Telehealth is a critical component of efficient services delivery for many more services than applied for. 

Please consider telehealth as applicable to consumer directed services facilitation. 

Services Facilitation, by nature, is an exceptionally administrative approach to service provision when compared to applied for services such as Community Coaching, Group Day, Group Supported Employment, Individual Supported Employment, In-Home Support Services, and Workplace Assistance – which are all billable and amenable to “direct support” (hands on) services provision, most of which are often provided in a community or setting outside of the home. 

To include Workplace Assistance in a telehealth modality (which includes the "facilitation of maintenance of and inclusion of the individual in an employment situation" specifically identifying allowable activities of "routine supports with personal care needs") seems counter-intuitive.  Assisting an individual with their personal care (and other) needs in a workplace setting requires on-site support, while another services, providing actual administrative services of the same nature, requiring no hands-on support (Services Facilitation), has no flexibility to meet the needs of the family in an often-preferred telehealth modality.   

Many families are already burdened with meeting their support coordinator, service facilitator, care coordinator monthly, in addition to negotiating a variety of other personal services and appointments.

Telehealth with an in-person visit requirement along the same lines as case management would greatly relieve many family support needs, compliance efforts, and very much relieve some of the current workforce crisis that many providers are currently facing. 

Your consideration is appreciated; 

Ashley Grant