HIPAA standards as apply to a standard office environment. HIPAA compliance also involves informing patients that their protected health information will be traveling by electronic means to another site for evaluation and consultation. This should be noted in the consent form at the point of care, and the HIPAA notice of privacy practices. In addition, all electronic transmissions, including email, should be encrypted and reasonable care should be taken to authenticate those providers who have electronic access to the records. Responsibility and Liability If a provider-to-patient model is used, with no provider at the originating site, the ID physician may bear full responsibility (and potential liability) for the patient’s care. The diagnostic and therapeutic recommendations rendered are based solely on information provided by the patient, any available medical records, and the history and physical examination performed by the clinician at the distant site. Therefore, any liability should be based on the information available at the time the patient was evaluated by the distant site provider. In a consultative model (provider-to-provider), liability may be shared; however, the allocation of responsibilities will vary by individual case and on a state-by-state basis, depending upon regulations. ID physicians should verify that their medical liability insurance policy covers telemedicine services, including telemedicine services provided across state lines if applicable, prior to the delivery of any telemedicine service. In the teletriage and teleconsultation models (provider-to-provider), the referring provider ultimately manages the patient with the aid of the consultant’s recommendations. Downloaded from https://academic.oup.com/cid/article/64/3/237/2912592 by guest on 03 December 2021 IDSA Position Statement on Telehealth and Telemedicine • CID 2017:64 (1 February) • 241 The referring provider may accept the recommendations in part or whole or not at all, and the responsibility and potential liability in this scenario may be shared (between the referring provider and the consultant) based on the extent to which the recommendations were followed by the referring provider. If a direct-to-patient model (provider-to-patient) is used (no provider at the referring site), the responsibility and potential liability rests entirely on the ID physician providing telemedicine services. In this case, the ID physician providing telemedicine services would also be responsible to ensure proper follow-up and to address any medication complications. ANTIMICROBIAL STEWARDSHIP PROGRAMS VIA TELEHEALTH IDSA supports the development of antimicrobial stewardship programs (ASPs) that use telehealth technologies. Using telehealth as a means to administer and conduct ASP-related activities will allow community hospitals (those that are solely owned or a part of a hospital system) to effectively and efficiently participate in stewardship programs. Many community hospitals lack the resources needed to build ASPs or, if resources are available, the resources must be allocated over a wide range of necessary ASP activities. Therefore, using telehealth technologies to administer ASPs will allow for greater flexibility and efficiency for a hospital and its staff. Ideally, ASPs that are administered via telehealth should allow an ID physician: • Access to the facility antibiogram: This facility-specific document provides useful information to ID physicians that will inform the practice of antimicrobial stewardship. • Access to, and interaction with, the facility pharmacy and therapeutics (P&T) committee: The P&T committee will make decisions on antimicrobial usage that will be pertinent to the ID physician providing stewardship services. The P&T committee may also benefit from access to the ID physician. • Access and ability to review a patient’s medical record: The electronic health record will hold pertinent data that will inform antimicrobial stewardship recommendations. • Access and interaction with hospital personnel to deliver educational programs in support of the ASP. • Access to patients when applicable to ASP functions. In addition to the tenets listed, IDSA also recommends that any ASP follow