The Doctor’s Advocate | First Quarter 2022

Nine Tips for Telehealth Clinical Documentation

Sue Boisvert, BSN, MHSA, Patient Safety Risk Manager, The Doctors Company

As the course of the pandemic continues to unfold and threats from new variants appear, many practices and patients are once again considering telehealth options—a trend that may continue even after the pandemic runs its course. Regardless of whether the care is delivered in person or through telehealth, the required levels of skill and expertise and the standard of care are the same.

Clinical documentation plays a significant role in demonstrating regulatory compliance, establishing medical necessity for billing, and defending the provider in the event of a licensing board complaint or professional liability claim. Due to the unique differences between an in-person patient visit and telehealth, documentation plays an essential role in proving that the standard of care has been met. The practice of telehealth creates additional and specific documentation requirements.

Consider the following nine tips for documenting telehealth care:

  1. Modality: Specify clearly in the patient’s record the telehealth modality used. Examples include “secure interactive audio-video session using [name of] telehealth platform,” “telephone medication management consultation,” or “asynchronous diagnostic test follow-up by portal/text/email.”
  2. Geography: Note the patient’s physical location and geography. For example, including “at her home in Tennessee” is necessary for billing purposes and determining venue in the event of regulatory or professional liability action. Also document the provider’s location as “in the clinic,” “from the hospital,” or “from the home office.”
  3. Informed consent: Obtain informed consent for telehealth visits. Advise patients about the risks of a telehealth visit, including the potential for technical difficulties, information security concerns, and that it may be necessary to convert the visit to an in-office visit depending on patient needs. In the progress note, summarize the discussion, the questions asked and answered, and the patient’s decision. Include a copy of the signed consent form. Find our sample “Telehealth Informed Consent” form on our Informed Consent Sample Forms page.
  4. Identity: Confirm patient identity to reduce the risk of billing fraud and medical identity theft. Ask new patients to hold a photo ID close to the camera. Document confirmation of patient identity. Patients also have the right to ask for provider identification.
  5. Appropriateness: Determine quickly if the patient and environmental conditions are appropriate for a telehealth visit. Some patients may not be appropriate candidates for telehealth visits based on their cognitive status. If the patient cannot answer questions or provide an accurate history and no support person is available, the visit may need to be rescheduled. Documentation in this situation might include “the visit was rescheduled at the patient’s request because her husband could not be available.” Evaluate and address distractions in the environment. Document patient assessment, environmental conditions, actions taken, and recommendations made. For more information on addressing patient distractions, see our article “Manage Patient Distraction During Telehealth Visits.”
  6. Others present: Include documentation of all participants. Others may be present at the patient’s location and may assist with or affect the quality of the visit. Document in the progress note the name and relationship of all individuals present on the patient’s side of the interaction. For example, document “visit conducted with child sitting on mother’s lap.” On the provider’s side, document the names of assistants who are present and their purpose. For example, a medical assistant may serve as a chaperone during remote sensitive visual examinations. In addition, document the use of interpreters who assist from a third location by video or telephone.
  7. Assisted assessment: Plan for and provide instructions to patients if they will be performing tasks during the examination. With preparation, patients may be able to measure and report their weight, vital signs, and home point-of-care testing results. Document results and specify “patient provided.” When patients assist in various aspects of physical examination, document the details as “patient assisted.” For more information on patient-assisted assessment, see our article “Strategies for Effective Patient-Assisted Telehealth Assessments.”
  8. Safety concerns: Scan the patient’s environment for possible safety concerns. As the volume of telehealth visits increased during the pandemic, clinicians were afforded a window into patients’ homes and lives that would not otherwise have been possible. This opportunity was both a blessing and a challenge. Visualizing the patient’s surroundings facilitates patient safety activities such as fall reduction, environmental allergy assessment, and brown bag medication checks. In some cases, however, providers may see conditions that require intervention that are not directly related to the visit. Examples include evidence of hoarding, unsanitary conditions, abuse, and potential human trafficking. Objectively document observations, discussions with the patient, recommendations, and follow-up plans.
  9. Quality improvement: Consider revising electronic health record templates to include some of these documentation recommendations as checkboxes, dropdowns, or text macros. Periodically evaluate telehealth visit documentation to ensure compliance with the recommendations.

Following these nine tips can help you ensure that your telehealth documentation is patient-centered, comprehensive, and effective. You can also benefit from familiarizing yourself with the regulatory and payer requirements specific to your practice location(s).

Additional Help

For additional guidance, find our complimentary on-demand education, Telemedicine to Telehealth: Trends and Emerging Risks, or contact the Department of Patient Safety and Risk Management at (800) 421-2368 or by email.

The Doctor’s Advocate is published by The Doctors Company to advise and inform its members about loss prevention and insurance issues.

The guidelines suggested in this newsletter are not rules, do not constitute legal advice, and do not ensure a successful outcome. They attempt to define principles of practice for providing appropriate care. The principles are not inclusive of all proper methods of care nor exclusive of other methods reasonably directed at obtaining the same results.

The ultimate decision regarding the appropriateness of any treatment must be made by each healthcare provider considering the circumstances of the individual situation and in accordance with the laws of the jurisdiction in which the care is rendered.

The Doctor’s Advocate is published quarterly by Corporate Communications, The Doctors Company. Letters and articles, to be edited and published at the editor’s discretion, are welcome. The views expressed are those of the letter writer and do not necessarily reflect the opinion or official policy of The Doctors Company. Please sign your letters, and address them to the editor.