Temporary Telehealth permission
Duration of temporary Telehealth permission for Alberta chiropractors
Council grants permission for the practice of temporary Telehealth for a limited duration of Monday, March 23, 2020, until Wednesday, June 30, 2021. This temporary Telehealth permission may be terminated, shortened, or extended at the Council’s discretion by another motion from the Council.
The Registrar may remove the right to practise temporary Telehealth permission from practitioners who, at the discretion of the Registrar, are in violation of the rules as established by a motion from the Council.
Termination of the term for temporary Telehealth compels chiropractors who chose to practise temporary Telehealth, to cease and desist performing all Telehealth services on or before 11:59:59 p.m. on the termination date, as established by a motion from the Council. Further completion of Telehealth in any form past the termination date will be referred to the Complaints Director for investigation. This referral may result in a referral to a hearing tribunal and result in tribunal orders including fines, costs and discipline.
Members who will be practising temporary Telehealth must inform the Registrar in the manner required by the Registrar before they can offer Telehealth consultations to the public. The Alberta College and Association of Chiropractors (ACAC) will provide written permission for members that register for Telehealth to provide temporary Telehealth services. No practice of Telehealth will be permitted past the termination date as established by Council.
Temporary Telehealth requirements:
- The chiropractor must be a registered member of the ACAC.
- The chiropractor must have Professional Liability Protection per ACAC Administrative Policy 2.10.
- The Canadian Chiropractic Protective Association (CCPA) has indicated they will cover a CCPA members’ liability that practise temporary Telehealth. It is the responsibility of ACAC members that use other providers to demonstrate to the ACAC that their provider will extend liability coverage to Telehealth consultations.
- Chiropractors who provide Telehealth must physically be in the province of Alberta while delivering Telehealth to patients who are physically in the province of Alberta.
- Consultations provided through Telehealth are subject to the ACAC Standards of Practice and the ACAC Code of Ethics, which guide clinical practice and decision making for all Alberta chiropractors.
- Telehealth is the use of information or communication technologies to allow chiropractors and their patients to connect via telephone, video or other remote monitoring technology to receive applicable chiropractic services at a distance when in-person visits are not possible.
- The provision of temporary Telehealth consultation may only be provided by the registered member and may not be delegated to anyone else.
Temporary Telehealth services can be provided to any patient requesting the service.
- A new patient care relationship may be established with a chiropractor when professional judgement supports the following criteria:
- The care delivered via Telehealth will be fundamentally like care delivered face-to-face.
- The Telehealth consultation will be an appropriate method to deliver service to the patient.
- The requirement for a direct physical examination is not necessary to provide a diagnosis (complete, working, or differential) and the resulting treatment plan.
- Patient factors including physical, sensory, communication, or cognitive deficits will not impact the ability to conduct Telehealth consultation.
- A current patient care relationship is deemed to be established when the chiropractor has already completed all the following:
- An in-person examination that was documented within the last calendar year with the chiropractor who will be providing the temporary Telehealth consultation.
- The chiropractor who will be providing the temporary Telehealth consultation has provided a treatment plan within the last calendar year to the patient as a result of the most recent in-person examination. The patient receiving Telehealth has a signed informed consent to chiropractic treatment form on file. It must have been signed and dated within the last calendar year prior to the Telehealth consultation with the chiropractor providing temporary Telehealth to the patient.
- Temporary Telehealth services that can be provided during Telehealth consultation include the following:
- The chiropractor may consult with the patient or obtain a history.
- The chiropractor may make physical observations and conduct examinations that can reasonably occur via Telehealth.
- The chiropractor may distribute and receive outcome measures from the patient.
- The chiropractor may make a diagnosis or working diagnosis for new patient consultations.
- The chiropractor must deliver a treatment plan based on the history, examination, and diagnosis, for new patient consults.
- The chiropractor must discuss the proposed treatment and options, allow the patient to ask questions, inform the patient of risks as an informed consent to treatment, and document that conversation. A record of the patient’s verbal consent should be recorded when the chiropractor is conducting a new patient consult, or there is change in the proposed course of treatment that leads to a diagnosis, treatment plan and prescription of treatment via Telehealth.
- The chiropractor may monitor, observe, prescribe new, or make changes to existing therapeutic exercises.
- The chiropractor may consult on general recommendations that promote improved health outcomes such as exercise, nutrition, sleep, etc.
- Chiropractors may not refer for diagnostic imaging or diagnostic testing based on the Telehealth consultation. The determination for diagnostic imaging and diagnostic testing can only be determined after appropriate in-person consultation and examination.
- The chiropractor can conduct a triage Telehealth consult or phone call with patients that will lead to a professional decision, as follows:
- The patient is a candidate for emergent chiropractic care, which will require an in-person history and examination that results in a diagnosis and treatment plan for their complaint.
- The patient is a candidate for emergent care that is best served with a referral to a provider other than a chiropractor for their complaint.
Informed consent for temporary Telehealth
As with all chiropractic services, for consent to be valid it must first be informed. In addition to the general requirements for informed consent outlined in the Standards of Practice and related documents patients must be aware of available treatment options, including options to receive in-person care, delay care until in-person care is available, and the unique risks and benefits that temporary Telehealth provides.
The chiropractor will augment the required informed consent process as required in the standards of practice. To support temporary Telehealth delivery the chiropractor must obtain and document verbal consent with their patient:
- To receive services via temporary Telehealth consultation as opposed to in-person care.
- To videotape, record, and store the information and data from the temporary Telehealth session, if the practitioner is planning to record the consultation.
- For the transmission of information via Telehealth technologies.
The chiropractor develops policies and procedures to:
- Verify their identity to patients.
- Verify the identity of the patients whom they are conducting a Telehealth consultation.
- Document the verification policy and processes used.
The chiropractor must also:
Inform patients of any limitations that Telehealth services impose on chiropractic treatment, such as the inability to apply hands-on evaluation and treatment.
- Inform patients of the risks inherent in the delivery of services using Telehealth delivery of services, including risks to privacy of patient information and safeguards the chiropractor is employing to address these risks.
- Consider the relevance and appropriateness of including a “hold harmless” clause for information lost due to technology failure in patient agreements, privacy statements, and consent documentation.
Chiropractors are expected to practice in compliance with all legislative and regulatory requirements relevant to their practice; the practice of chiropractic using temporary Telehealth technologies is no exception. Chiropractors need to be aware of, and comply with, the privacy legislation that is relevant to their practice. Due to privacy legislation, Alberta chiropractors are restricted to providing temporary Telehealth to Alberta residents who are in Alberta at the time of the Telehealth consultation.
The chiropractor is required to:
- Comply with all privacy and security requirements during Telehealth sessions and when they are in contact with the patient through other electronic means such as arranging appointments via email.
- Document privacy and security measures used to protect the patient’s private information.
- Employ authentication and encryption technologies, as well as secure transmission systems and storage mechanisms.
- Develop policies and practices to ensure that patient records cannot be accessed by unauthorized users, tampered with or destroyed, and are protected at both the originating and remote sites.
- Secure all physical devices used in Telehealth when storing patient information related to Telehealth services.
- Maintain awareness of current and emerging risks to patient privacy inherent to Telehealth practice and employ technical, administrative, and physical controls to address these risks.
Services delivered via Telehealth are subject to the same Standards of Practice as in-person chiropractic services; however, several additional documentation and record-keeping considerations must be addressed.
The chiropractor is required to:
- Retain accountability for evaluating any information gathered from a third-party source (such as a non-chiropractor health provider). The chiropractor must determine its reliability and accuracy and the ability to incorporate the information into the assessment or treatment.
- Maintain written records summarizing all interventions consistent with the Standards of Practice.
- Note the duration of the call, inclusive of the start and stop time of the consultation in the clinical record.
- Record the financial record as a Telehealth consultation.
- If a chiropractor does make an audio or video recording, the patient must be informed of the recording, provide consent to be recorded, and the chiropractor must retain that recording as part of the clinical record.
Fees and billings
Chiropractors that are authorized by the ACAC to practise temporary Telehealth are required to have a clear fee schedule for Telehealth services.
Chiropractors are required to adhere to the following fee and billing practises:
- Patients are informed of the services that are eligible for Telehealth.
- Patients are informed of the fee and the service they will receive as part of the Telehealth consultation.
- The patient's record must include a detailed summary of all services provided, including the start and stop time of the consultation.
- Only time spent communicating with the patient can be claimed as part of the service. Time spent on administrative tasks cannot be claimed.
- A chiropractor may only claim one Telehealth consultation per patient in a single day.
- In-person services cannot be claimed on the same day for the same patient.
- Patients are provided a receipt that shows the service occurred via Telehealth consultation.
Chiropractors who choose to offer Telehealth under the temporary Telehealth permission granted by Council are subject to the same regulation as if they were providing the services in person. Chiropractors who offer temporary Telehealth are also accountable to only provide services granted in the temporary Telehealth permission as approved by Council. Failure to comply with the regulations that govern chiropractic practice are subject to the complaints process under Part 4 of the Health Professions Act.
Members application for temporary Telehealth