency declaration
period and following, providers must be familiar with the
regulations in the applicable jurisdiction pertaining to whether
the physician-patient relationship may be established using
telemedicine.
In general, if a provider renders services that meet the definition
of telemedicine, that may be enough to create a patient-provider
relationship. Keep in mind that, as of this writing, CMS and
other payors recognize an audio-only encounter as meeting the
standard for reimbursement for certain services. That means it
is possible that a single phone call may be enough to establish
a physician-patient relationship. Neither express, written
consent nor an agreement about payment are requirements for
establishing a professional relationship and the duties that come
with it.
Additional Requirements
Licensure Requirements
The default position is that a provider must be fully licensed to
practice medicine in the state where the patient is located at
the time of the encounter. (Federally licensed physicians who
exclusively treat Federal beneficiaries may be exempt from this
requirement.) Some states have issued special, limited licenses
for telemedicine or expedited credentialing for telemedicine
practice. The Federation of State Medical Boards (www.FSMB.
org) has a chart listing each state’s current licensure status, as
many states suspended full licensure requirements during the
pandemic.
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