Telehealth services for rural and remote clients

The Better Access telehealth services can be delivered by eligible allied mental health professionals, specifically, psychologists and eligible occupational therapists and social workers. Find more information about eligibility for providers.

No. Refer to the Australian Government Department of Health - Better Access Telehealth Frequently Asked Questions.

Yes. The referral arrangements for psychological services under the Better Access Initiative apply to telehealth services. Information about referral requirements are contained in the Medicare Benefits Schedule.

Clients must meet the usual requirements for a Better Access service and  be in a rural, remote or very remote region at the time of the service. The client must also be located more than 15 kilometres by road from the providing practitioner. Find information about eligibility for Better Access to mental health, and  for specific information about telehealth eligibility)

The Australian Department of Health uses the Modified Monash Model (MMM) to classify geographical regions. The MMM replaces the Accessibility/Remoteness Index of Australia (ARIA). Find out more about MMM. Rural, remote and very remote regions are classified as regions MMM4-7.

The Doctor Connect website contains a searchable online map that can be used to check whether the client is located in regions MMM4-7.  Go to the Doctor Connect website and then enter the client’s postcode. The search will identify the MMM region classifications from MMM1-7.

Yes, if the client has a valid referral and is in a MMM4-7 region at the time of service.

Psychological services provided under the Better Access initiative are expected to be for the purpose of providing treatment to eligible clients with an assessed mental disorder. However, some assessment activity may form part of the initial consultation with the client, for example, to enable the practitioner to confirm and refine a differential diagnosis or to identify a baseline for establishing the client's progress in response to the treatment provided.

It is anticipated that any assessment provided will be appropriate to the client's presentation and the likely condition to be treated, and will be necessary in informing and directing provision of treatment to the client. Any assessment should occur in preparation for treatment and generally should not extend beyond the initial consultation with the client.

Yes. Refer to the Australian Government Department of Health - Better Access Telehealth Frequently Asked Questions.

No. Medicare benefits are not available for Australians who are overseas at the time of the service.

All ten Better Access sessions available to eligible clients in a calendar year can be delivered by telehealth.

Yes. The client has had 6 sessions under the Better Access initiative and will require a review by their referring practitioner to access further sessions.

The Better Access telehealth item requires an audio and visual link. If you cannot establish this at the outset of a session, the item should not be claimed.

However, the welfare of the client must be considered and you may need to speak with the client by telephone or instant messaging (chat function) to discuss options and address any risk; this service cannot be claimed under Medicare. It is good practice to establish a plan with the client, on intake, about the process to use if communication problems occur at the beginning of a session.

If the session is well under way when the link breaks and the videoconference cannot be re-established within a reasonable timeframe, then the provider may need to consider contacting the client via telephone or instant messaging (chat function), if possible, to ensure the safe and appropriate conclusion of the consultation. The telehealth item number can only be claimed for the period when the videoconference (audio and visual) was in place. This may mean the provider has to use the item number for a short session.

It is good practice to establish a plan with the client, on intake, about the process to use if telecommunication problems occur during a session.

The government does not mandate the requirements for telehealth technology. Refer to the document “Principles for selecting telehealth technology” for more information.

For clients with limited access to the technology required for telehealth, the options available to them will depend upon services within their community. Providers may explore whether there are dedicated and private videoconferencing services available at GP clinics, community health centres, or remote area clinics.

It is important that providers consider the privacy of the client during the telehealth sessions. As such, redirecting the client to a public library, for example, would be considered inappropriate for privacy and confidentiality reasons.

The Privacy Act 1988 (Commonwealth) (Privacy Act) (see www.legislation.gov.au) applies to all private practitioners. The Australian Privacy Principle (APP) number 11 is particularly relevant to keeping personal information secure.

In a telehealth environment, this means providers are required to take “reasonable steps” to secure personal information such as addressing the potential for interference or breach of privacy if a telehealth session or email (e.g., homework, invoice) is ‘hacked’ or a recorded session is lost or stolen. 

It is good practice to ensure client files contain contact details for several people that the client has nominated can be contacted in a crisis, copies of all consent forms and contingency plans, and information on the technology employed and any difficulties that occurred with the technology during the session. 

As with all psychological services, providers are required to make clinical notes but there is no requirement to record a telehealth videoconferencing session with a client.

If the provider wants to record a session they need to discuss this with the client and obtain the client’s consent. In some jurisdictions it may not be legal to record a consultation without the explicit consent of all people who you intend to record. For example, if there is a third party to the consultation (e.g., partner, parent, carer) then you would need to obtain explicit consent to record the session from the client and also the third party.

Providers should ensure the recording of the session as well as the storage, use and disposal of the record of the session meet the relevant privacy and health records legislation.

If the client has not accessed all 10 sessions per calendar year and has a valid referral, the client will be eligible for telehealth services. However, providers will need to consider whether telehealth would be suitable for the client’s presentation and whether both client and provider have access to appropriate technology to conduct telehealth.

You can read more about these considerations in the “Information Sheet – Considerations for telehealth providers”.

As private practitioners, all telehealth providers under Better Access come within the jurisdiction of the Commonwealth Privacy Act (see www.legislation.gov.au) . The Office of the Australian Information Commissioner’s (OAIC) website contains information about what steps to take if a client’s privacy is breached, such as in the resource Data breach notification – A guide to handling personal information security breaches.

From early 2018, the Privacy Amendment (Notifiable Data Breaches) Act 2017(see www.legislation.gov.au) establishes a new Notifiable Data Breach (NDB) scheme that will require organisations and practitioners covered by the Privacy Act to notify the following where a data breach is made as result of the unauthorised access or unauthorised disclosure of client information:

• The Office of the Australian Information Commissioner (OAIC); and to
• Affected individuals of an eligible data breach that is likely to result in serious harm.

The NDB scheme commenced on 22 February 2018. It only applies to eligible data breaches that occur on, or after, that date.

A data breach occurs when personal information held by an organisation is lost or subjected to unauthorised access or disclosure. Data breaches are not limited to malicious actions, such as theft or ‘hacking’, but may arise from internal errors or failure to follow information handling policies that cause accidental loss or disclosure. The Privacy Commissioner will have the ability to determine if further action is required in the event of such a breach. You can read more about these impending changes on the OAIC website.

Providers need to consider how to address any risk of harm to self or others by the client prior to providing services. Recommendations for working with clients who pose a risk of harm to self or others are provided in the accompanying document titled “Considerations for Telehealth providers”.

Yes

Yes. The specific Better Access telehealth item numbers should be used for services provided by telehealth videoconference. 

Go to How to bill for telehealth for a brief listing or the November 2017 Medicare Benefits Schedule.

Email is not a secure form of communication as it can be intercepted. The Privacy Act (see www.legislation.gov.au) and the state/territory health records legislation require health practitioners to take reasonable steps to secure personal information, including health information such as a client invoices. Providers should consider password protecting the attached invoice when emailing it to a client. Providers could also consider investigating email encryption options but must be mindful of the capacity of clients to open an encrypted email.

It is recommended that providers discuss the privacy risks of emailing invoices with their clients and obtain their explicit consent to do so.

a. Practices using practice management software for MBS billing and rebate claiming

Practices that use multifunctional practice management software for billing and claiming rebates have two processes available:

1. Clients can be invoiced for full payment or bulk-billing, services can be paid for, and client rebates can be claimed for MBS telehealth psychology items via Medicare Online, even though the client is not present at the practice. Medicare details are stored in practice software and rebates claimed through Medicare Online are directly sent electronically to Medicare to be deposited into the person’s bank account.
2. For all bulk-billed telehealth services (and at the time of the service), the client must agree to be bulk-billed through Medicare. Clients will need to provide explicit consent that 1) the service was provided on the specified date and 2) that the rebate is to be assigned to the provider. This consent can be obtained remotely via a secure email methor or secure messaging systems.

Electronic signatures must comply with Medicare legislative requirements to assign a benefit and the steps outlined in section 10 of the Electronic Transactions Act 1999 (see www.legislation.gov.au). See Bulk-billing-videoconference-email consent for an example of an email template.

A copy of the email consent to assign the MBS benefit to the practitioner must be kept on file (either electronically or in hard copy format) for audit purposes for at least 2 years. The email signature does not need to be noted or submitted for electronic claims through Medicare Online.

b. Practices using merchant terminals for MBS billing and rebate claiming (e.g., HICAPS)

Practices that rely upon merchant terminal for payment of services and for claiming client rebates (via Medicare Easyclaim) have two methods available:

1. Take client credit card details at the end of the telehealth sessions (or via telephone at the time of booking the consultation), and manually enter the details into the merchant terminal for full (gap) payment of the telehealth service. Send the invoice and/or receipt to the client via secure messaging (or mailed through Australia Post) in order for the client to claim the MBS rebate either online via their personal MyGov portal or in person at a local Medicare branch.
2. Use the merchant terminal to bulk-bill the telehealth service as the assignment of the MBS benefit can be made directly to the practitioner through this facility. A signed copy of consent to assign the benefit is still required from the client (as mentioned in part a). The practice could then manually post (or securely scan), with reply paid envelopes, merchant bulk-billed transaction receipts to the client for them to sign and send back to the practice.

c. Practices that do not operate with online invoicing or rebate claiming systems (manual claiming)

Practices that use only simple computer generated invoices/receipts (e.g., via Microsoft Word or MYOB) and rely upon manual methods of payment (i.e., cash/cheque, manual credit card forms, or internet deposits) for services and for claiming client rebates have four methods available:

1. Cheque for full payment (i.e., including any gap fee) for the service can be mailed to the practice/practitioner and receipts issued via Australian Post (or secure email messaging) for the client to claim online via their personal MyGov portal or in person at a local Medicare branch.
2. Clients can pay the full payment (i.e., including any gap fee) for the service using internet banking transfers (i.e., Pay Anyone) paid directly to the practitioner/practice bank account. The client can email a copy of the deposit transactions so that the practice can send receipts to client to claim rebates, as above.
3. Bulk-billed services can be invoiced directly to Medicare by :
   • The practice completing the online Medicare Bulk Bill Webclaim Assignment of Benefit Form and then posting it to the client for their signature in a reply paid envelope.
   • The client can download the Medicare Bulk Bill Webclaim Assignment of Benefit Form, sign it, and post it back to the practice to complete and submit manually (or via secure scanning/email messaging) to Medicare.
   • A secure email agreement (see Bulk-billing-videoconference-email consent). An email reply for manually submitted claims will be considered the “signature” to assign the benefit to the treating practitioner if it is noted as “email agreement” in the signature block of the assignment benefit form.

This publication was produced by the Australian Psychological Society Limited (APS). The information provided does not replace clinical judgment and decision-making or legal advice. While every reasonable effort has been made to ensure the accuracy of the information, no guarantee can be given that the information is free from error or omission. The APS, their employees and agents shall accept no liability for any act or omission occurring from reliance on the information provided, or for the consequences of any such act or omission.

The APS does not accept any liability for any injury, loss or damage incurred by use of or reliance on the information. Such damages include, without limitation, direct, indirect, special, incidental or consequential. The information provided by APS does not replace the need to obtain independent legal advice specific to your situation.

The Commonwealth does not make any representation about the completeness, accuracy or currency of the contents of this document and does not accept any legal liability for any loss or damage that may be alleged to have resulted from reliance on it.  The Commonwealth advises all readers to seek, and rely on, their own legal advice about statements in the document, including those that purport to represent an interpretation of the law.  Access to current versions of Commonwealth legislation (such as the Privacy Act 1988) is available at www.legislation.gov.au.