ALCOAST 096/20 - MAR 2020 TEMPORARY CHANGES TO TELEMEDICINE POLICY IN RESPONSE TO THE COVID-19 PUBLIC HEALTH EMERGENCY

united states coast guard

R 201727 MAR 20
FM COMDT COGARD WASHINGTON DC//CG-11//
TO ALCOAST
UNCLAS//N06300//
ALCOAST 096/20
COMDTNOTE 6300
SUBJ:  TEMPORARY CHANGES TO TELEMEDICINE POLICY IN RESPONSE TO THE COVID-19 PUBLIC HEALTH EMERGENCY
A. Health and Human Services Notification of Enforcement Discretion for
Telehealth Remote Communications During the COVID-19 Nationwide Public Health
Emergency dtd 17 Mar 20
B. Telemedicine, COMDTINST 6300.3 (series)
C. Use of Imaging and Recording Devices in USCG Healthcare Facilities,
COMDTINST 6010.6 (series)
1. This ACN provides guidance on the use of popular video chat applications
to deliver healthcare services ("telehealth") during the COVID-19 public health
emergency. REF (A) waives Health Insurance Portability and Accountability Act
(HIPAA) restrictions against using non-public facing remote communication
products, such as FaceTime or Skype, to communicate with patients during the
COVID-19 outbreak.
2. REF (B) allows USCG medical personnel to deliver clinical services via video
teleconferencing (VTC), but requires that VTC platforms be HIPAA compliant.
REF (C) prohibits USCG healthcare personnel from using personally owned devices
to take images or make recordings of patients, or to otherwise facilitate any
other communication or conveyance of protected health information (PHI) in the
healthcare context.
3. The prohibitions in Chapter 13 of REF (B) and Chapter 11.a. of REF (C)
against using personally owned devices to deliver telehealth services are
hereby temporarily waived, but this temporary waiver shall apply only to video
and audio functions for the purposes of patient encounters and continues to
follow the other guidelines outlined in REFs (B) and (C). Use of screen shots,
capturing video or audio of the medical examination, or recording of any audio
or video content of the medical interview is prohibited and subject to penalties
under REF (C).
4. In accordance with HHS COVID-19 guidance in REF (A), USCG healthcare may use
the following VTC products to deliver telehealth services without a Business
Associate Agreement (BAA): Skype for Business, Updox, VSee, Zoom for Healthcare,
Doxy.me, Google G Suite Hangouts Meet. Personnel may also use the following
non-HIPAA compliant private facing applications to deliver telehealth services
during the COVID-19 national public health emergency: Apple FaceTime,
Facebook Messenger video chat, Google Hangouts video, or Skype (preferred).
5. Personnel shall not use public facing applications, such as Facebook Live,
Twitch, and TikTok.
6. The temporary waiver to use personal devices and non-HIPAA compliant video
chat systems is only valid while REF (A) remains in effect.
7. HSWL-SC will distribute additional telehealth guidelines to the field. 
8. Technical point of contact: CAPT Joseph L. Perez, Chief, Operational Medicine,
HSWL Service Center, 757-628-4338, joseph.l.perez@uscg.mil.
9. Legal point of contact: LT Guyer S. Bogen, Legal Service Command Norfolk, VA,
757-628-4435, Guyer.S.Bogen@uscg.mil.
10. RADM Dana L. Thomas, Direct of Health, Safety, and Work-Life, sends.
11. Internet release is authorized.