Telehealth best practices

• Use a HIPAA-compliant, encrypted platform with a signed Business Associate Agreement (BAA). Consumer FaceTime, standard Zoom (non-BHA), and SMS do not qualify; the COVID-era enforcement discretion for everyday apps has ended.
• Confirm end-to-end or transport encryption, waiting rooms, and unique per-session links. Disable session recording unless clinically indicated and consented.
• Practice from a private, secure location on an encrypted, password- protected device over a trusted network — not public Wi-Fi.
• Ask the client to be in a private space; if others are present or the space isn’t private, document it and adjust.
• Have a backup modality ready (phone) and tell the client in advance what you’ll do if the video drops.

Obtain and document telehealth-specific informed consent before or at the first session (in addition to your general consent). NH requires documented informed consent for telemedicine. Cover:

• Benefits, limitations, and risks of telehealth (including technology failure and privacy risks).
• The client’s physical location at each session and the clinician’s location.
• A verified identity and an emergency contact / support person for each session.
• What happens if there’s a technology failure, and how to reconnect.
• Emergency procedures and the limits of remote crisis response.
• The right to decline telehealth and pursue in-person care, and any cross-state limitations.
• Privacy of the client’s own environment and confidentiality boundaries.

Re-confirm and document the client’s current physical location at the start of every session — it drives licensure jurisdiction and the correct emergency resources.

Distance changes crisis response. Prepare before you need it — ideally at intake and reviewed when risk rises.

• Record the client’s exact address for each session and their local emergency number.
• Identify the nearest emergency department and local crisis line to the client’s location, plus NH Rapid Response (1-833-710-6477).
• Obtain a local emergency contact and agree in advance on when and how you may contact them.
• Know how to initiate a welfare check with local police for the client’s address, and the criteria you’d use.
• Build a safety plan and means-restriction plan that account for the client being alone and remote.
• If video drops during a high-risk moment, call the client immediately; if unreachable and imminent risk exists, contact local emergency services for their location.

Telehealth notes carry the same content as in-person notes, plus:

• Modality used (two-way audio-video vs. audio-only) and the platform.
• Client and clinician physical locations for the session.
• That telehealth informed consent is on file / was obtained.
• Confirmation of client identity and that they were in a private setting.
• Any technology issues and how they were managed.
• The emergency contact and local resources confirmed for that session.
• Correct place-of-service and telehealth CPT modifiers per payer (e.g., modifier 95; POS 10 for the client’s home vs. POS 02).

• Care is generally deemed to occur where the client is physically located. You typically must be licensed in that state — not only in New Hampshire.
• If a NH client travels out of state, you may not be authorized to treat them there that day. Plan ahead and document location each time.
• Check compacts: PSYPACT (psychologists), Counseling Compact (LCMHCs), and the Social Work Licensure Compact as it comes online. Confirm NH’s participation status and that you hold the required authorization to practice across lines.
• Some states offer limited temporary/telehealth registration for out-of-state providers — verify before seeing a client located there.
• Confirm each payer’s telehealth and cross-state coverage rules; NH Medicaid and commercial plans differ.

When in doubt about jurisdiction, pause and verify licensure for the client’s current state before proceeding — this is a common source of board complaints and coverage denials.

• Look at the camera periodically to approximate eye contact; keep your face well-lit and centered.
• Name the medium early: acknowledge the awkwardness, and invite the client to say when something feels off.
• Slow down. Leave extra space for turn-taking; latency eats the natural rhythm of conversation.
• Reflect what you can’t fully see (“I can’t read the room the way I would in person — how are you feeling right now?”).
• Use the screen: share worksheets, safety plans, and psychoeducation on-screen together.
• Attend to the frame — pets, kids, roommates, and phones all shape the session; problem-solve privacy collaboratively.
• Check in on fit: some clients and presentations do better in person. Revisit modality as clinical needs change.