As we’ve all witnessed, the use of behavioral telehealth has increased exponentially during the COVID-19 pandemic. Clearly, it’s proven an important vehicle for delivering services, particularly in the face of the mental health issues the pandemic has created. As a result, the question of “What are the Joint Commission behavioral telehealth requirements?” has come up frequently. So, let’s take a look at that.

Joint Commission Behavioral Telehealth Standards

In its Behavioral Health Care manual, TJC lists “Technology Based” as one of the settings in which an organization can provide services. (To locate this on your Joint Commission Connect site, click on the Service Profile tab and scroll down to the Settings section where you’ll see Technology Based on the list.) The applicable standards for Technology Based services include all the core standards that apply in other types of behavioral health settings.

Behavioral Telehealth Requirements for Opioid Treatment Programs

In April, TJC clarified in an FAQ that an in-person medical evaluation is still a requirement for new OTP patients on methadone. Also, patients starting methadone cannot receive escalating doses for induction as take-home medication.

Joint Commission Behavioral Telehealth: Human Resource Requirements

Joint Commission behavioral telehealth requirements in the Human Resource area are the same as those for all practitioners within the organization. These include the Human Resources standards for credentialing, orientation, supervision, and training detailed in HRM.01.02.01 – HRM.01.0007.01 in the BH manual.

There is no Joint Commission requirement that an organization delineate telehealth as a separate privilege or clinical responsibility. If your organization has already credentialed the practitioner to provide a clinical service and they’re now providing that same service via telehealth, no additional credentialing (or privileging) is required. See the TJC FAQ Telehealth – Providing Behavioral Healthcare via Telehealth During the COVID-19 Pandemic.

Joint Commission Survey Process for Behavioral Telehealth

The process for surveying telehealth services is similar to the typical Joint Commission survey. The surveyor conducts tracers with a strong focus on the assessment and treatment planning process. Recent feedback from one organization confirmed this:

“The surveyor knew we were providing telehealth because that was on our application. She selected two telehealth cases for review. One was a client who had previously come onsite for services. The other was a new client we admitted directly to our telehealth service.

The surveyor had several questions about the assessment process for our telehealth service. Specifically, she was looking to see if we had done all the required assessments for our telehealth clients. And also that the treatment plans focused on the issues we had identified in the assessments. Same approach as she used for all the tracers.

One area where we got a finding was that we hadn’t yet implemented our outcomes measurement process for our telehealth clients. So, we’ll be doing that real soon.”

Behavioral Telehealth: Best Practices

There are several resources available that offer best practice approaches to providing behavioral telehealth services. For example, TJC recently released Quick Safety Issue 55: The Optimal Us of Telehealth to Deliver Safe Patient Care. It offers several key strategies for ensuring successful telehealth implementation.

Also, The American Psychological Association has issued Guidelines for the Practice of Telepsychology. Similarly, the American Psychiatric Association has developed Telepsychiatry Practice Guidelines that include a Telepsychiatry Toolkit.

Behavioral Telehealth: The Future

In short, behavioral telehealth has proven an effective vehicle both to sustain mental health services and to expand them during the pandemic. Advocates have proclaimed the need for behavioral telehealth for many years. The COVID-19 pandemic may well have set the stage for this critical service to now unleash its potential.

Barrins & Associates Consultation

We’re resuming our Mock Surveys and Continuous Readiness Consultations in full force. Since many of our clients have begun offering telehealth services, we’ve incorporated that review into our mock surveys. As always, our goal is support your ongoing standards compliance and survey readiness!