Telehealth Group Therapy: Reimbursement & Clinical Issues

Telehealth group therapy give therapists an effective and efficient method to support patient mental health during the COVID-19 crisis.

Telehealth Group Therapy Treatment

As group therapists work to respond during the COVID-19 crisis, online telehealth group therapy sessions are replacing in-person groups. During this time of social isolation, group meetings add a greater protective factor. In addition, telehealth group sessions give therapists an effective and efficient method to support patient mental health during the COVID-19 crisis.

Ethical Practice for Telehealth Group Therapy 

Competency in both group therapy and telehealth services are the basis for offering online group therapy sessions. Telehealth group therapy has seldom been implemented by most therapists, so the legal and ethical frameworks are still evolving.

Emerging literature suggests:

  • Review your ethics code
  • Review evidence-base about telehealth group therapy for your type of group and population
  • Greater risks than in-person
  • Documentation is essential

Privacy & Confidentiality

While session leaders are under an imperative to maintain confidentiality, group members (in most states) are under no ethical or legal obligation.

  • Privacy is the individual’s legal right to control the dissemination of information
  • Confidentiality is professional’s legal duty to protect an individual’s privacy
  • Privacy can be violated by the professional and/or by other group members

So, video platforms are potentially beneficial, especially during the current isolation. Yet, online systems have some hazards that do not exist for in-person group sessions. As a result, each patient’s confidentiality is at greater risk.

Potential Breaches to Confidentiality May Include:

  • Member connects from an unsecured location where a third party can see or hear
  • Members connect using WIFI, which can be compromised
  • Member records or takes a screenshot, picture or records the group or an individual member
  • Member uses such material to threaten or harm another group member
  • Privacy violations can be significant to member and/or family

Compromising a group member’s privacy could affect them individually and potentially impact the benefits of telehealth group therapy. So, group psychologists should alert members to the increased risks associated with telehealth in a group setting.  

Options can be discussed considering risks/benefits of each of these and other precautions:

  • Use nickname, fictitious name or initials on screen
  • Choose to not participate
  • Seek alternative treatment
  • Wear disguise or block face with pre-approved masks that do not interfere with voice (However, this approach seems a bit extreme. Besides, I am not sure this is practical. Masks muffle sound and in a group where people are connecting from their various locations, sound can be a serious issue.)
  • If patients block the video feed of their face, this form of contact may be considered telephone therapy, which is reimbursable outside of the video group session codes. See MEDICARE APPROVES TELEPHONE SERVICE FOR COVID-19 for more information.

Group leaders should outline potential benefits for each member of the group and compare that to any potential for concern.

Telehealth sessions should never begin before patients read and sign the informed consent forms for group telehealth. A discussion with the therapist before the initial session makes sure they are aware of the benefits, risks, and any concerns about confidentiality. The group leader is always responsible to uphold and adhere to the most stringent privacy standards that are possible for each group.

HIPAA-Compliant Video Platforms

Clinicians remain encouraged to use HIPAA compliant platforms for the highest possible levels of confidentiality and security for telehealth group sessions whenever possible. While the privacy guidelines have relaxed during the COVID-19 pandemic, and though HIPAA requirements are not a guarantee of confidentiality, privacy continues to be a central legal and ethical concern when providing telehealth group therapy sessions.

Our federal government waived provider penalties for HIPAA violations with a “good faith” proviso for telehealth services during the COVID-19 national public health emergency.

Screening Appointments Before Group Sessions

Group screening appointments remain a best practice for group leaders before group telehealth sessions, just as with in-person group sessions.

Conduct pre-screening appointments to:

  • Review informed consent
  • Review group guidelines
  • Conduct “tech check” after giving telehealth platform specifications to make sure the connection and technology is adequate
  • Some guidance suggests that WIFI should not be used (but we at TBHI have not found any support for limiting connections to wired connections only. If you have facts from technology experts with references, please help us by posting in the comment box below.)

Set expectations to reduce group dropouts, clarify goals and maintain the integrity within the telehealth group sessions.

Telehealth Technology Preparation Guidelines

Consider these available settings, as per your group’s needs:

  • Choose a multi-point video system with digital waiting room
  • Consider these available settings, as per your group’s needs:
  • Members can be seen simultaneously
  • Simulated backgrounds
  • Member(s) can be removed from meeting
  • Digital waiting room where you post group rules
  • Disable chat to prevent distracting side conversations
  • Allow private question feature but advise members to only use for technical difficulties
  • Disable recording of sessions (recording is discouraged by telehealth research and consensus documents)
  • Conduct a “tech check” before allowing a prospective member to join the group.

Ask them to learn/demonstrate that they know:

  • How to arrange adequate lighting for their face to be completely visible, even in the evening
  • Where/how to mute the sound from their microphone
  • Shut off the sound from their speakers if needed (prevents feedback)
  • Be in the same location they passed a tech check for every meeting
  • Use earbuds or a headset available at every meeting
  • Respect how sensitive the microphone can be
  • Prevent disruptions and intruders

Suggested Telehealth Group Therapy Guidelines

  • Distraction-free, private space
  • No recording of sessions in any way
  • Prevent anyone in the environment from hearing or seeing group interactions
  • Log in with own ID – legal name, pre-agreed nickname, initials, etc.
  • Do NOT use anyone else’s ID upon entry or during interactions
  • Alone & able to speak freely
  • Do not disturb sign on door
  • Seated but not on bed or with bed in view
  • Sit close enough to camera to have their face be seen clearly (if facial expression is important to tx model)
  • Clear background from distractions
  • Turn off text-messaging and/or email
  • Wear appropriate clothing
  • Secure their device’s position
  • Camera at eye level
  • Phones/devices on airplane mode
  • Wear earbuds or headphones
  • Keep microphone close to their mouth
  • Keep speakers low enough so sound doesn’t come back through their microphone to create feedback
  • Dial in by telephone if Internet signal degrades but keep video connection alive.
  • Turn sound from computer off when using telephone to replace audio signal.
  • If video platform fails and connection is lost, exit and return to the virtual meeting room if possible. Stay off your telephone, and wait for directions by [email, text or telephone].

Start sessions by asking if everyone:

  • Can hear you
  • Can see each other
  • Agrees to abide by posted group rules
  • Is on a landline
  • Has sign on the handle of a locked door to their space

Legal Issues for Telehealth Group Therapy Services

Across state lines

Clinicians not licensed in the state from where telehealth group members attend must watch federal and state guidelines. Always consult state licensing board interstate practice policies.

For more information about practicing across state lines see COVID-19: TELEHEALTH ACROSS STATE LINES AND INTERNATIONAL BOARDERS

Telephone vs Video Connections

Telephone-based care is approved by Medicare.

For applicable codes see MEDICARE APPROVES TELEPHONE SERVICE FOR COVID-19. State-based insurance companies may or may not all follow suit.

Check your insurance commissioner websites for your states, and get guidance from third party carriers as applicable. CCHP (Center for Connected Health Policy) maintains an up-to-date portal for information on state law reimbursement policies HERE.

Telehealth Group Therapy Billing Codes

Two code sets for telehealth group therapy treatments fall under the emergency COVID-19 guidelines for Medicare: 

  • CPT Code 90853 Group Psychotherapy by Telehealth (Added March 30, 2020)
  • 96164 and 96165 Health Behavior Assessment and Intervention Group codes

In Summary

As policies change quickly, and each state responds differently to the COVID-19 pandemic crisis, clinicians are encouraged to be extra diligent. The hassle involved in checking current policy and dealing with companies that don’t all comply with state law, reduces the chances that you bill incorrectly and not get paid, or fail to bill at all.

For additional information on the COVID-19 Crisis and how it impacts telehealth services as a whole, see our primer HERE for a complete overview.

Your TBHI Professional Training Options

TBHI specializes in teaching you how to relax when delivering telehealth.  It offers you a step-by-step learning path of online training that helps you be legally and ethically compliant, clinically proficient, and able to handle even the most difficult of clinical scenarios. Take advantage of COVID discount pricing to learn how to sit back and enjoy your telehealth experiences, rather than struggling with ZOOM fatigue and clinical uncertainty. All courses are evidence-based, available 24/7 through any device and most count toward legal and ethical requirements for licensure. Two micro certifications are also available.

    1. Telehealth Group Therapy  — Exciting, highly interactive telehealth learning experience designed to get answers to your questions about legally and ethically managing telehealth group therapy. Digital class will allow you to connect with colleagues ahead of time to ask questions and share answers. Distinguished faculty will lead you through telehealth group therapy theory and exercises.
    2. Telehealth Clinical Best Practices Workshop — Live, interactive webinar, w/ 4 CME or CE hours to discuss preventing and handling complex clinical issues.
    3. Course Catalog
    4. Micro Certifications to give you a broader range of legal and ethical grounding, and allow you to distinguish yourself as a TBHI-credentialed professional on your websites, in social media, directories and other areas.

UPDATED 5-12-2020

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11 comments on “Telehealth Group Therapy: Reimbursement & Clinical Issues

  1. Thank you for taking the time to post this information. With the special discount made available and still so much to learn about telehealth services I may register for some of your training. It looks vital to a growing industry in telehealth.

  2. Thanks for a very thorough and informative article. I can imagine that advising no use of WiFi may be one of the more challenging aspects of the recommendations. How would you suggest having that conversation? What would you advise the patient to do instead?

    • Poonam, Thank you for your comment. After reading your response, I put more thought into this and actually asked a few of my video vendor associates about the technical issues invovled. They all said that is a video platform is HIPAA compliant, the issues of WIFI is a moot point. Many very reputable platforms allow apps, which by definition,l work on mobile devices. They are HIPAA compliant.

      I’m going to change the above blog post to delete the point about not using wifi.

      You always have been a clear thinker, and once again, your input has helped in keeping us all on our toes.
      Thanks again.
      Take care.


  3. yes thank you for this helpful article, have a quick question can we add modifiers GT & 95 at reimbursement time in group therapy charges under 90853?

    • Yes, according to the latest guidance that I’ve seen from CMS, you will want to add modifiers but use “95” after the CPT code in the 1500 form, and “11” in the POS field below that.

      See our other blog posts about COVID reimbursement and the Telehealth Primer that we published a few weeks ago, too. Search here: https://telehealth.org/blog. Also, you may want to see our latest free COVID update webinar, here: https://telehealth.org/covid

  4. Thank you so much for all the good info. Do you have any more specific information (coding, reimbursement, etc.) about reimbursement for group sessions. I’m an MD looking to set up weekly or biweekly sessions on the Covid situation to help patients better manage their anxiety and confusion. We’re already using a HIPPA compliant platform for individual visits that can host up to 10 participants at a time.

    • Dr. Basta,

      Thank you for voicing your appreciation and asking for more. If you want information about general telehealth billing, TBHI offers a highly rated, 3-hour digital course that will clarify many specific questions. You’ll also find that is available 24/7 and it currently comes at a COVID discount of 30% off. See details on the power portion of this webpage, which lists individual TBHI training programs.

      Given the need for even more competencies when working in telehealth than when working in-person, you or your staff may want to consider the wisdom of taking some basic courses to improve your telehealth competencies for general as well as group therapy. Additionally discounted packages of the above-listed individual courses can lead to certifications that are listed here on the TBHI certifications page.

      • Thanks, I may do that although I’ve been doing one on one telehealth for a while now. I was just wondering if there are specific requirements/CPT codes for group sessions.

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