How COVID-19 Could Affect Your Facility
Date: May 13, 2020
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Into Action Consulting, Inc. is committed to keeping you up to date on the latest news from the Department of Healthcare Services (DHCS) in regards to your licensing and certification requirements. Are you concerned about how COVID-19 may affect your facility? If so, we’ve outlined some key points that you should know. 

On March 19, the DHCS released an important update regarding COVID-19 and changes that behavioral health facilities should be aware of. The information notice covers: Behavioral Health services via telephone and telehealth, licensing extensions, fee reductions and waivers, and canceling meetings and gatherings to prevent COVID-19 transmission. 

Below are key points from each important update.


Behavioral Health Services via Telephone and Telehealth:

  • Telehealth is now an allowable mechanism to provide clinical services. The standard of care is the same whether the patient is seen in-person, by telephone, or through telehealth. 
  • The DHCS has encouraged all counties to work with providers to maximize the number of services that can be provided via telephone and telehealth. 
  • The DHCS does not restrict the location of services via telehealth. Patients may receive services via telehealth in their home, and providers may deliver services via telehealth from anywhere in the community, outside a clinic or other provider site. 
  • There are few requirements about which live video platforms can be used, as long as they are HIPAA-compliant. Specifically, providers may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video or Skype to provide telehealth. However, public facing applications such as Facebook Live, Twitch, TikTok, and similar video communication applications should not be used in the provision of telehealth.
  • The U.S. Department of Health and Human Services Office of Civil Rights (HSS-OCR) will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules when providers use telehealth in good faith during the COVID-19 public health emergency. 
  • Services provided via telehealth or telephone, should be documented as they would normally be documented in the patient’s file and a patient’s verbal or written consent for the telephone or telehealth visit should be documented in the file.


Residential and Outpatient Facility Applications: 

  • The DHCS will grant extensions for application deadlines. The assigned DHCS Licensing Analyst will work with the program to address any outstanding and/or needed documentation. DHCS will grant extensions to programs to respond to regulatory and certification standard requirements.
  • On-site audits and site reviews are being conducted virtually. This is a very detail oriented process. For more information about completing a virtual site visit please contact us directly and one of our consultants would be happy to discuss this with you. 


Requesting Fee Reductions or Waivers: 

SB 601 went into effect on January 1, 2020. The new law authorizes the DHCS to establish a process to reduce or waive any fees required to obtain a license, renew or activate a license, or replace a physical license for display. 

In order to submit a request for fee reduction or for the fee to be waived, the facility must include: 

  • Identify whether the request is for a fee reduction or for the fee to be waived 
  • Identify the type of fee requested to be reduced or waived (i.e., renewal application fee, relocation fee, etc.) and the specific fee amount.
  • How this reduction or waiver is specific to the COVID-19 emergency. 
  • The economic hardship or displacement that occurred during the emergency. 
  • Identify the provider type (SUD residential or outpatient)
  • Identify the provider number and legal entity name. 
  • Identify the program/facility name. 
  • List the facility mailing address and the Program Director and contact person. 


Meetings, Gatherings, and Events: 

The DHCS is recommending that facilities follow guidance by the California Department of Public Health and limit unnecessary meetings, gatherings, and events, and convert all possible meetings into virtual events. See guidance in Governor Newsom’s executive order here.


To read the full information notice from the DHCS, please click here

We know this update can seem overwhelming and stressful but we’re here to help! We have a staff of professionals ready to assist you through this process. Give us a call or email us with your contact information and someone will promptly set up a phone conversation or schedule an appointment to come out to your facility for a consultation.

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