Telehealth Feature Specification Template

You need a HIPAA-compliant video solution with a signed BAA. Zoom for Healthcare (not regular Zoom) satisfies this. Purpose-built telehealth video platforms (Twilio Video, Daily.co, Vonage) offer more flexibility for embedding into your application and customizing the clinical workflow. Regular consumer video tools (Zoom, FaceTime, Google Meet) are not HIPAA-compliant without specific configurations and BAAs.

Build audio-only as a first-class experience, not a last resort. CMS permanently authorized audio-only telehealth visits for certain service types after the pandemic. Many state Medicaid programs also reimburse audio-only visits. Design your intake, clinical documentation, and billing flows to work without video. Track the percentage of visits that fall back to audio and investigate root causes.

For synchronous video visits, use standard E/M codes (99201-99215) with modifier 95 and place of service 10 (telehealth in patient's home). For audio-only, use 99441-99443. For asynchronous/store-and-forward, use 99421-99423. Payer reimbursement varies. Commercial payers often follow CMS guidelines with some variation. Always verify with each payer. Your billing team should maintain a payer-specific telehealth reimbursement matrix.

The Ryan Haight Act requires an in-person evaluation before prescribing controlled substances (Schedule II-V), with limited exceptions. The DEA issued temporary flexibilities during the COVID-19 public health emergency. Check the current DEA guidance and state-specific rules. For most telehealth urgent care use cases, avoid controlled substance prescribing in the initial release and add it later with appropriate safeguards (video-only, identity verification, state-by-state rules engine).

Section 508 (for government contracts) and the ADA require digital health products to be accessible. Key requirements include: closed captioning or transcription for deaf/hard-of-hearing patients, screen reader compatibility, keyboard navigation, language interpretation services, and TTY/TDD support. Many health systems also require WCAG 2.1 AA compliance as a procurement condition. Build accessibility into V1, not V2. ---