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Office of Civil Rights Notification of Enforcement Discretion applies to all HIPAA health care providers, rendering telehealth services under good faith provisions of telehealth during COVID-19 to all telehealth patients until the end of the public health emergency (PHE) Providers who can perform these services in a good faith communication portal include physicians, nurse practitioners, physician assistants, nurse midwives, clinical nurse specialists (CNAs), clinical psychologists, licensed clinical social workers, registered dietitians, and nutrition professionals Office and other outpatient visits can now be rendered to new or established patients (codes 99201-99215) Since the physical examination cannot be performed, the recommendation from the DHHS is for providers to choose the appropriate level of service based on time or the medical decision-making component of the interaction Requirements to render these CTBS services include obtaining one annual consent for the service and be provided by practitioners who cannot bill separately for evaluation and management (E&M) services, such as licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists, and speech-language pathologists (Table 2)
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