By John Fisher, JD, CHC, CCEP
Wisconsin Updates Telehealth Guidance for Mental Health and Substance Abuse Programs
Client Alert: August 11, 2015
What Changed?
The Wisconsin Division of Quality Assurance (DQA) has issued updated guidance on the use of telehealth in certified mental health and substance abuse treatment programs. The new memorandum, DQA Memo 2015-011, replaces older guidance from 2004 and reflects how much telehealth technology has changed since then.
For providers, the update may make it easier and more affordable to use telehealth tools while continuing to meet state certification requirements. The overall goal is to support broader access to care for patients in Wisconsin.
Why It Matters
Programs that want to offer services by telehealth should review their certification status, policies, staff training, and technology safeguards before beginning or expanding telehealth services.
Which Services Are Covered?
The guidance applies to certified programs that use telehealth for counseling, psychotherapy, medication management, or related clinical consultation. Covered services may include outpatient care, crisis services, community support services, comprehensive community services, day treatment programs, inpatient services, and other qualifying services.
What Providers Should Do
- Confirm that staff who provide telehealth services are properly trained and meet all applicable program and telehealth certification standards.
- Identify in the program’s telehealth plan and policies which staff members will provide telehealth services.
- Make sure telehealth equipment used for clinical supervision or collaboration complies with all applicable DQA requirements.
Important Limits to Keep in Mind
- Telehealth services are not available for narcotic treatment services certified under Chapter DHS 75.15 or for certain mental health inpatient services certified under Chapters DHS 61.71 and DHS 61.79.
- Telehealth cannot replace the required face-to-face assessment for continued use of restraint or seclusion in an inpatient setting.
Supervision Considerations
Programs may use telehealth equipment for clinical supervision and collaboration, but they must still meet all supervision and collaboration requirements. This includes requirements related to transmission quality, privacy safeguards, and restrictions on storing transmitted information.
Providers should also note that clinical supervision for substance abuse counselors still requires at least one in-person meeting each month.
Bottom Line
The updated guidance gives Wisconsin providers more flexibility to use telehealth, but certification, staff training, program policies, and patient safeguards remain essential. Providers considering telehealth should review the memorandum and certification application carefully before implementation.
